United States
Environmental Protection
Agency

Region 4

345 Courtland St., N.E.
Atlanta, GA 30365

904/9/93-002
EPA

December 1993

mEPA

FINAL
ENVIRONMENTAL
IMPACT STATEMENT
SUPPLEMENT

Tallahassee - Leon County
Wastewater Management
Tallahassee, Leon County, Florida

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FINAL

ENVIRONMENTAL IMPACT STATEMENT SUPPLEMENT

TALLAHASSEE - LEON COUNTY WASTEWATER MANAGEMENT
TALLAHASSEE, LEON COUNTY, FLORIDA

'	/r;'o?ecti©a

Prepared toys" ' - ' JjZ S3S88
united States Environmental Protection Agency

Cnmmanta and inquiries should be forwarded to:

Bains J. Mueller
Chief, Environmental policy Section
U.S. Environmental Protection Agency, Region IV
345 Conrtland street, N.B.

Atlanta, Georgia 30365
(404) 347-3776
FAX (404) 347-5206

Approved by:

rrnfa*				j /-Z&-9Z

Patrick M. Tobin	Data

Acting Regional Administrator

united states inviromnental Protection Agency

Region IV

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EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY FOR FINAL ENVIRONMENTAL IMPACT STATEMENT SUPPLEMENT

TALLAHASSEE-LEON COUNTY WASTEWATER MANAGEMENT

TALLAHASSEE-LEON COUNTY, FLORIDA

Draft ( )

Final (X)

U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365

Type of Action:	Administrative Action	(X)

Legislative Action	( )

EXECUTIVE SUMMARY

Purpose of and Need for Proposed Project

The City of Tallahassee (City) prepared a 201 Facilities Plan (201 Plan)
that proposed*the expansion of the City's central sewers to serve growth areas
in Leon County. A draft 201 Plan was approved in April 1977. The U.S.
Environmental Protection Agency (USEPA) prepared an Environmental impact
statement (EIS) that evaluated the 201 Plan alternatives and the "No-Federal-
Action" alternative. A Final EIS was issued by the USEPA in 1983 (USEPA, 1983).
The No-Federal-Action alternative was selected as the EIS preferred alternative
in the 1983 EIS.

The 201 Plan and the 1983 Els were required in part because the city had
intended to use federal grants to fund the majority of a proposed expansion of
the City's wastewater collection and treatment facilities. The 1983 EIS
"...addressed the Federal Action of the provision of Federal funds for Phase II
wastewater facilities as proposed by the Draft 201 Facilities Plan for
Tallahassee-Leon County" (USEPA, 1983). The proposed Phase II wastewater
facilities were intended to service growth areas that would not be served by 201
facilities that were already approved for federal funding.

The 1983 EIS considered four federal-action alternatives which proposed
wastewater facility construction of either: 1) a new treatment plant in northeast
Leon County (to serve the northeast growth areas) and the expansion of the
existing Thomas P. Smith (T.P. Smith) Wastewater Treatment Plant/Southwest (SW)
Treatment Facility beyond its Phase I capacity (to serve the southwest and
southeast service areas), with treated effluent disposal for the Northeast (NE)
Plant by means of rapid infiltration in the northeast and disposal of the T.P.
smith/sw Plant by conveyance to the expanded Southeast (SE) Sprayfield; or 2) an
alternative similar to above except disposal of all treated effluent would be at
the SE sprayfield; or 3) expansion (with conservation measures) of the T.P.
smith/sw Treatment Facility to 19.9 mgd capacity or expansion (without
conservation measures) of the T.P. smith/sw Treatment Facility by 0.3 mgd
capacity and continuing to operate the existing Lake Bradford Road Plant, with
treated effluent disposal at the expanded SE Sprayfield and facilities serving
as a regional treatment system in either case; or 4) construction of a new SE
Treatment Plant (serving the southeast and northeast growth areas) to supplement

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the expanded T.P. Smith/SW Treatment Facility (serving the southwest service area
and projected southwest growth areas), with treated effluent disposal at the
expanded SE Sprayfield.

In addition to these four federal-action alternatives, a fifth alternative,
the No-Federal-Action alternative, was also considered in the 1983 EIS. This
alternative considered the given condition within the Tallahassee—Leon county
area without changes and described wastewater treatment that would be available
without new federal funding. Generally, the No-Federal-Action alternative
assumed that no centralized, structural alternative would be constructed, with
expansion of existing facilities only continuing to Phase I levels and new growth
for wastewater disposal to be provided by on-lcst and small community systems.
The No-Federal-Action alternative was the baseline for evaluating environmental
impacts of the structural alternatives considered in the 1983 EIS. As indicated
above, the No-Federal-Action alternative was selected as the preferred
alternative in the 1983 EIS.

since the USEPA issuance of the 1983 EIS, investigations into failures of
on-lot septic systems within the study area and compilations of information
relating to soil types, water tables, and population density have provided data
which were not available during the preparation of the EIS study. Subsequently,
the city of Tallahassee, Leon County's Board of Commissioners, and the USEPA have
determined the need to re-evaluate the No-Federal-Action alternative selected in
the 1983 EIS.

In 1988, the City prepared a Master Sewer Plan (MSP) that proposed
expanding their facilities within the City boundaries. With Leon County's
approval, this expansion was to also include unincorporated portions of the
County, and use monies from a 5-year capital improvements program. These monies
would be from local sources and would not be expected to include federal funds.
Given the decision to re-evaluate the No-Federal-Action preferred alternative of
the 1£83 EIS and the availability of local funds, several other options of the
No-Federal-Action alternative could be considered. These option alternatives
primarily included centralized system alternatives which involved the concept of
spray irrigation of wastewater effluent or other forms of wastewater disposal and
some improvement of existing wastewater treatment plants, and a decentralized
system alternative which involved some improvements and use of on-lot systems.
These option alternatives are addressed in the present EIS, which is a Supplement
to the original 1983 EIS. A Draft EIS supplement (DEISS) was issued by the USEPA
on June 29, 1990 and is hereby being followed by this Final EIS supplement
(FEISS).

The EIS Supplement addresses direct and indirect impacts of wastewater
management alternatives for the study area for a 20-year planning period (1990
through 2010). The study area boundaries used in the EIS Supplement are those
boundaries defined for eight service areas in the 1988 City MSP. These
boundaries were used because the City is the only entity proposing centralization
of wastewater management facilities.

The terms "centralized" and "decentralized" are used in the EIS Supplement
for the development of the system alternatives. Centralized, as used in the EIS
Supplement, refers to a regional system that has a large collection system to
convey sewage from the source to one or two large treatment facilities. These
facilities are generally operated and maintained by a government agency or
authority. Decentralized, as used in the EIS Supplement, refers to a system that
includes a multitude of single-customer, on-lot systems and small
collection/treatment systems (e.g., package plants) servicing a cluster of
customers. The decentralized alternative of the EIS Supplement is similar to the
No-Federal-Action alternative of the original 1983 EIS. The centralized
alternatives of the EIS supplement would also be No-Federal-Action alternatives
provided local funds (i.e., no federal funds) were used.

ES-2

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1988 eitt8^Vy'no?er)o««y^aS •n°t1 regliest.ed a°y federal funds to implement the
?+.	' ? do®s the implementation of the MSP as proposed otherwise

constitute a ®a;jor Federal action" under section 102(2)(C) of the National

thatra^PT^ Qi,n° i1Cy k • ln addition to these three centralized

thia tiiifr!^ i! f Snltt, ' ^ d®c.entralized alternative, was selected during
this timeframe as a fourth alternative for more detailed evaluation.

has low^stimetif	ti0\dUrili9 the 9eneral 1989 timeframe, Alternative 1

hiah 1 v1 e a^t!=>r°a?d P«sent worth value in addition to being

SE sLSfield ?hi«	V® Pr°P°8ea an expansion of the city's existing

sScce^SSv derated	»°uld be an extension of an existing.

Alternative 2 hA 1™ VL+° l"*?1 8Prayfield, effluent disposal system.

Imolementabilitv althounh	4 capital costs and present worth value.

opLatina^ foSaV a^fv	consider?d lower than Alternative 1 because

operators of the existinit	°+ s^stem' including harvesting, is new to the

costs and presentworthvllul * tI****' flternativP 7 has low estimated capital
costs and present worth value, it was selected for more detailed consideration

ES-3

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EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 M6D)

GOLF
COURSE
SPRAY
IRRIGATION
3.0 MGD)

EXPANDED
TP SMITH
PLANT
(27.5 MGD)

EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGD)

GOLF
COURSE
SPRAY
IRRIGATION
(3.0 MGD)

EXPANDED
SE AGRICULTURAL
SPRAY IRRIGATION
(29.5 MGD)

EXPANDED
T P SMITH
PLANT
(27.5 MGD)

SE FOREST
SPRAY IRRIGATION
(7.5 MGD) NEXT
TO EXISTING 2 2 MGD
AGRICULTURAL
SPRAY SITE

ALTERNATIVE

ALTERNATIVE 2

^ EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGD)

EXPANDED
T.P SMITH
PLANT
(27.5 MGD)

GOLF
COURSE
SPRAY
IRRIGATION
(3j0 MGD)

SE WETLANDS
AND RIB'S (6.0MGD)
NEXT TO EXISTING
22 MGD AGRICULTURAL
SPRAY SITE

ALTERNATIVE 3

ALTERNATIVE 4

LEGEND

[""I EXISTING WASTEWATER TREATMENT FACILITY
Q EXISTING EFFLUENT DISPOSAL FACILITY
0 PROPOSED EFFLUENT DISPOSAL FACILITY
¦ EXISTING CONVEYANCE
	 PROPOSED CONVEYANCE

CENTRALIZED WASTEWATER MANAGEMENT SYSTEM
ALTERNATIVES I THROUGH 4

FIGURE ES-I

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EXPANDED
CONVEYANCE

IMPROVED
LB R
PLANT
(4.5 MGD)

NE WETLANDS
AND RIB'S
(5.2 MGD )

EXPANDED
TP SMITH
PLANT
(21.3 MGD)

'expanded

CONVEYANCE

IMPROVED
LB R
PLANT
(4.5 MGD)

NE
PLANT
(5.2 MGD)

A

!

SE WETLANDS
AND RIB'S (3.8 MGD)
NEXT TO EXISTING
22 MGD AGRICULTURAL
SPRAY SITE

EXPANDED
TP SMITH
PLANT
(21.3 MGD)

SE WETLANDS
AND RIB'S (9X1 MGD)
NEXT TO EXISTING
22 MGD AGRICULTURAL
SPRAY SITE

ALTERNATIVE 7

ALTERNATIVE 8

LEGEND

n EXISTING WASTEWATER TREATMENT FACILITY
O EXISTING EFFLUENT DISPOSAL FACILITY
0 PROPOSED EFFLUENT DISPOSAL FACILITY
A PROPOSED WASTEWATER TREATMENT FACILITY
—— EXISTING CONVEYANCE
	 PROPOSED CONVEYANCE

CENTRALIZED WASTEWATER MANAGEMENT SYSTEM
ALTERNATIVES 5 THROUGH 8

FIGURE ES-2

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PAGE NOT
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DIGITALLY

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because it represented a system with both north and south wastewater management
sites which allows wastewater to be managed nearer the source. Alternative 9,
the decentralized alternative, is similar to the preferred alternative of the
original 1983 EIS.

These four further-considered alternatives represent the following spectrum
of possible scenarios: expansion of the City's existing, successful agricultural
spray irrigation operations; use of forest spray irrigation operations that would
have minimal disruption of the site's ecosystem; use of north and south systems
that manage wastewater near the source; and maintaining the status quo of a
"decentralized" system with some improvements.

Below is a brief description of each alternative selected for further

Alternative 2 -

Alternative 7

study:

Alternative 1 - centralization with wastewater conveyed to the south to be

treated at the improved 4.5 mgd Lake Bradford Road (LBR) Plant
and the improved and expanded 27.5 mgd T.P. smith Facility.
Effluent disposal would be handled by agricultural spray
irrigation at the expanded 29.5 mgd southeast (SE)
Agricultural Sprayfield and by a 3.0 mgd golf course spray
irrigation operation using four (4) existing local golf
courses (Florida state University, Jake Gaither, Capital city
Country Club, and Hilaman Municipal).

Same as Alternative 1 except that the 7.5 mgd expansion of the
SE Agricultural Sprayfield would be for forest spray
irrigation rather than agricultural spray irrigation.
Alternative 2 would utilize the expansion areas of the SE
Sprayfield site for forest spray irrigation and continue
agricultural spray irrigation at the existing area..

Centralization with 80 percent of the wastewater conveyed to
the south to be treated at the improved 4.5 mgd Lake Bradford
Road Plant and the improved and expanded 21.3 mgd T.P. Smith
Facility. The remaining 20 percent of the wastewater would be
conveyed north to be treated at a new 5.2 mgd NE Plant.
Effluent disposal would be handled by artificial (man-made;
constructed) wetlands followed by Rapid Infiltration Basins
(RIBs) located adjacent to the SE Agricultural Sprayfield and
in a proposed NE disposal site.

Decentralization, which includes improving the 4.5 mgd Lake
Bradford Road Plant, expanding the Killearn Lakes Plant (3.5
mgd), expanding the SE Agricultural Sprayfield (24.5 mgd), and
using on-lot systems to meet the remaining future wastewater
management needs.

Alternatives Evaluation

The above four alternatives (1, 2, 7 and 9) selected for further study were
matrix-evaluated during the DEISS preparation stage (1989), based on cost-
effectiveness, reliability, implementability, and environmental impacts. The
cost-effectiveness rating evaluation (1989) included an analysis of the
alternatives' capital costs, annual operation and maintenance (O&M) costs,
present worth values, and annual household costs. The reliability evaluation
estimated the degree to which each wastewater management system could
consistently achieve and maintain effluent limits for which the system was
designed, which included the City staff's experience in using the technologies.
The implementability rating involved the City's approval of the
technologies/alternatives, equitable cost distribution, certain public concerns
such as land-use compatibility, and various other considerations. The
environmental analysis was based on evaluation of both primary and secondary
(indirect) impacts.

Table ES-1 is a matrix ranking summary of the four selected system
alternatives. As shown in this table, Alternatives 1 and 2 were equally ranked

Alternative 9 -

ES-7

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highest among the four alternatives, overall, Alternative 1 is ranked favorably
due to its high reliability and impleinentability since it would be an expansion
of the City's existing, successfully-operated management system for agricultural
spray irrigation. Alternative 2 has the same overall favorable ranking because
of its high implementability and because of, anticipated low or minimal negative
environmental impacts. Alternative 7 received a lower overall ranking because
its capital costs were projected to be higher, environmental impacts, and
reliability concerns relative to the proposed use of artificial wetlands (a
relatively new technology for wastewater effluent treatment in the united States
which has shown increasing reliability — probably even since the 1989 matrix
evaluation for the DEISS — but has not been used by the City in the project
area). Alternative 9, the decentralized alternative, also received an overall
lower ranking because of reliability concerns pertaining to the lack of a
structured maintenance program for on-lot (septic tank) systems and some
documented on-lot system failures in the study area due in part to the drainage
characteristics of certain soil types in the failure area and interspersed
throughout the Tallahassee area.

TABLE ES-1
SUMMARY OF SYSTEM ALTERNATIVE RANKINGS
FOR THE FOUR ALTERNATIVES SELECTED FOR FURTHER EVALUATION (1)

Category

SYSTEM ALTERNATIVE

Cost-effectiveness	3	2	1	4

Reliability	4	3	2	2

Implementability	4	4	4	3

Environmental Impacts	2	4	2	3

Total	13	13	9	12

Overall Ranking	4	4	2	3

Ranking goes from least preferred (=1) to most preferred (=4). when a tie
exists for a category, both alternatives are assigned the same numerical
ranking. Ranking was not statistically treated.

Although the matrix analysis is somewhat subjective, it should be noted that
all of the characteristics addressed during the category rating process and all
of the categories addressed during the ranking process were considered of equal
importance. Weighing of the items would have been difficult to justify because,
although certain items could be considered more "important" than others, the
determination of a specific weighing value is highly subjective and dependent on
the wants and needs of an individual or organization.

Selection of Preferred Alternative

Given the nine alternatives considered and the four alternatives (1, 2, 7
and 9) selected for further study in the EIS supplement, the USEPA finds
Alternative 1 to be an acceptable alternative. Alternative 1 is a practical
alternative that represents a continuation of the City's successful agricultural
spray irrigation approach to the disposal of treated effluent through an
expansion of the city's SE Sprayfield, as well as the irrigation of existing golf
courses. As such, Alternative 1 was considered the preferred alternative for the

ES-8

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EIS Supplement. This selection was based on the evaluative ranking results
developed at the deiss preparation stage (1989) for the four criteria considered
(cost-effectiveness, reliability, implementability, and the environmental
impacts) presented in Table ES-1. in general, the overall favorable ranking was
attributed to: (1) projected relatively low capital costs, (2) the City's
f??i!»fnfrUrf4o««ortenCeJin.,0perating agricultural spray irrigation facilities for
effluent disposal, and (3) negative environmental impacts could be expected to
""V11®126?1 • Alternative 1 would not only utilize the City's
th«	-ln agricultural spray irrigation, it also proposes to

iS- ®xiatlng SE Sprayfield as opposed to developing a new, separate
facility. of the final four alternatives considered, Alternative l
. m°s j cost-effective of the three centralized alternatives
Y*8 *	m(?St reliable given the City's success in agricultural

* e*lstln9 SE Sprayfield; was rated as one of the three
f	given that the alternative would expand the city's existing

it 1 33 °PP_os®d.to developing a new, separate sprayfield facility; and
ironmenta:1 impacts could be expected to be reasonably minimized
despite the fact that the alternative ranked as one of the two least
environmentally preferable. Based on these criteria, Alternative 1 was tied with
i	aa having the most favorable overall ranking. Alternative 1 was

^ upreue5red alternative over Alternative 2 in the EIS supplement
since tne city has had successful experience in agricultural spray irrigation as
opposed to forest spray irrigation proposed.in Alternative 2. Nevertheless,
gation is also to be tried by the city for Alternative 1 as a small
demonstration project for an undetermined number of acres.

neral, Alternative 1 is a practical alternative that represents a
t City's agricultural spray irrigation approach to the disposal
-nt .ro.ugh an expansion of the City's SE Sprayfield, as well as
the irrigation of existing local golf courses.

Success of the City's SE and sw sprayfield Operations

. „ . ^fty'8 experience with agricultural spray irrigation disposal operations
- . ®® ucc®ssful at the existing SE Sprayfield, and the production of animal
jr processed foods for humans has reduced operational costs. The

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Based on this monitoring program, the USEPA understands from the City that
the city discovered five (5) nitrate-nitrogen groundwater quality violations
(1989, 1990 and 1991) in one of the seven compliance wells at the City's SE
Sprayfield, and four (4) nitrate-nitrogen groundwater quality violations (1986,
1987 and 1988) in one of the two compliance*wells at the City's SW Sprayfield.
These exceedances have been resolved through corrective action by the City and
monitoring has shown no additional groundwater quality violations since 1991 for
parameters monitored. As a rule, nutrient groundwater quality problems can be
minimized or prevented.

Environmental protection measures to minimize environmental impacts for
Alternative 1 would include the use of wildlife corridors, vegetated buffer areas
around the sprayfield site perimeter (external borders), frequent water quality
monitoring during operation, and prudent control of spray irrigation application
rates. The operation of the city's existing SE Sprayfield has been successful
in that city monitoring has shown minimal nutrient water quality degradation in
local groundwater resources. Nutrient groundwater quality problems can be
monitored and generally be minimized.

Description of the Preferred Alternative

Alternative 1 is referred to as a centralized "treatment south" alternative.
This means that all untreated wastewater flows would be conveyed to southwest
Leon county to receive secondary treatment at either the improved Lake Bradford
Road Plant or the expanded T.P. Smith Plant. The treated wastewater from the
Lake Bradford Road Plant is proposed by Alternative 1 for disposal via a spray
irrigation operation at four (4) golf courses. The treated wastewater from the
T.p. smith Plant is to be transported to the expanded SE agricultural spray
irrigation fields for final disposal.

The expanded SE spray irrigation facility of Alternative 1 would consist of
Eastern and Western Expansion areas. The Eastern Expansion area is being leased
by the city from a forest-products company (St. Joseph Land and Development
Company) and consists of approximately 1,830 acres total. Figure ES-4 is a soils
map of this area. From the map it can be seen that the majority of soils in
areas proposed for irrigation within the Eastern Expansion Area are Ortega and
Kershaw Sands. The Ortega Sands are characterized as moderately-well drained
s°ils that would provide good effluent filtration while Kershaw Sands are
characterized as excessively-drained soils and would provide minimal effluent
filtration, a total of 909 acres of center pivot and fixed-head agricultural
spray irrigation is planned for the Eastern Expansion area (the USEPA understands
from the city that the 909 acreage value may be changed by local decision-makers
if Alternative 1 is implemented). Although, as indicated above, forest spray
irrigation is to be tried by the city for Alternative 1 on a small demonstration
project basis, the majority of the 909 acres are to be utilized for agricultural
spray irrigation. The agricultural crop rotation in the Eastern Expansion area
is expected to include corn, soy beans, canola, and rye/rye grass. All
agricultural crops produced from effluent sprayfields are not for direct human
consumption and must be utilized consistent with state of Florida regulations.
Accordingly, irrigated crops produced by the City from the proposed Alternative
f m®y °nly be utilized as animal feed (e.g., cattle feed) and/or as processed
^ humans (e.g., canola oil; soy bean oil) only to the extent consistent
itn chapter 17-610 of the Florida Administrative Code (F.A.C.). The remaining
acreage balance (of approximately 1,830 total acres) would either be actively
sfn£9i by the forest-products company, and/or set aside as wildlife corridors,
ucn land management by the St. Joseph Land and Development Company is proposed
include logging portions of the southern half of the proposed wildlife
to e* i	t.he Eastern Expansion area leased to the city. This timbering is

fcoE\ 6 jurisdictional wetlands designated by the U.S. Army Corps of Engineers
FloT-lrf°r	Florida Department of Environmental Regulation (FDER: now the

As ano • *1E>!?rtment of Environmental Protection, FDEP, effective July 1, 1993).
timHavT 5 t*1® Florida Game and Fresh Water Fish commission (FG&FWFC),
Dlnao i ® should also be limited to the thinning of alternate rows of planted
between^ • ProPosed wildlife corridors, with vegetation in exposed areas
FG&FWFr "®ainin9 trees being moderately maintained in coordination with the

of the DroK!i?LPo £diC C0ntr.01 burns or Perhaps mowing to benefit the habitat
p otected Gopher Tortoise. Figure ES-5 illustrates the "proposed"

ES-10

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LEGEND

8 CHIPLEY FINE SAND 0-2% SLOPES
J 18 KERSHAW SAND 0-5% SLOPES
19 KERSHAW SAND	5-8% SLOPES

37 ORTEGA SAND	0-5% SLOPES

43 RUTLEGE LOAMY FINE SAND

39	PELHAM FINE SAND
47 TALQUIN FINE SAND

5 BLANTON FINE SAND 0-5% SLOPES
I I ALBANY LOAMY SAND 0-2% SLOPES

40	TROUP FINE SAND 0-5% SLOPES
24 LUCY FINE SAND	0-5% SLOPES
23 LEON SAND

42 PUJMMER MUCKY FINE SAND DEPRESSIONAL
45 SAPELO FINE SAND
A SINK OR DEPRESSIONAL AREA

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT
EASTERN EXPANSION SPRAYFIELD

SOILS MAP
PREFERRED ALTERNATIVE

1600	0	1600	3200

SCALE IN FEET

GANNETT FLEMING ENVIRONMENTAL ENGINEERS , INC.
HARRlSBURG , PENNSYLVANIA	FEBRUARY , 1991

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wildlife corridors as well as sensitive resources such as surface waterbodies and
archaeological sites in the Eastern Expansion Area of Alternative 1.

Sludge generated during the treatment of the wastewater is to be disposed
by land application near the T.P. Smith Facility, the SW spray field for dewatered
sludge disposal, and an expanded airport site for liquid sludge disposal. The
latter site, however, is apparently at capacity based on FDEP nitrogen level
determinations. The Western Expansion area of Alternative 1 (approximately 1,280
total acres) has not been acquired by the City and it is USEPA's understanding
from the City that acquisition of and construction at the Western Expansion area
appears unlikely at this time. Nonetheless, Figure ES-6 was prepared to
delineate "suggested" wildlife corridors for any potential future use of the
proposed Western Expansion Area of Alternative 1.

Although Alternative 1 is the preferred alternative of this USEPA EIS
Supplement, the USEPA is not requiring its implementation since this EIS
Supplement is discretionary and there are no federal funds and no major federal
action proposed for Alternative 1 (or for Alternatives 2, 7 or 9) at this time.
Unless the proposed project becomes a major federal action, the-selection of an
appropriate alternative for the city of Tallahassee wastewater management would
be a local decision. At the time of issuance of this FEISS, a proposed
Tallahassee wastewater management alternative had not been finalized. Local
decision-makers including the city of Tallahassee, City Commission, Leon county
Board of County Commissioners (County Commission), citizens Advisory Committee
(for a NE treatment plant), Citizens Advisory committee (for effluent disposal)
and the general public were continuing to locally review the project in terms of
acceptability, design, prioritization, and implementation. As such, the contents'
of this FEISS may not include any or all aspects of the ultimate approach locally
selected. The FEISS will serve, however, to provide technical guidance to local
decision-makers and the public.

while the USEPA considers Alternative 1 the preferred alternative from a
practical perspective, the other three system alternatives further considered in
the EIS Supplement (Alternatives 2, 7 and 9) also have attributes that the local
decision-makers may or may not wish to further consider in their selection of a
preferred alternative. Of these alternatives, Alternative 2 is noteworthy from
an environmental perspective. Alternative 2, as indicated above, is similar to
Alternative 1 except that it proposes forest irrigation rather than agricultural
irrigation. Overall, it was ranked equal to Alternative 1 in the 1989 matrix
evaluation, but was ranked higher environmentally. Global climate change
impacts, for example, due to land clearing of vegetation at the Eastern
Sprayfield Area, would be offset to a greater degree through the irrigation of
a forest crop than an agricultural crop due to the greater biomass of the tree
crop. If the existing young pines on site could be irrigated (i.e., the site is
not cleared and replanted with a new crop of pines), global climate change
impacts would be further minimized and the existing silvicultural land use of the
Eastern Expansion Area would essentially be unaltered. In addition, the
potential for soil erosion would be significantly reduced if the existing trees
would be irrigated or if the existing trees are harvested and replanted with a
new crop of trees without the clearing and grubbing (stump removal) required for
an agricultural crop. The City and the pulp and paper company that owns the land
may reach a mutually beneficial agreement involving effluent utilization for
silviculture, on the other hand, disadvantages for Alternative 2 would appear
to be the City's inexperience in forest irrigation (although forest irrigation
is being successfully used at 66 sites in the southeast, including 31 in Florida)
and operational considerations such as understory maintenance of the tree crop
and use of "drip" irrigation as opposed to "spray" irrigation (which may reduce
the per-acre effluent disposal capacity of the operation and therefore require
a larger sprayfield land area). The small forest irrigation demonstration
project that the city is to try as part of Alternative 1 (if implemented), should
provide an excellent opportunity for local decision-makers to compare the merits
of agricultural irrigation versus forest irrigation. Operational, environmental
and nutrient uptake (crop nitrogen demand) aspects of each technique would need
to be considered by local decision-makers.

ES-12

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Permitting Requirements

c4. v f £5®ferred alternative would be subject to compliance with all federal,
state of Florida, Leon County and city of Tallahassee permits, standards and/or
levant to the proposed spray irrigation project proposed in the
preferred Alternative 1. Three applicable federal permitting areas are described
They are the National Pollutant Discharge Elimination System (NPDES)
^	issued by the USEPA/Region IV (for Florida projects), the "Sludge Only"

2 v USEPA/Region IV, and Section 404 wetland permits (Clean
water Act) issued by the coe and reviewed by the USEPA.

__j *r^>fUa^L^ the e*i3ting NPDES permitting program (40 CFR Parts 122 and 124)
pr	Permit Application Regulations for storm Water Discharges" (55

at-nr-m «a-t- ^ November 16, 1990), an NPDES permit is required for point source
^ dls°har9es to waters of the united States from the facility actually
wastewater. This provision applies to domestic wastewater
~m®nt facilities that have design flows of at least 1.0 mgd. The NPDES storm
Zlttl hj-^T	* ° November 16, 1990, also require that point source storm

.wa r,s the United States from all construction activities
dStnStUH the.	clearing, until revegetated, of spray irrigation sites)

Droar-flm TV,a tota}\ of ^7® ?r more acres must be permitted under the NPDES
to on^Ini permit application deadline for these discharges is 90 days prior
coTOrano „ merit of construction. Construction activities needing NPDES permit
age can be made through a general permit recently issued by EPA/Region IV.

for-	tQ *^DES permitting for the preferred Alternative 1, application

water £»u permit would need to be made by the city for point source storm

faeim-A	t waters of the United States from regulated treatment

ADnl ily treating domestic wastewater under the above-noted criteria.

abnva 2 j	City for a separate NPDES permit would also be needed by the

uni-hoH e^6+f ? ® r Polnt source storm water discharges to waters of the

th«	® ^or , construction sites associated with and actually involving

laild appllca5lon site (including the initial clearing, until

^ 4.	proposed Eastern Expansion area of the SE Sprayfield and the

din^nr-K^ Western Expansion area (if implemented) of the preferred Alternative 1)

wonlH	a ® i7e or more acres of land. These permit requirements

unnormft-t	-for	preferred Alternative 1 as well as any existing

unpermitted City sites.

or>a*-=f^0rin water Point source discharges to waters of the United States from the
annn/?" (spray irrigation) of non-agricultural/non-silvicultural land
! °2 sites (such as golf courses, rights-of-way, and landscape areas)
receiving domestic wastewater treated to the quality required by Chapter 17-610
u'	® land application of reclaimed water are not required to be covered

annHn!?'P9rnita' unless the USEPA specifically requires a facility to submit an
tho	on 5 case-by-case basis. Therefore, no NPDES permit is needed for

peration of such land application sites for the city's proposed project (if
_ifrm.Wa fr Polnt source discharges exist to waters of the United States for such
r,f	53 sPeclf ally requested by the USEPA. However, dedicated discharges

rm; i a:Lmed water, without land application, are required to be covered by NPDES
,¦ „f!z •	may also be noted that storm water discharges from the land

oE« ation of wastewater effluent on agricultural and silvicultural sites are
^ro® t*ie NPDES permitting program if the sites are consistent with 40 CFR
_ . 122.3(e), so that the operation of such sites for the city's proposed

^lfequi" an N,P?E1S Pennit if consistent with 40 CFR 122.3(e).
f _f®' no NPDES Permit would be needed by the City for the operation of the
courses (if implemented) proposed in the preferred Alternative 1, as
al™ h?7	existing City application sites (if such storm water point

Wftef8 °fJ the United state8 exist at these sites).
?a	*Ce	a application of wastewater effluent on agricultural

Erafnai L' I*Th« cw°c the	Permitting program, the operation of the Eastern

,-n « /Pra^ and the Western Expansion thereof (if implemented)
cW «r0d i"1riiatAV0 l' as wel1 aB any existing City application
Ultra of\VL nn®S ilra/field- (ff 8Uch atorin water Point source discharges to

permit if thfse	e*18«. t.hese sites)» would not require an NPDES

permit if these sites are consistent with 40 CFR 122.3(e).

ES-15

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Included in the proposed spray irrigation of wastewater^ effluent in the
preferred Alternative 1 is the generation of and land application of wastewater

+-^ /-iaan uator Ret reauires that the disposal

sludge. section 405(d) of the" clean Water Act requires tna^	a"P°BSi

reuse of sewage sludge be regulated. This regulatory f-^hnieal federal
accomplished through the utilization of permits based upo	disDosal/reuse

regulatory standards. The USEPA established federal sludge disposal/reuse

standards which were promulgated in the Federal Reqi8te_	hv all

February 19, 1993. In general, these standards must be c?®Pjied„^i»t5n if
treatment works treating domestic sewage by February

these standards would be a violation of the Clean water Act.	rami?»i-aH

that current and proposed sludge disposal/reuse activities	»clnHoa-onlv«

through an NPDES permit, where applicable, or through issuan	usEPA/Realon IV

permit. This federal permitting activity would be 18®u®f J^da Therefore the
until program authorization is given to the State of Flo:ri •	. j.

newly promulgated federal regulations are in addition to t ... . ..
sludge disposal/reuse regulations. Relative to the preferred	' .

City must also make application for a sludge Only permit f	..	. th

proposed sludge disposal/reuse activity associated with the s	J nraetice

Alternative 1 proposal, as well as any other City sludge disposal/reuse Practice.

These federal regulations are in addition to the State o	g

disposal/reuse regulations.

Specific to the City of Tallahassee, the USEPA last	ThomaqEp ^mlth

for land application to the City of Tallahassee for the city	av-4r<» ,*n iqo-j

Wastewater Treatment Plant in 1980. This federal permit wa	p
but was inactivated by the USEPA on April 6, 1981.

Failure to obtain prior authorization for discharges under the NPDES program
may result in the USEPA assessment of administrative, civil, ana/
penalties under Section 309 of the clean Water Act.

In addition to the NPDES permitting, the preferred
be subject to the requirements of a section 404 (Clean Water A J £ '
would include any unavoidable direct losses of wetlands through dr g ~
activities such as land clearing and construction activities, ho e , p p a
spray irrigation areas within the proposed Eastern Expansion.°	t K®

1 were selected to avoid wetland areas since hydric (wetland) soils vrouldn be
suitable/desirable for effluent disposal. Nevertheless, "V

losses would be subject to 404 permit determinations by the Jacksonville Die ict
COE, as well as wetland determinations by the state of Florida and L®°" bounty,
as appropriate. Conveyance pipeline crossings of wetlands would likewis be
subject to section 404 permitting. Also, the USEPA reviews 404 permit
applications for the COE. Secondary impacts to wetlands and surface waterbodies
could also occur. Periodic water quality monitoring of surface waters and
selective application measures would help minimize such secondary impacts.
surface waters should not be allowed to become eutrophic due to spray irrigation
of wastewater nutrients.

The permitting guidance outlined in this document is very general and is not
intended to be used to make final decisions on the applicability of the NPDES or
sludge regulations, or Section 404 of the Clean Water Act. Site-specific
conditions are always important factors in making these determinations.

Key Environmental impacts and Environmental Protection Measures

The most critical primary environmental impacts of the preferred alternative

are:

Potential groundwater and surface water contamination.

Human health effects relative to effluent aerosols drifting off site.

The removal of all vegetation in the spray areas.

The loss of suitable habitat for protected or candidate protected
species in the area (Gopher Frog, Gopher Tortoise, Indigo snake,

ES-16

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Florida Pine Snake, Panhandle Golden Aster, and Panhandle Meadow
Beauty) as well as the possible disruption of Gopher Frog migration
paths for breeding in waterbodies.

The possible disruption of archeological sites in the spray irrigation
areas.

Groundwater and surface water contamination can result from the disposal of
effluent at the expanded SE Sprayfield and the golf courses. The removal of
trees would result from establishing field areas for the cultivation of
agricultural crops (animal feed and/or processed human food only). The
disruption of Gopher Frog migration could result from construction-related
separation of abandoned Gopher Tortoise burrows (used by Gopher Frogs as habitat)
and surface waterbodies (needed by Gopher Frogs for breeding). Habitat
disruption of the Panhandle Golden Aster and Panhandle Meadow Beauty may occur
as a result of the conversion to agriculture. Archeological sites could be
disturbed during sprayfield construction activities. Listed and newly-recorded
archeological sites (per the city's survey of the Eastern Expansion area of
preferred alternative) should be avoided to the extent determined by the Florida
State Historical Preservation Officer (SHPO).

The secondary environmental impacts of the preferred alternative which
generate the most concern are the impacts on public health and land-use changes.
The public health issue is a concern to residents living adjacent to or
downgradient/downstream/downwind of the SE sprayfield and the adjacent proposed
Eastern Expansion area as well as golf courses, should they be utilized for spray
irrigation. (Residents living east (and north) of the proposed Eastern Expansion
area have voiced complaints during the public hearing held by Leon County in
Tallahassee on July 23, 1991, concerning aerosol spray drift, odor, and decreased
property values.) Potential public health risks are related to aerosols
containing non-pathogenic bacteria and pathogens (e.g., pathogenic bacteria,
viruses, protozoans and other infectious microbes) traveling away from the
sprayfield area and the potential groundwater contamination of the Floridan
Aquifer, a drinking water source. (Groundwater concerns were voiced by the
public during the USEPA Public Hearing held in Tallahassee on August 9, 1990.)
Post-irrigation use of the golf courses may also be of public concern.

It is generally documented that wastewater treatment methods can remove
significant numbers of pathogens and non-pathogenic bacteria typically associated
with sewage wastewater. However, not all may be killed by disinfection. In the
case of pathogens such as viruses, the surviving numbers could potentially be
hazardous from a human health perspective since even a small number of viruses
can be infectious. However, several precautions can be taken to reduce the human
health risk at spray irrigation sites. These include effluent treatment,
effluent monitoring, on-site containment of aerosols, and groundwater monitoring.

The USEPA understands from the City that City effluent is disinfected in
accordance with state of Florida standards and permit requirements. The City's
wastewater treatment processes are the activated sludge process, chlorination,
and natural ultraviolet light (sunlight) treatment in the holding ponds. Prior
to effluent spray irrigation, the city monitors its effluent for 40 parameters
including 17 metals on a monthly basis; monitors for 11 parameters (biochemical
oxygen demand (BOD), total suspended solids (TSS), total nitrogen, chlorine
residual, chlorides, Ph, fecal coliforms, and other parameters) on a twice a week
basis; and monitors for the six (6) above parameters on a daily basis.

Studies have shown that the health risk associated with aerosols from sewage
effluent spray irrigation sites is extremely low, particularly for irrigation
with wastewater that has been disinfected. Effluent sprayer nozzle design can
also help minimize aerosol drift effects. The dispersal of aerosols is also
directly related to wind velocities. (Local prevailing winds average 7.7 miles
per hour and are from a southerly direction in the spring and summer and shift

ES-17

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j £ +.«.« vaar.) other factors which
toward a more northerly direction near the end or t y	aerosol travel are

prolong pathogen viability and increase the ai	darkness. studies also

increased relative humidity, lower temperature,	aerosol than do the

indicate that pathogens tend to survive longer evergreen forested buffer
traditional indicator organisms. The use of aen	borders of the Eastern

areas, which is proposed by the city along the	, thQ spread of aerosols

Expansion area for Alternative 1, should greatly r	velocities. wildlife

off site by acting as a barrier and by :ced"°"Jf_ed Ea8tern Expansion area
corridors within site boundaries of the propo	th0 0ff_site migration

consisting of natural vegetation, should further re waStewater directly to
of spray effluent aerosols. The spray applies*tioi	wouid further reduce

forested areas, as opposed to open agricultural tie r forest irrigation is
the risk associated with aerosols (as previously m®n wj.thin Alternative 1).
proposed by the City as a small demonstration ^ro] neighboring a sprayfield
However, in general, reasonable protection of resicte	tatj_on of appropriate

should be possible through the proper design and imp	treated wastewater

effluent treatment methods, frequent effluent	htj disinfection, prudent

prior to irrigation, natural ultraviolet	(sun 9 ' areas along external

spraying operations, use of evergreen	within the general sprayfield

borders of sprayfields, use of forested corridors	of effluent to forested

area, and groundwater monitoring. Direct	tion demonstration project,

areas, such as the proposed City's small forest irrig	d further reduce the

for Alternative 1, should further contain aerosols o
human health risk associated with aerosols.

^	and other public access

The spray application of wastewater to golf coursi	icuitural or forest

areas, which would provide greater public exposure tn	, ids reinovai and high-

sprayfields, requires additional treatment for suspena	Coinpiianoe with these

level disinfection under State of Florida regulation *	iated with aerosols at

regulations should greatly reduce the health ru*s 
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further minimized through prudent spraying operations that allow acceptable
effluent soil infiltration rates that avoid ponding.

Human health concerns also exist for potential groundwater contamination of
the Floridan Aquifer drinking water source. After application of the wastewater
effluent to land surfaces, the wastewater infiltrates into the soil and interacts
physically and chemically to remove the potentially harmful constituents not
removed during effluent treatment. It is possible that some of these
constituents could move quickly through the soil (depending on soil filtration
characteristics and depth) and into the groundwater used as a source of public
drinking water.

As previously indicated, the city is conducting an on-site groundwater
monitoring program for its existing effluent sprayfields. Historically, over 60
monitoring wells have been drilled and tested at the SE Sprayfield site during
interagency cooperative studies. Although the City has been monitoring wells for
some time, the state of Florida required monitoring via a Groundwater Monitoring
Program by permit condition since November 1, 1984. The City now quarterly
monitors seven (7) compliance wells at the SE Sprayfield for six (6) parameters:
no2 (nitrite) and N03 (nitrate) as nitrogen; nitrites; total Kjeldahl nitrogen;
chlorides; dissolved organic carbon (DOC); and fecal coliforms. Pesticides and
herbicides are also monitored annually.

Based on this monitoring program, the USEPA understands from the city that
the city discovered five (5) nitrate-nitrogen groundwater quality violations in
the seven compliance wells at the City's SE sprayfield. Expected causes of these •
violations included a faulty well construction, application techniques for
additional (non-effluent) fertilizer, and possibly on-site cattle burial.
Overall, four (4) other violations (also for nitrate-nitrogen) were monitored in
one of the two compliance wells at the city's sw sprayfield. Expected causes for
these violations included the fact that a stockpile of dewatered sludge was
placed near a compliance well. The USEPA further understands from the City that
the exceedances in these two wells were reported to the FDEP by the City as part
of their quarterly reports and that the FDEP responded by writing a letter and
by discussing some of the violations with the city. The discussed exceedances
involving the faulty well, additional fertilizer, dewatered sludge, and possibly
on-site cattle burial were resolved by constructing a new nearby well and
adjusting farming techniques at the SE Sprayfield, and by removing the sludge at
the sw Sprayfield, and that monitoring has shown no additional groundwater
quality violations since 1991 for the parameters monitored. As a rule, nutrient
groundwater quality problems can be minimized or prevented.

The impact of land-use changes at the SE Sprayfield is related to the change
of silvicultural operations to agricultural operations. The concern is not so
much for aesthetics or restriction of future land use potential but rather for
global climate change impacts. Deforestation reduces the capacity of an area of
the earth to sequester carbon dioxide from the atmosphere. Carbon dioxide is the
major contributor to the greenhouse effect. However, if Alternative 1 is
implemented, the proposed retaining or creation of vegetated areas in the
sprayfield area is expected to help minimize the impact of deforestation due to
converting forested land to sprayfields (e.g., use of agricultural sprayfields
(i.e., vegetation) to replace cleared forested areas, implementation of the small
forest irrigation demonstration project which would retain some existing forested
area, retention of additional forested areas within the project area as wildlife
corridors, and use of evergreen buffer strips along external sprayfield borders
which would retain or create forested areas).

As a consequence of the land-clearing activities proposed for the Eastern
Expansion Area, approximately 85% of the existing on-site Gopher Tortoise habitat
(sandy, upland areas) would be converted to a spray irrigation field. However,
the remaining 15% of the suitable habitat areas is to be protected by inclusion
in the proposed wildlife corridors, i.e., the natural vegetation areas contiguous
to spray irrigation areas within the Eastern Expansion area depicted in Figure
4—2. Protection of the remaining 15% of suitable habitat was recommended by the
Florida Game and Fresh Water Fish Commission (FG&FWFC) "to ensure the continued
on-site existence- of the protected Gopher Tortoise, Gopher Frog, Eastern Indigo,

ES-19

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and Florida Pine Snake. (See FG&FWFC letter dated February 6, 1991 in chapter
5 included as part of USEPA's response to DEISS Letter #5, based on the FG&FWFC's
field observations on January 23, 1991). (Note: If the 909 acreage figure and/or
their configuration proposed in this FEISS for spray irrigation in the Eastern
Expansion area is changed by local decision-makers, adequate on-site sandy areas
must still remain for the Gopher Tortoise. The USEPA recommends additional
coordination with the FG&FWFC, as appropriate.)

Environmental Protection Measures

Table ES-2 provides environmental protection measures that would lessen the
potentially detrimental, environmental impacts of the preferred alternative.
These measures are recommended by the USEPA for implementation by the city of
Tallahassee, if the preferred alternative is pursued for implementation by the
City. They are categorized as to the likelihood of implementation.

TABLE ES-2

SUMMARY OF ENVIRONMENTAL PROTECTION MEASURES

Measures that will be implemented -

•	comply with the existing National Pollutant Discharge Elimination System
(NPDES) permitting program (40 CFR Parts 122 and 124) and the "NPDES Permit
Application Regulations for Storm Water Discharges" (55 FR 47990 dated
November 16, 1990), which require an NPDES permit for:

*	Point source storm water discharges to waters of the United States
from regulated domestic wastewater treatment facilities actually
treating domestic wastewater that have design flows of at least 1 mgd;

*	Point source storm water discharges to waters of the United states
from all construction activities associated with the spray irrigation
project (including initial clearing of the application site until
revegetated) disturbing a total of five or more acres of land —
application by 90 days prior to commencement of construction.

Pursuant to section 405(d) of the clean Water Act, the city must also make
application for a sludge Only permit for the current and proposed sewage
sludge disposal/reuse activity associated with the proposed project, as
well as any other city sludge disposal/reuse practice. Also, standards
promulgated in 40 CFR 503 (February 19, 1993) must, in general, be complied,
with by all treatment works treating domestic sewage by February 19, 1994.
Permit application should therefore also be made by the City with the
USEPA/Region IV for:

*	All current and proposed activities involving the land application of
sludge.

•	Conduct monitoring of the water quality of the effluent leaving the
wastewater treatment plants (i.e., prior to effluent spray irrigation) for
the parameters and at the frequency currently being conducted (40
parameters including 17 metals on a monthly basis; 11 parameters such as
biochemical oxygen demand (BOD), total suspended solids (TSS), total
nitrogen, chlorine residual, chlorides, pH, fecal coliforms, and other
parameters on a twice a week basis; and the six (6) above parameters on a
daily basis). if pollutant concentrations exceed permit limitations,
correct problems in the treatment operations and/or design as soon as
possible.

•	Conduct monitoring of the water quality of groundwater wells within
one-half mile of the preferred Alternative 1 spray irrigation site for the
six (6) parameters and at the quarterly frequency currently being conducted
(nitrite and nitrate as- nitrogen, nitrites, total Kjeldahl nitrogen,
chlorides, and dissolved organic carbon (DOC), as well as any other water
quality parameters specified by the state of Florida in order to detect any
exceedances of relevant water quality standards. if monitoring data
exhibit concentrations exceeding state of Florida water quality standards

ES-20

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for groundwater and/or permit limitations, correct problems with irrigation
operation and/or design as soon as possible.

Conduct frequent monitoring of the water quality of surface waters.
Surface waterbodies, for example, should not be allowed to become
eutrophic.

Retain wildlife corridors within the Eastern Expansion area proposed by the
city for near-future construction (and in the Western Expansion area if
ever developed). wildlife corridors should maintain a portion of the
natural vegetation of the on-site upland and wetland habitats. Corridors
are intended to provide habitat areas contiguous to spray irrigation areas
to allow undisturbed movement of wildlife around these irrigation areas,
including Gopher Frog reproductive migrations. The Eastern Expansion Area
wildlife corridors should include an isthmus area (a minimum of 300-500
feet wide) west of center pivot Area c to maintain corridor interconnection
for north-south wildlife movement. The wildlife corridors should
essentially be continuous, although occasionally would be crossed by dirt,
gravel or paved access roads. Proposed logging activities within portions
of the cortidors should be minimized and selective. (Note: If the
configuration of the areas to be irrigated in the Eastern Expansion Area
are altered by local decision-makers from those shown in Figure ES-5, the
USEPA recommends that an appropriate north-south wildlife corridor still be
maintained. Likewise, if the proposed spray irrigation acreage (909 acres)
and/or the proposed configuration of these acres are changed, the USEPA
recommends that adequate on-site sandy areas still be maintained for the
Gopher Tortoise. Additional coordination with the FG&FWFC is recommended,
as appropriate.)

Retain/create a buffer zone around the field areas that is a minimum of 400
feet in width along Tram Road and 100 feet along the other sprayfield
external boundaries to minimize perturbations attributable to the
sprayfield expansion area, particularly aerosol spray drift. The buffer
zone should act as a year-round, vegetative screen and as such must be a
dense evergreen forested area. The use of evergreen buffer areas, in
combination with the above-described forested wildlife corridor areas,
should greatly reduce the spread of aerosols off site by acting as barriers
and by reducing wind velocities. The southern boundary already has a
densely-forested buffer as a result of an existing gas pipeline right of
way. The southern buffer width would be at least 400 feet. Buffer strips
should also be retained around on-site waterbodies and along streams for
field runoff filtration.

Protect and preserve archaeological sites located in buffer areas and
designated wildlife corridors. For the examined Eastern Expansion, these
include Sites SFl, SF4, SF9, SF19, SF21, SF22, SF23, and SF26. of
particular concern is Site SF9 (Eagle Lake site) . The primary protection
zone for this site should be a 1400-foot diameter circle, the center of
which is to be coordinated with and established by the Florida SHPO.

Utilize all agricultural crops raised via spray irrigation (e.g., corn, soy
beans, canola, and rye/rye grass) at the proposed sprayfield expansion
site(s) and existing sprayfields only for animal feed and/or for processed
food for humans (e.g., canola oil; soy bean oil), i.e., not for direct
human consumption, to the extent consistent with the State of Florida
(Chapter 17-610 F.A.C.). Grazing of cattle on proposed or existing
irrigated sprayfields only to the extent consistent with Chapter 17-610
F.A.C., and utilization of crops grown for consumption (e.g., bermuda hay
for livestock feed) on existing sludge fields (Class B or equivilent) only
to the extent consistent with chapter 17-640 F.A.C.

ES-21

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•	Comply with sound agricultural practices such as field terracing and row
crop contouring.

•	Comply with all federal, state of Florida, Leon county and City of
Tallahassee standards, permits and/or ordinances relevant to the proposed
sprayfield expansion.

Measures that are planned for implementation -

•	Consider any reasonable public complaints made before or during operation
of the proposed sprayfield expansion regarding effluent aerosol dispersion
or other operational impacts.

•	Conduct agricultural operations with the primary goal being the proper
disposal of effluent.

•	Conduct frequent monitoring of the water table level at the spray
irrigation areas and adjust the effluent application rates accordingly.
Application rates are not to exceed state of Florida permit conditions.
The City's existing SE Sprayfield is currently permitted by the state of
Florida to spray irrigate at a rate of 3.16 inches per week.

•	Monitor weather conditions to avoid spraying effluent during crop
harvesting and during inclement weather conditions (e.g., rainy, wet,
windy, freezing conditions) if spraying during those conditions would be
expected to cause detrimental environmental or human health effects, or be
considered ineffective from an effluent disposal perspective. similar
prudent spraying operations should also be undertaken to the extent
feasible during periods of increased relative humidity, lower temperature,
and darkness since studies have shown that these conditions prolong
pathogen viability and increase the distance of aerosol travel. Spraying
should also not result in effluent ponding in order to minimize any human
health effects from animal vectors. Application rates should be adjusted
in any areas where ponding persists (ponding has apparently occurred in the
SE corner of the existing SE sprayfield).

•	Create 6- to 8-inch vegetated (herbaceous ground cover) earthen berms along
the sprayfield area/wildlife corridor boundaries as part of the leasing
farmer's agricultural practices. Such berms would help contain surface
water runoff and allow percolation and soil filtration of the applied
effluent in designated spray irrigation areas. This would help reduce the
probability of wetland and other surface waterbodies within the sprayfield
expansion area (as well as the adjacent St. Marks River System) from
becoming eutrophic.

•	Create 10- to 12-inch vegetated (herbaceous ground cover) earthen berms
around "live" sinkholes within the sprayfield expansion area to divert
surface water runoff flows from direct access to groundwater and thereby
help protect groundwater quality.

•	During the design and proposed construction phases, Karstic depressions
(other than the discussed "live" Karstic sinkholes) should also be avoided
If avoidance is infeasible, filling depressions with native soils could be
tried unless these depressional areas are wetlands. The fill soils should
only be moderately well-drained, so that drainage into the Karstic areas
would not be encouraged. Native soils should also preferably be mixed with
organic material to enhance spray irrigation effluent filtration and
pollutant removal. since such filled areas may subsequently subside,
slight initial mounding may be advisable or additional filling using the
same soil mix may subsequently be needed. Should the depressional area
collapse and become a -live" sinkhole, spray irrigation in the area should

ES-22

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be stopped and vegetated earthen berms created around the sinkhole as
indicated above.

•	Preserve as many trees at the site as possible. Tree clearing should be
limited to the sprayfield areas and designated farm operation areas. This
would minimize habitat losses, habitat disruption, and global climate
change (greenhouse effect) impacts. Additional proposed silvicultural
timbering by the St. Joseph Land and Development Company on land in the
Eastern Expansion area leased to the City should be minimized, selective,
and exclude jurisdictional wetlands designated by the COE and/or the FDEP
due to reproductive migrations of the protected Gopher Frog. Also, as
specified by the Florida Game arid Fresh Water Fish Commission (FG&FWFC),
timbering should be limited to the thinning of alternate rows of; planted
pines in the proposed wildlife corridors, with vegetation in exposed areas
between remaining trees being moderately maintained in coordination with
the FG&FWFC through periodic control burns or perhaps mowing to benefit the
habitat of the protected Gopher Tortoise. should land access to the
Western Expansion area be obtained by the City and the site developed,
timbering should be similarly limited there.

Measures that could be implemented -

•	Protect cultural resources on the edge of irrigation fields by
incorporating them into "protection areas" (wildlife corridors and buffer
zones) as determined by the Florida SHPO. These include sites SF2, SF7,
and SF1.8. Additional City coordination with the Florida SHPO should be
provided, as appropriate.

•	Protect cultural resources located in irrigation fields as determined by
the Florida SHPO. These includB sites SF3, SF5, SF6, SF8, SF10, SF11,
SF12, SF13, SF14, SF15, SF16, SF17, SF20, SF24 and SF25. Of these sites
only one, SF3, which is located in the fixed sprinkler irrigation area,
appears to warrant additional systematic archeological examination.
Additional City coordination with the Florida SHPO should be provided, as
appropriate.

•	Protect any listed or uncovered cultural resources located along pipeline
corridors to the satisfaction of the Florida SHPO.

ES-23

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PROJECT

UPDATES SUMMARY

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PROJECT UPDATES SUMMARY

UPDATE OF PROJECT-RELATED LOCAL EVENTS AND CONCERNS

Presently, the city of TaLlahassee has not requested any federal funds to
implement the 1988 City Master Sewer Plan (MSP), nor does the implementation of
the MSP as proposed otherwise constitute a "major Federal action" under NEPA, and
NEPA does not mandate that an EIS supplement be prepared. However, this
discretionary EIS Supplement has been prepared by the USEPA to provide technical
guidance to the City of Tallahassee Sewer Division as well as other local
decision-makers for facility expansion planning, unless the city MSP should at
some time rise to the level of a "major Federal action," the decision-makers for
the present project as proposed are local government entities as opposed to the
federal government. Specifically, the local decision-makers include the City of
Tallahassee, city Commission, leon County Board of County Commissioners (County
Commission), Citizens Advisory committee (for effluent disposal), Citizens
Advisory Committee (for a NE treatment plant), citizens Advisory committee (for
sewage sludge management), and the general public.

The list of alternatives considered in the DEISS and FEISS does not
constitute a finite list of alternatives, but is reasonable subset of
alternatives that includes various forms of decentralized effluent disposal
(septic tanks) or centralized effluent disposal (spray irrigation, artificial
wetlands with RIBs, deep well injection, surface water discharge, etc.), various
disposal sites within Leon county, and various forms of spray irrigation
(agricultural, silvicultural, golf courses, etc.). Alternative 1 is selected in
the feiss as the preferred alternative based on a matrix evaluation process
during the DEISS preparation stage (1989). It is a practical and implementable
expansion of the city's existing agricultural SE sprayfield. However, it is not
the only feasible alternative that could be implemented in Leon County, and
updates since 1989 may be relevant for site selection and disposal methods. The
local decision-makers may or maj not choose to consider alternatives beyond those
presented in the DEISS and this FEISS.

A number of important local events have occurred at the Tallahassee
government and public level since the completion of the DEISS, and the local
decision process concerning the Tallahassee wastewater management still continued
during the completion phase of the FEISS. Given the fact that the proposed
project does not presently constitute a "major Federal action" under NEPA, and
from a timely, procedural and practical perspective, not all of these events were
considered in the FEISS. Therefore, along with the findings of the FEISS, local
decision-makers may or may not choose to consider these events, local public
concerns/comments, their own concerns/comments, more recently updated and future
information, and alternative disposal methods/sites in determining a preferred
approach to the wastewater management of the City of Tallahassee. In addition,
local decision-makers may also wish to consider the recent USEPA guidance manual
on water reuse (EPA/625/R-92/0C4) entitled "Guidelines for Water Reuse" (USEPA,
1992).

Although not all of these Bvents and concerns were considered in the FEISS,
the following is a documentation or summary of some of these important events and
concerns based on most or portions of public comments (Also refer to chapter 5
of this FEISS for public verbal and written comments at the USEPA Public Hearing
with USEPA responses and the public comment letters on the DEISS with USEPA
responses); the Leon County's (Leon County Public Works) "informal" comment
letter on a draft version of the FEISS to the USEPA dated July 15, 1992 and the
"informal" (outside NEPA DEISS comment period) response letter to the USEPA from
the city of Tallahassee (Water and Sewer Department) dated October 27, 1992

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(copies of these two letters are appended at the end of this chapter); and City
of Tallahassee "informal" written editorial comments on a draft version of the
FEISS dated August 21, 1992 and/or USEPA personal communications with the City
of Tallahassee. Some additional USEPA project comments and concerns are also
provided.

o Treatment Plant and Spravfield Capacity Reratinqs

The City of Tallahassee has indicated that the city's T.P. Smith (TPS)
Treatment Plant has been rerated to 20.0 mgd (rerated on 9/8/89 from 17.5 mgd).
Together with the 4.5 mgd capacity of the city's Lake Bradford Road (LBR)
Treatment Plant, the total design treatment capacity is 24.5 mgd. The disposal
sprayfield facilities were then rerated in order to equal the design capacity of
the treatment facilities, sprayfield application rates were therefore increased
in the city's fdep permit from 3.0 inches/week (in/wk) to 3.16 in/wk to provide
design irrigation capacities of 23.25 mgd (rerated on 9/8/89 from 22.0) at the
City's SE Sprayfield and 1.25 mgd (rerated on 9/8/89 from 1.2 mgd) at the City's
sw sprayfield, for a total design irrigation capacity of 24.5 mgd.

Also, in addition to the rerating of the T.P. Smith Plant to 20.0 mgd, the
City has more recently completed a 7.5 mgd expansion of the plant in January
1993, so that the total design treatment capacity for the TPS Plant is 27.5 mgd,
as of the issuance of this FEISS. The total City design treatment capacity of
the expanded TPS Plant (27.5 mgd) and the LBR Plant (4.5 mgd) is therefore 32.0
mgd. It may be noted that the City also operates a 0.06 mgd Municipal Airport
Plant (MAP) facility, so that the total city treatment capacity technically is
32.06 mgd. (Note: The USEPA understands from the city that the City plans to
close the MAP in 1996, although its flows will be diverted to the T.P. Smith
Plant.)

Accordingly, an expansion of the city's existing sprayfields would be needed
to increase the current total City sprayfield design irrigation capacity (24.5
mgd) to equal the total design treatment capacity (32.0 mgd, or 32.06 mgd if the
MAP is included), and/or golf courses or other areas for spray irrigation and/or
one or more other methods for effluent disposal (alternatives to spray
irrigation) could be used to accommodate the additional treatment capacity.
Alternative 1 proposes a city sprayfield expansion of 5.0 mgd (to a City design
sprayfield irrigation total of 29.5 mgd) and a golf course irrigation design
capacity of 3.0 mgd, for an combined addition of City sprayfield and golf course
irrigation design capacity of 8.0 mgd and a total combined irrigation design
capacity of 32.5 mgd. The additional 0.5 mgd capacity for spray irrigation would
allow for the 0.06 mgd capacity for the MAP facility and would also provide some
contingency capacity for golf course irrigation, i.e., golf courses are not
always as available as sprayfields for irrigation due to their public access
nature and other possible differences between sites such as weather.)

Although the total City treatment capacity was rerated to 32.0 mgd (or 32.06
if the MAP is included), it should be noted that the flow projections in the EIS
Supplement indicated that only 31.0 mgd would be required for the planning
period, so that 31.0 mgd was used in the EIS Supplement (e.g., Section 2.4.1;
Tables 2-11 through 2-18) in developing costs.

o Southern vs. Northern Leon county Wastewater Disposal

Several speakers at the usepa Public Hearing held in Tallahassee on August
9, 1990, and the County (July 15, 1992 letter), registered concerns regarding the
fact that the treatment and disposal of sewage effluent from northern Leon County
is proposed for ^southern Leon county if Alternative 1 ("treatment south"
alternative) is implemented. It may be noted that, at least from a soils
suitability perspective, it appears from the 1981 Soil survey of Leon county,
Florida (USDA [SCS] and USFS, 1981) that the northern part of Leon County is
generally less suitable for septic tank and spray irrigation wastewater disposal

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j 4- sav however, that favorable soils for
than the southern part. This is not to siay^ in both northern and southern
4-anks and spray irrigation do not	. t exist in southern Leon

ol^eon county or that at£avor>il« soils do not ^	public Works

Su"y! However, the USEPA	irri,*tio„ .ite assessment in 1989 and

Deoartment apparently conducted a ®P"y"del to dispose the same quantity of
determined that more acreage wauid be nee	^	in the geleCted southern

effluent In the selected	Bt^°. This suggests a slower percolation rate at

eftluenT- in i-««	-—	-

alternative sites due to soil type
the northern sites

the nortnetn	Tallahassee that the City would

The USEPA understands from the c:tcy thern versus southern Leon county

concur with the county with such a trenax^r ^ county appears to be generally

in general, since the northern P° aandy upper horizons are rather shallow.
" y . j y,„ 1 avers of clay and since sanay	f%__ contractor for nine sites m

TheScity has conducted geohydrologic analys i s^pleg generally exhibited clay
northeastern Leon county in 1991* , eoiieCted. such clay layers would affect
layers of varying decree in the sasJP and thus its suitability for septic tank
the drainage capabilities of the area an
and sDrav irrigation disposal.

ana spray	y	^ ^ thig FEISS> when the

This trend also generally agrees wren'	^ apray irrigation in the SE

acreage predicted to be required for	irrigation in the NE (component

(component Dl> is compared to agr:effluent flow (mgd) is much greater in the
Xn i +•>,«. .Baraae acreage needed per eXxiue	,	same trend also exists

NE <430 acres/mgd) than in the SE (188 acres/' g ) • acres/mgd) compared to the
for the ira forest irrigation	<=^^7 *or." mgd). (This trend, however

se forest irrigation site (component D3.	wetlands with RIBs disposal

fi not true in every instance s.nce the	to require the same amount of

in lit se Tcomponents Dll and D-6) are predicted to	acres/mgd). For Table

acreaqe as in the NE (components D12 an^ ^17) 'eat"ima'te acreages and was based on
2-9, the maximum application rats was " gurVey at the given sites. However, the
the soils in the 1981 Leon county Soil survey ^ cQnducted at any site proposed

?of?rrrgSondLthiVSe^n?So. « determine actual soil percola n rates.

for irrigation	t-	October 27, 1992 letter

it mav also be noted that the City ^dJrcaHHresginq the Environmental impact
has "...been involved «ith readdressing £	^ city ^ County

Statement of 1983 because of septic tank. athat you [USEPA] revisit the 1983
Conoriission letter was sent to "t^^hv sJptto tSk failures in the county,
This recruest was prompted by sep	the county continues to

b^ind ?ie c?ty liSts. It's difficult	encountered with these

the seotic^pproach giv.n the problems that are e	visit of the

?nTltay £il"£e«.-PP The ami	tanks, ^observed,

greater Tallahassee area m 1987. northern Leon County than, . J?®, °®£n
with more failures being noticed in northern	were not conducted during the

.n_tin„ Qf the county. Although percolation t ration were observed among as
slte ^isi? the effects of differences	This observed trend

well as within some of the residential subdivis	supported by the 1981 soils

£r northern v,. southern Men "^0?f%f„Situon ^racteristics regarding
survey for Leon county. Specific soil a	gsed below in the soils m

suitabilities for wastewater d^posal axe disc
Northern vs. Southern Leon County" section.

u ... to consider other northern
The local decision-makers nay or may not	reView soil maps, and conduct

alternatives verify the 1989 Ptblic Works stu y,	sites f°r	drainage

o"SS infiitr/tJn (percolation, studies at the.e ««• it.d (^	^

capability and suitability determinations * S tives is consistent with the
letter) that such a review of northern alt®r.I\a lineB. However, regardless of
locally-adopted -Southern stra^^" ^^l wSld remain a practical alternative

soil suitability comparisons, Alternative 1 wo	prayfield (although greater

conveyance3 would-be 8 needed	Compared to a northern

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alternative).

o Soils in Northern vs. southern Leon County

Based on the "General soil Map" for Leon County in the 1981 Soil Survey,
Leon County is dominated by three soil associations: the Orangeburg-Lucy-Norfolk
association in the northern part of Leon County and the Kershaw-Ortega-Alpin and
the Dorovan-Talquin- Chipley associations in the southern part of Leon County.
The Orangeburg-Lucy-Norfolk soils and the Kershaw-Ortega-Alpin soils are
generally well-drained while the Dorovan-Talquin-Chipley soils are generally not
well-drained. Specifically, the 1981 Soil Survey classifies the Orangeburg-Lucy-
Norfolk soils as "well drained soils" and the Kershaw-ortega-Alpin soils as
"excessively drained and moderately well drained soils," while the Dorovan-
Talquin-Chipley soils are considered "somewhat poorly drained to very poorly
drained soils." Of the two well-drained soil associations, the depths of these
sandy associations differ significantly; the Orangeburg-Lucy-Norfolk soils are
sandy to only 20-inch depths with loam below, compared to sandy 20-40 inches deep
with loam below or are loamy throughout (Note: "loam" is a soil type that is
defined in the 1981 Soil Survey as a mix of clay (7-27%), silt (28-50%), and sand
(<52%) particles.) By contrast, the Kershaw-Ortega-Alpin soils are sandy to 80
inches or more, with some having loamy layers (lamellae) below 45-inch depths.

Regarding the suitabilities of these soil associations for septic tank
absorption fields, Table 11 of the 1981 soil Survey presents the "restrictive
soil features" of existing soil types. All listed Orangeburg, Lucy and Norfolk
soil types are classified as "moderate: percs slowly" and/or "moderate: wetness,"
with "moderate" being defined as having unfavorable soil properties for the given
activity. The Kershaw soils are classified as "slight" which is defined as soil
properties generally favorable for the activity. Oretega and Alpin soils are
classified as "severe: poor filter," with "severe" being defined as soil
properties very unfavorable for the activity. The Dorovan, Talquin and chipley
soils are classified as "severe: wetness" or "severe: floods, wetness." These
classifications indicate that only the Kershaw soils have properties favorable
for septic tank absorption field" infiltration while the others do not adequately
drain or drain too well and therefore do not provide proper filtration (i.e.,
adsorption of inorganics (metals), microbes, etc.).

o Suitability of Soils in the Proposed Eastern Expansion Area

Based on the 1981 Soil Survey, the soils of the Eastern Expansion Area
sprayfield site proposed by the City are dominated by Ortega Sand, Kershaw Sand
with a 0-5% slope, Talquin Fine Sand, Chipley Fine Sand and Kershaw Sand with a
5-8% slope, respectively (also refer to Fig. 4-1 in this FEISS). of these, only
the Kershaw sands are classified as favorable for septic tank absorption fields
(classified as "slight," i.e., having favorable soil properties for the
activity).

Of the portions of the proposed Eastern Expansion Area sprayfield proposed
for irrigation (i.e., center pivot irrigation Areas A-E and adjacent fixed head
irrigation areas: Refer to Fig. ES-5 or 4-2 of this FEISS), irrigation areas
associated with and adjacent to Areas A, B, and D primarily contain Kershaw Sands
while irrigation areas associated with and adjacent to Areas c and E primarily
contain Ortega sand. As indicated, Kershaw Sands are considered suitable soil
types for septic tank absorption fields while Ortega Sand would not be favorable
due to poor filtration capabilities (too well-drained sands). However, it should
be noted that the city's proposed action is not septic tank disposal of raw
sewage, but rather spray irrigation of monitored, secondarily-treated sewage
effluent. As such, spray irrigation would disperse effluent over a greater area
than septic tank disposal and also would dispose wastewater of a considerably
higher water quality than untreated raw sewage wastewater of septic tanks.
(Specifically, all of the vertical soil horizons are utilized for filtration
during spray irrigation whereas several inches of soil filtration are not

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utilized in septic tank drainage fields, since drainage lines are buried several
inches below the surface; spray irrigation utilizes the entire horizontal soil
surface area whereas septic tank fields only utilize soil areas associated with
the drainage lines; and secondarily-treated spray effluent requires considerably
less soil filtration for purification than untreated septic tank raw sewage
wastewater.)

Because of the filtration limitations of the Ortega Sand in the proposed
irrigation areas associated with and adjacent to Areas C and E as well as some
unfavorable soils interspersed in irrigation areas associated with and adjacent
to Areas A, B and D, the USEPA recommends reduced irrigation application
(inches/week) in these areas, if monitoring exhibits compliance with state of
Florida groundwater quality standards and monitoring is conducted to the
satisfaction of the State of Florida, additional application can be tried if
commensurate with groundwater quality compliance. Groundwater monitoring is also
essential since the entire Eastern Expansion Area lies in the Woodville Karst
Plain, i.e., Karstic geology that is subject to water dissolution and collapse
(sinkholes). In any areas of collapse, irrigation should be stopped immediately
in those areas and the State of Florida notified. The USEPA recommends that no
effluent be sprayed in a reasonable surrounding area of the existing sinkhole
depressional area located within the proposed fixed head irrigation area adjacent
to Area D, as well as any other potentially discovered sinkhole areas (Refer to
Fig. ES-5 or 4-1 of this FEISS) . The USEPA further recommends that the State of
Florida consider the existing soil characteristics and Karstic conditions of the
proposed Eastern Expansion Area in their permitting decision for the city's
proposed sprayfield expansion.

o Leon County Action on NE Treatment Plant

The concept of a NE Wastewater Treatment Plant is not a new one. It was
promoted in the 1977 201 Plan, but was not the preferred alternative in the USEPA
1983 FEIS. The City's 1988 MSP, however, calls for a NE Wastewater Treatment
Plant to be constructed after the year 2010. The USEPA understands from the city
of Tallahassee that a Citizens Advisory Committee (for a NE treatment plant) had
been established to consider the establishment of a NE treatment plant and to
determine where such a plant could be located and how best to dispose the
effluent generated. The Committee, however, did not provide a final
recommendation and has not reconvened on the issue. The USEPA further
understands from the City that the City had made a commitment that a wastewater
treatment plant in NE Leon County would be constructed in early 1997.
Subsequently, however, the County (per personal communication with the City and
the city's October 27, 1992 letter) unilaterally defranchised (cancelled) the
City's water and sewer service zones outside city limits, so that the City
consequently felt that a NE Plant would not be needed in the NE area (where the
City's "urban services area" outside the City limits was located).

As a result of the County's action as well as the County's denial of the
franchise applications for the SE Sprayfield, the City Commission has decided to
hold the update of the city's Master Plan in abeyance (after action on certain
proposed amendments had proceeded). The County indicated (July 15, 1992 letter)
that the city Commission had apparently elected to terminate (March 11, 1992) the
City consultant's work on the city's Master Plan and that this action "...may
have put an end to the northeast treatment plant" since the NE Plant and the NE
Sprayfield were the main items of the City's Master Plan.

As discussed below, however, the City of Tallahassee and Leon County have
more recently signed a new "Water and Sewer Agreement" (1993) on February 11,
1993, which establishes a new urban services area outside of the City in northern
Leon County. The USEPA also understands from the city that the northeast is the
next likely area for potential treatment plant construction. The City already
owns an 80-acre site in the northern part of the city that was acquired as part
of the Welaunee annexation package that could potentially be used for such a NE

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plant. The site is located south of interstate Highway 10 and north of
Miccosukee Road, in the SW quarter of Section 12, Township 1-N., Range I.E. (Also
refer to Figure ES-3, where this site is depicted as the alternative Northeast
WWTP"). Given the public interest in such a plant (as opposed to conveyance of
northern wastewater for treatment and disposal in southern Tallahassee) as
demonstrated at the USEPA Public Hearing on August 9, 199°/	decision-makers

may wish to further consider such a potential treatment plant with appropriate
effluent disposal in their future Tallahassee wastewater management plans.

o City of Tallahassee Action on T.P. Smith Plant Expansion

In the absence of a ne Plant and under the proposed implementation of
Alternative 1, wastewater generated in northeastern Leon County would initially
continue to be conveyed via existing pump stations to the T.P. Smith Plant on the
southwestern side of Tallahassee. The USEPA understands from the City that the
City's 7.5 mgd expansion to the T.P. Smith Plant was completed in January 1993.
Also at that time, a new force main from the northeast routed around the eastern
side of the city of Tallahassee via Capital circle to the T.P. Smith Plant was
completed by the City and was operational in February 1993, although some
refinements were still made thereafter. In the near future (1995-1997), the City
furthermore expects that new additional pump stations would be required for
conveyance.

o Expansion of the City's SE SPravfield Under Alternative 1

Alternative 1, the preferred alternative of the FEISS, proposes the
expansion of the city's existing SE sprayfield. Both an Eastern Expansion Area
and a Western Expansion Area are considered under Alternative 1. However, the
USEPA understands from the city that the land of the Western Expansion Area has
not been acquired by the City and that acquisition of and construction at the
Western Expansion Area appears unlikely at this time. The FEISS has therefore
concentrated on the potential environmental impacts of the expanding the se
Sprayfield toward the east, i.e., the Eastern Expansion Area.

o Leon County Action on SE sprayfield Expansion

The USEPA understands from the City (October 27, 1992 letter) and/or the
County (July 15, 1992 letter) that the County (Board of County Commissioners) has
denied (July 23, 1991) two Leon county sewer "franchise" applications for
right-of-way placement permits for the expansion of the SE sprayfield and the
expansion of an effluent force main from the T.P. Smith Treatment Plant to the
SE Sprayfield. We understand the County's actions are based on citizen concerns
for existing residents east (and north) of the site relative to the proposed
Eastern Expansion area of Alternative 1, which the City has proposed for
near-future construction. The USEPA understands from the city that citizen
concerns regarding aerosol spray drift, odor, and decreased property value were
voiced by some 20 speakers in a public hearing held by Leon County in Tallahassee
on July 23, 1991.

As a consequence, the City's proposed Eastern Expansion area (part of
Alternative 1) is presently denied by Leon County. The County has requested that
the city revise/update the 1988 City MSP and that the City present various
wastewater alternatives with cost estimates to the County for consideration, a
Citizens Advisory Committee (for effluent disposal) consisting of both City and
County appointees was established and has reviewed alternatives. During this
process, the county Commission has stated that "the sole eastern expansion of the
sprayfield is no longer a consideration of this Commission" (per the citv's
October 27, 1992 letter).

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o Citizens Advisory Committee Action on Disposal Site Priorities

The USEPA understands from the City that at the time of preparation of the
DEISS (1989), the City's next planned effluent disposal expansion (Alternative
1) was to expand the SE Sprayfield with golf course irrigation disposal to be
provided as the sprayfields approached capacity. However, the USEPA further
understands from the City that the Citizens Advisory Committee (for effluent
disposal) recommended that the golf course disposal be provided first, followed
by other public access disposal methods. This recommendation was considered in
a meeting with the City Commission on November 16, 1992 and, ultimately, it was
decided that the Citizens Advisory committee should provide recommendations to
the City Commission for their review. The citizens Advisory Committee
recommended to:

*	Proceed with the golf course irrigation approach;

*	Landscape irrigate public access areas at the Tallahassee Airport;

*	Provide an additional 100 million gallons of effluent storage capacity
for the SE Sprayfield to provide flexibility for effluent application
for agricultural irrigation;

*	Use the "one-half pivot" concept, which would provide additional
flexibility for effluent application for agricultural irrigation by
controlling the amount of effluent distributed to either side of the
pivot sprinkler.

These recommendations were approved by the citizens Advisory Committee on
December 7, 1992, and were to be presented to the City Commission for their
review, if it is decided that golf course irrigation is to precede sprayfield
expansion, the City would recommend construction of a force main for effluent
conveyance to the golf courses.

It also should be noted that, per FDEP stipulation, golf course spray
irrigation would require that an alternate disposal method be made available as
a contingency. It is the USEPA's understanding from the City that such a backup
does not presently exist.

More recently, the City has reviewed the feasibility of irrigating golf
course and other public access areas. An essentially final report entitled
"Master Plan for Public Access Reuse" has been completed by City contractor in
November 1993. The USEPA understands from the city that the report generally
concludes that the operation would be expensive and that an application rate of
0.6-0.7 inches/week (i.e., 1 mgd) could be expected for the proposed sites. The
local decision-makers may or may not wish to review the methods and conclusions
of the report as part of their alternative selection process.

o City Commission Action on SE Sprayfield Expansion

In addition to the County's denial of the sewer franchise, we understand
from the County (July 15, 1992 letter) that the city Commission has directed the
City to stop pursuit of the expansion of the SE Sprayfield. The City (October
27, 1992 letter) has stated that they "...do not believe that the door is closed
forever on a sprayfield expansion; and, in fact, it is one of the least costly
of the alternatives considered." The city also indicated that after the review
by the Citizen's Advisory Committee (for effluent disposal), the City Commission
was expected to review the alternatives matter (November 16, 1992) and may
readdress the SE Sprayfield option through its consultant. In addition, city
technical studies, in which the County was included as being represented on the
Technical Committee, concluded that the currently permitted effluent
application rate (3.16 in/wk) for the SE Sprayfield should not be increased.
Presumably, therefore, additional effluent could not be irrigated at the
sprayfield without expansion. Under the circumstances, the design of the City's
sprayfield expansion had not yet begun, and the City has been and is still
leasing the Eastern Sprayfield Expansion Area.

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o City of Tallahassee and Leon County Water and Sewer Agreement of 1993

on February 11, 1993, the city and County signed a Water and Sewer Agreement
(1993) that re-established a City water and sewer service area outside the City
limits, i.e., the County has allowed the City to again have jurisdiction over a
portion of the northern County outside of the City limits except in areas where
sewer service providers already exist. This agreed upon sewer service area,
known as the "urban services area," is similar in location to the previous "urban
services area" cancelled by the County, although it is not the same area and is
smaller.

it should be noted that the FEiss (Refer to Fig. 1-1 and 2-1) still depicts
the former (cancelled) urban services area as well as the other city sewer
services areas. As indicated above, the urban services area outside the City
limits has changed due to the City/County Water and Sewer Agreement. in
addition, general configurational changes have also occurred to the boundaries
of the other depicted City sewer services areas. The overall more significant
changes to the city sewer services areas is an area reduction in the SE quadrant
(north of Old Tram Road) and in the NE quadrant (north of Bannerman Road) as well
as a relocation of the.boundary through Lake Jackson instead of around it along
its southern (Old Quincy Highway) and eastern boundaries.

As part of the City/County Agreement (page 3, item 7), it is stated that:
"The County agrees to work with the City and the Citizens Committee on wastewater
effluent to develop solutions to the disposal of wastewater effluent and
recognizes that without resolution of this issue, many benefits of this agreement
cannot be realized." The USEPA understands from the City that the City
interprets this to mean that the County would consider the SE SprayfieId
expansion (Alternative 1) as a disposal alternative. To this end, the USEPA
further understands from the City that the County has indicated that wider
vegetated buffer zones would be needed on the outside borders of the Eastern
Expansion Area (the USEPA would support such a recommended added buffer), which
would result in less actual spray irrigation acreage. Consequently, the 909
acres proposed on the Eastern Expansion area and used in this FEISS (See Fig.
ES-5 and 4-2) as the proposed spray irrigation acreage, may be decreased. The
configuration of the center pivot irrigation areas (Areas A-E) and adjacent fixed
head irrigation areas may also be altered. The local decision-makers may or may
not choose to implement such changes. However, whatever configuration is
selected, the USEPA recommends that irrigation should be limited to suitable soil
types for proper infiltration, that wildlife corridors are maintained within the
sprayfield, and that a north-south corridor for wildlife movement also be
maintained. Also, additional coordination with the Florida Game and Fresh Water
Fish Commission (FGFWFC) may be needed (subsequent to the January 23, 1991
interagency field inspection and the FGFWFC follow-up letter dated February 6,
1991 - refer to chapter 5 of this FEISS) to ensure that sufficient sandy habitat
areas are still available for the Gopher Tortoise and other protected species
under any revised irrigation area configuration.

o Artificial Wetlands Alternatives

The County indicated (July 15, 1992 letter) that artificial wetlands were
not properly discussed in the EIS Supplement considering the rapid emergence of
the technology in Florida, it should be noted that the EIS Supplement considers
alternatives involving artificial wetlands, and includes such an alternative
(Alternative 7) as one of the four alternatives considered for further study.
The use of artificial wetlands is a relatively new technology for wastewater
effluent treatment in the United States which has shown increasing reliability
— even since the 1989 matrix evaluation for the preparation of the DEISS. The
local decision-makers may or may not choose to further explore such alternatives.
It may be noted, however, that although the artificial wetlands method has been
successfully used in the Orlando, Florida area, the city of Tallahassee has not
used it in the project area; the city does have successful experience in the

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spray irrigation method proposed in Alternative 1. The USEPA also understands
from the City that the artificial wetland method is not, by itself, an effluent
disposal method but rather a treatment method that would still need to be
followed by some form of disposal (e.g., RIBs, if feasible and environmentally
appropriate). The City apparently believes that the nitrogen removal provided
by artificial wetlands and required for RIB disposal can more reliably be
provided by a sewage treatment plant.

o 1989 Matrix Evaluation of Alternatives

Alternatives 1, 2, 7 and 9 were selected for further consideration in the
alternatives analysis during the preparation of the DEISS. Matrix evaluations
were completed by alternative for cost-effectiveness, implementability,
reliability, and environmental impacts. It can be noted that some ratings of
individual characteristics and rankings of alternatives may change with time and
with decision-makers while others may not. For Alternative 1, for example,
"land-use" impacts were rated a "1" (greatest impact) in the "environmental
impact" matrix on Table 3-9, since the land-use conversion for the expansion of
the SE Sprayfield would be from a silvicultural/natural forested area to an
agricultural sprayfield. If, as the USEPA understands from the City of
Tallahassee, the City is to try forest spray irrigation on a small demonstration
project basis as part of the implementation of Alternative 1, land use would
overall be less impacted for that portion of Alternative 1 and arguably may merit
a higher rating for Alternative 1 for land-use impacts. Also, if the reliability
and implementability of effluent treatment through the use of artificial
(constructed) wetlands continues to increase and can be effectively used locally
in combination with an appropriate effluent disposal method, the "potential for
operational failure" implementation characteristic (rated a "1" in the
"implementability" matrix on Table 3-7) may also arguably merit a higher rating
for Alternative 7. Local decision-makers may or may not choose to consider such
changes over time or differences in objective judgement during the alternative
selection process.

o "Effluent-to-Enercrv" Concept

Local state and private foresters have expressed interest in the City's use
of U.S. Forest service (USFS) lands as spray irrigation sites for silviculture,
i.e., the "effluent-to-energy" concept (Also refer to chapter 5 of this FEISS).
In general, the USEPA does not disagree with the "effluent-to-energy" concept,
and USFS site alternatives were considered in the DEISS. However, it can
generally be expected that the examined USFS sites are likely to support
sensitive communities such as the longleaf pine-wiregrass communities and
endangered species. As such, it is believed that these sites are not the best
suited for silvicultural or other forms of development involving land clearing,
and should instead be preserved or allowed to naturally recover if disturbed.
In general, many other acres of land exist locally that are more suitable for
effluent irrigation of trees and other vegetation. For example, Alternative 2
proposes silvicultural irrigation and Alternative 1 proposes agricultural
irrigation at the city's SE Sprayfield expansion site. Although USFS sites and
Alternative 2 were not selected as the preferred alternative in the FEISS, the
selected Alternative 1 is an agricultural irrigation site that, if implemented,
is to include some silvicultural irrigation, i.e., it is the understanding of the
USEPA that the City is to try forest spray irrigation for an undetermined number
of acres in the Eastern Expansion area of the SE Sprayfield on a small
demonstration project basis as part of the implementation of Alternative 1.
Local foresters may or may not choose to further discuss the proposed pilot study
with the City of Tallahassee if such an alternative is implemented.

o Sprav Irrigation Acreage Estimates for Alternatives

The City of Tallahassee has calculated the spray irrigation or RIB acreage
needs for several components in Table 2-9. The City's calculations assumed a

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"rule-of-thumb" application rate of 2 inches per week. In general, the revised
acreage estimates appear to be less (by varying percentages) than presented in
the DEISS. The differences (City vs. EIS Supplement) in estimated acreage are
apparently due to the fact that application rates presented in chapter 2 (Table
2-9) are, as indicated above, the maximum application rates for the land
considered for disposal, based on the 1981 Soil Survey. The local decision-
makers may or may not choose to review these acreage estimates and the related
estimates and sub-estimates (such as costs) presented in the FEISS, where
necessary.

o Additional Decentralized Alternatives

The County indicated (July 15, 1992 letter) that decentralized
alternatives (such as traditional and "hybrid" septic tanks and package treatment
plants) considered "viable" by Leon county should have been addressed in the EIS
Supplement (in addition to the considered Alternative 9). The city indicated
(October 27, 1992 letter) that the City opposes package plants in the Urban
Services Area due to "bad experiences nation-wide with these systems" and that
there are current package treatment plants in Leon County with "known problems."
The City has also opposed County amendment proposals to the city's Master Plan
that would allow package plants in urban areas.

Although a decentralized alternative was considered in the EIS supplement
(Alternative 9), the approach taken by the EIS Supplement is that most larger
cities are converting to a centralized form of wastewater management. while
there are soil types in both northern and southern Leon County that could be used
for septic tanks, the County also contains areas with poorly drained soils and
tank failures. Also, if septic tanks fail,

the resultant water quality problems are difficult to detect early and to
subsequently mitigate, and conversion to a centralized system would then likely
occur anyway and, if so, probably at a higher cost.

o citv/countv Development Potential with a Centralized System

One of the initial (pre-DEISS) concerns of the public was that a
centralized sewage system would result in secondary development impacts, i.e.,
development of the City of Tallahassee and Leon County would be encouraged and
accelerated compared to a decentralized system (such as septic tanks requiring
minimum lot size acreage resulting in low density development). The USEPA does
not disagree with such concerns for increased potential for development of the
city and County with the implementation of a centralized system, and
environmental degradation can be associated with increased populations.
Development could result in non-point-source water quality degradation, wetland
losses and other environmental impacts. we therefore encourage the local
decision-makers to use good judgement in their land-use planning and zoning that
allow controlled development, as well as compliance with State of Florida and
Leon County Best Management Practices (BMPs) during construction. Conversely,
failing septic tanks can also result in water quality problems for surface and
groundwaters. Use of a centralized system should reduce such potential if
infiltration/inflow reduction and other maintenance programs are implemented by
the local provider.

o Project Funding and Costs

Although federal USEPA funds have been used for the City of Tallahassee
sewer system infrastructure in the past and federal funds were associated with
several alternatives in the USEPA 1983 EIS, no federal funds have presently been
requested by the City for alternatives considered in the present EIS Supplement
to the 1983 EIS, since all presented alternatives in the EIS Supplement are
considered "no-federal-action" alternatives. it is the understanding of the
USEPA that funding is to be obtained from local sources. The County indicated
(July 15, 1992 letter) a concern that local public funding was not distinguished

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from local private funding in the EIS Supplement. The local decision-makers may
or may not choose to distinguish cost sources for comparisons between, for
example, centralized versus decentralized alternatives. In addition, the City
of Tallahassee noted that a cost estimate for a backup system for golf course
spray irrigation for Alternative 1 (so that irrigation at these sites could be
discontinued if necessary) was not included in the FEISS (Chapter 2) and
considered this omission a "major oversight." The EIS Supplement (Section 3.1
in this FEISS) also did not include the initial "hook-up" costs in the FEISS
development of the total annual household costs for system customers (Section
3.1) for connection from a decentralized septic tank system to a centralize sewer
system. The City also was unclear as to why the EIS Supplement estimated that
sludge hauling costs for treatment south would be twice the cost for treatment
north and south. This appears to be due to different hauling distances and land
costs at the two facilities. Also, although the total city treatment capacity
was rerated to 32.0 mgd (or 32.06 if the MAP is included), it should be noted
that the flow projections in the EIS Supplement indicated that only 31.0 mgd
would be required for the planning period, so that 31.0 mgd was used in the EIS
Supplement (e.g., Section 2.4.1; Tables 2-11 through 2-18) in developing costs.
Local decision-makers may or may not choose to consider such cost issues.
Finally, it should be noted that cost estimates in this FEISS were based on 19 89
dollars unless otherwise indicated, which the local decision-makers may or may
not choose to update.

o Residential Connection to Centralized Sewer System

The USEPA understands from the City of Tallahassee that public complaints
are common regarding "hook-up" fees associated with residential connections to
a sewer system. The City's policy regarding connection has allowed some
practical public discretion. In general, if a septic system is functioning
properly, the City has not required a resident to connect to the sewer system;
however, a failing septic tank inside the city limits may not be repaired in lieu
of connection to the sewer system. In either case, however, a small City monthly
"readiness to serve charge" of $8.15 (for a typical residential meter size; in
fiscal year 1994 (FY 94) dollars) is required from all residents in a sewered
area, even if not connected. City fees (in FY 94 dollars) for connection inside
the City limits are $2,970, which includes a system fee of $2,520 and a (4-inch)
tap fee of $450, while City fees outside the City limits total $4,305.60
including a system fee of $3,855.60 ($3,780 plus 2% Leon County tax) and a
(4-inch) tap fee of $450. The city offers a loan program, so that connection
payments can be made with monthly utility payments. In addition, there is a City
monthly user fee of $2.60 per 1,000 gallons of sewage for residents inside the
City limits, and a $3.90 monthly user fee plus 2% per 1, 000 gallons of sewage_ for
residents outside the City limits. In addition to these payments to the city,
actual on-lot connection of a residence to the sewer system would be required,
so that an additional plumbing cost of approximately $1,000 (in 19 93 dollars) per
average residence can be expected. In general, the USEPA believes that the
City's practical approach regarding public discretion for sewer connection may
be acceptable provided that water quality problems are not continued or created
(as determined by the City or other appropriate government agency) so that water
quality standards are not violated.

As noted previously, the initial "hook-up" costs were not considered in the
FEISS. Local decision-makers may or may not choose to consider such additional
costs.

o USEPA NEPA Compliance

As previously indicated, the City of Tallahassee presently has not
requested any federal funds to implement the 19 88 City MSP, nor does the
implementation of the MSP as proposed otherwise constitute a "major Federal
action" under Section 102(2)(C) of NEPA, and NEPA does not mandate that an EIS
Supplement be prepared. However, this discretionary USEPA EIS Supplement

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provides technical guidance to the City of Tallahassee sewer Division as well as
other local decision-makers for facility expansion planning, unless the proposed
project becomes a major federal action, the selection of an appropriate
alternative for the City of Tallahassee wastewater management would be a local
decision. Since no major federal action is currently planned, the USEPA
presently does not intend to prepare a Record of Decision (ROD) for this EIS
Supplement. If, however, local decision-makers should ultimately include federal
involvement in the City MSP at the level of a "major Federal action," the EIS
Supplement (the DEISS and this FEISS) will serve to meet the requirements of NEPA
(and an ROD would be prepared), unless a significant amount of time has passed
before project implementation and significant changes have occurred in the
project as proposed, in the impacts of the project, and/or in the project area.
After appropriate examination of such considerations, the need for a supplemental
EIS to update the present EIS Supplement could be determined.

o USEPA Action on Storm Water Regulations and Permitting

Storm water point source discharges to waters of the United States from the
operation (spray irrigation) of non-agricultural/ non-silvicultural land
application sites (such as golf courses, rights-of-way, and landscape areas)
receiving domestic wastewater treated to the quality required by Chapter 17-610
F.A.C. for the land application of reclaimed water are not required to be covered
by NPDES permits, unless the USEPA specifically requires a facility to submit an
application on a case-by-case basis. Therefore, no NPDES permit is needed for
the operation of such land application sites for the city's proposed project (if
storm water point source discharges exist to waters of the United States for such
sites) unless specifically requested by the USEPA. However, dedicated discharges
of reclaimed water, without land application, are required to be covered by npdes
permits. It may also be noted that storm water discharges from the land
application of wastewater effluent on agricultural and silvicultural sites are
exempt from the NPDES permitting program if the sites are consistent with 40 CFR
Part 122.3(e), so that the operation of such sites for the city's proposed
project would not require an NPDES permit if consistent with 40 CFR 122.3(e).

o USEPA Action on Sludge Standards and Permitting

The USEPA established federal sludge disposal/reuse standards which were
promulgated in the Federal Register at 40 CFR 503 on February 19, 1993. In
general, these standards must be complied with by all treatment works treating
domestic sewage by February 19, 1994. Violation of these standards would be a
violation of the clean Water Act. It is anticipated that current and proposed
sludge disposal/reuse activities would be regulated through an NPDES permit,
where applicable, or through issuance of a "Sludge-Only" permit. This federal
permitting activity would be issued by the USEPA/Region IV until program
authorization is given to the State of Florida. Therefore, the newly promulgated
federal regulations are in addition to the State of Florida sludge disposal/reuse
regulations.

o Citizens Advisory Committee Action on Sewage Sludge

In response to the Florida regulations regarding sewage sludge and in
anticipation of the promulgation of the new federal (USEPA) sewage sludge
standards (40 CFR 503 [February 19, 1993]), a Citizens Advisory Committee (for
sewage sludge management) was formed on July 8, 1992. This Committee addressed
various processes to further reduce pathogens in sludge to allow disposal at the
existing agricultural (i.e., bermuda grass utilized as hay for livestock) sludge
fields indefinitely if the sludge meets additional pollutant concentration
requirements for inorganics such as metals (since Tallahassee is not a
particularly industrialized area, we understand from the City that these
requirements can be met) . The Committee agreed that the "chemical stabilization"
method might be the^ best for future implementation in a few years. Although the
City is currently in compliance with the permit requirements for Class B sludge,

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the City wishes to be able to dispose Class A sludge in the future. (Note: Class
A and B sludge are federal classifications defined in the promulgated standards.
A class A pathogen facility utilizes treatment to reduce pathogen densities to
levels that are protective of public health and the environment; a Class B
facility utilizes both treatment and site restrictions to reduce pathogen
densities to levels that are protective of public health and the environment.)

Also, the State of Florida regulations (Chapter 17-640 F.A.C.) address
sludge fields (Class B residuals) used as agricultural vs. disposal fields and
the utilization of crops grown on such sludge fields. In general, in order for
sludge fields to be defined as "agricultural" as opposed to "disposal" fields
depends on the amount of nitrogen applied (essentially, if the amount of nitrogen
from sludge and, if applicable, irrigated effluent does not exceed the nitrogen
demand of the crop, it is defined as an agricultural field). class B
restrictions regarding field buffer zones and crop utilization are specifically
addressed in Rule 17-640(6) F.A.C. Essentially, crops grown on Class B sludge
fields for consumption as animal feed or human food (fruits and vegetables that
do not touch the soil/sludge that are to be consumed raw; pasture vegetation) can
not be harvested until 30 days after the last sludge application. Root crops
that do touch the soil/sludge can not be harvested until 18 months after the last
sludge application. Accordingly, City of Tallahassee utilization of crops
(bermuda grass utilized as hay for livestock) grown on sludge fields must be
consistent with Chapter 17-640 F.A.C.

o Population Projections for Tallahassee

The USEPA understands from the County (July 15, 1992 letter) that the
County has concerns regarding the County-expected use of pre-19 9 0 population
estimates in the EIS Supplement. The County suggests that these estimates may
now be too high compared to the 199 0 census, given the economic "recession" (July
15, 1992 letter) and the adopted local Comprehensive Plan which affects County
developmental density. As such, the local decision-makers may or may not choose
to consider circumstances that may affect projections relating to the appropriate
amount of expansion of the Tallahassee wastewater management systems. According
to the Tallahassee-Leon County Planning Department (1992) statistics dated
February 14, 1992, obtained by the USEPA through the Tallahassee Chamber of
Commerce (Tallahassee Chamber), the 1990 census for Leon County (including
university students) indicates a population of 192,493 and a population
projection for the year 2010 of 261,600 (35% increase since 1990). It should be
mentioned that, according to personal communications with the Tallahassee chamber
(1992 and 1993), the City of Tallahassee constitutes approximately 90% of Leon
County and that no census data or projections exist at this time for incorporated
Tallahassee. However, estimates for incorporated Tallahassee obtained through
the Tallahassee chamber indicate a (presumed) 1990 population estimate for the
City of 124,773. In addition to this information, the Tallahassee chamber
indicated that the Leon County has a labor pool from a 13-county radius including
south Georgia. Therefore, an additional, apparently significant, population of
commuters exists in the County (including the city) during the work day.

o city Water Usage projections

The County (July 15, 1992 letter) also has concerns regarding the EIS
Supplement projection of 160 gpcpd of water usage as being high for the region
and accordingly resulting in an over-estimation of the amount of City expansion
necessary. It is the USEPA's understanding from the City that the 160 gpcpd is
the peak flow and 140 gpcpd is the average daily flow, the latter being used in
the EIS Supplement. It should be noted that water usage projections are
partially based on drinking and wastewater volumes for residents. Based on the
literature (Baker et al., 1975; USEPA, 1977), average American per capita
household consumption rates can be expected to approximate 6 0 gpd but can be
greater (86 gpcpd - Durham, North Carolina projections for 2010: USEPA, 1989; 123
gpcpd - general Florida in 1985: USGS, 1990). Added to such domestic

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requirements are the water needs of local industrial, commercial, power plant,
etc. consumption needs. The City (October 27, 1992 letter) emphasized that the
160 gpcd wastewater flow rate was ".. .not an average sewage use by residents" but
rather was "...the total flow at the plants (residential, industrial, commercial,
and institutional) divided by the total population served by the sewer system."
The City also indicated that the per capita figure is higher than what one
resident produces since Tallahassee experiences a "very significant sewage flow"
from non-residential sources including people working in Tallahassee but living
outside the City sewer system. This is consistent with the above Tallahassee
Chamber information regarding commuters.

Examples of overall water consumption rates in the literature are 100 gpcpd
for Baldwin County, Alabama (USEPA, 1990); 187 gpcpd for Oade County, Florida
(Miami-Dade Water and Sewer Authority Department, 1991); and 172 gpcpd for
general Florida in 1985 (USGS, 1990). The local decision-makers may or may not
choose to revisit the 160 gpcpd figure and attendant sewage treatment/ effluent
disposal needs based on specific local consumption needs, water conservation
methods (which the USEPA encourages), projected City growth, and contingencies.
It should be noted that domestic and agricultural irrigation usage should not be
included in per capita figures since such wastewater would not be returned to the
sewer system; the commercial, industrial and demographic aspects of the
Tallahassee service area are important considerations; university students and
families with children often exhibit greater than average domestic water usage;
and conservation methods may or may not be practiced in the Tallahassee area.

o Local Water Conservation

The county (July 15, 1992 letter) also has concerns that water conservation
methods relative to city water distribution and City sewerage generation were not
provided in the EIS Supplement, suggested heightened water management practices
were: system-wide reductions of pressure, water conservation programs, and the
adoption of incentive-based rate structures. it was suggested that water
conservation methods may preclude the need for the City's proposed additional
sewer facilities. The City indicated (October 27, 1992 letter) that "...water
conservation would not have resulted in these projects being done" and that the
T.P. smith Plant was being expanded because of increased peak monthly flows in
1987 and 1988 which resulted in the City "...slightly exceeding the plant's
average capacity." In addition, the FDEP had requested that the plant and SE
Sprayfield be expanded, which was agreed to in a City-FDEP Memorandum of
Understanding. A proposed new force main was intended to "...handle diversions
from an existing trunk which became overloaded during very wet periods" and new
growth in the future. The city's "aggressive" Infiltration/Inflow (I/I)
reduction program had also discovered leaks of which 75% had been repaired to
reduce peak flows (with work continuing on the other discovered leaks).

The USEPA strongly supports water conservation methods and related
recycling and pollution prevention (source reduction) methods in households and
industry. The FEISS addresses some water conservation approaches in Table 2-5
of this FEISS; however, the USEPA understands from the City that, although
conceptually not opposed to water-saving devices, the city presently has no
prepared plan to implement water-saving devices and believes that such devices
would be difficult to implement since Tallahassee has an abundant water supply.
Nevertheless, the USEPA encourages the city and the County to consider water
conservation methods as part of facility design and to implement such
conservation methods.

o citv Centralized sewer system Spills

The County indicated (July 15, 1992 letter) concerns regarding "numerous
repeated sewage spills" from the centralized City system that occurred throughout
1991 at Lake Munson and Lake Lafayette were not discussed in the EIS supplement.
The City indicated (October 27, 1992 letter) that these spills occurred during

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heavy rainfall periods during January and March of 1991 and that city trunk lines
experienced more infiltration and inflow than could be handled, and offered that
the total volume spilled in 1991 from the City's system "...was about 0.4 percent
of the estimated volume which flows from septic tanks within Leon County
annually."

Such spills are generally more "visible" than septic tank failures and are
a localized or point source impact, which therefore can be (and should be)
relatively easily corrected by the city. The city indicated (October 27, 1992
letter) that such problems had not occurred in 1992 due to drier weather, the
City's I/I reduction program, and the City's capital improvement program. The
City furthermore stated that: "We are not happy about the 1992 incidents but
these were very unusual in nature and due to our capital improvements, won't be
repeated."

o other sewer service Providers

The County indicated (July 15, 1992 letter) that the future role of other
local sewer service providers, such the Talquin Electric Cooperative (TECO),
should be have been considered as opposed to limiting the alternatives of the Eis
Supplement to the promotion of the City's central sewer system. In addition to
references to TECO in the FEISS (e.g., section 2.1.2), local decision-makers may
or may not choose to use various providers in the wastewater management of
Tallahassee, although the City would seem to be the largest centralized system
in the area and have experience with large (mgd) process flow volumes. To date,
TECO apparently is experienced in accommodating area small (mgd) process flow
volumes.

o Human Health Risks

Potential health risk concerns associated with spray irrigation of treated
effluent have been raised by the local public. These include concerns from
sprayfield aerosols containing non-pathogenic bacteria and pathogens (e.g.,
pathogenic bacteria, viruses, protozoans and other infectious microbes) traveling
away from the sprayfield area, and the potential groundwater contamination of
drinking water. It is generally documented that wastewater treatment methods can
remove significant numbers of pathogens and non-pathogenic bacteria typically
associated with sewage wastewater. However, not all may be killed by
disinfection. In the case of pathogens such as viruses, the surviving numbers
could potentially be hazardous from a human health perspective since even a small
number of viruses can be infectious. However, several precautions can be taken
to reduce the human health risk at spray irrigation sites, including effluent
treatment, effluent monitoring, on-site containment of aerosols, prevention of
on-site ponding of sprayed effluent to reduce animal vectors, and groundwater
monitoring. The USEPA supports the implementation of such precautions for
sprayfield irrigation projects.

The USEPA understands from the City of Tallahassee that fecal coliform
levels are monitored by the city before effluent is spray irrigated on
sprayfields and after irrigation via groundwater monitoring. The USEPA also
understands from the city that the water quality limits for fecal coliform levels
used by the City for effluent prior to sprayfield irrigation is the State of
Florida standards defining "secondary treatment" of wastewater, i.e., <200
organisms per 100 ml of effluent. Although there are no USEPA or federal
standards for fecal coliforms for spray irrigated effluent, this criterion is
consistent with USEPA guidance from the Requirements Memorandum #79-3 dated
November 15, 1978 of the former Construction Grants Program (USEPA, 1978). The
concepts of this memorandum were incorporated in a USEPA Technology Transfer
manual entitled "Land Treatment of Municipal Wastewater" (USEPA No. 625-1-81-013)
(USEPA, 1981). The 200 counts/100 ml of effluent criterion is USEPA's fecal
coliform criterion for bathing (swimming) waters. it is presumed that water
considered safe enough for swimming (which could include incidental drinking)

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would be adequate for irrigation of sprayfields, particularly with vegetated
buffers. In the absence of federal standards regarding acceptable remaining
levels of fecal coliforms in sprayed effluent, the USEPA recommends that the
state of Florida the use, at a minimum, the above federal guidance (USEPA, 1981)
to help protect public health and the environment during their permitting
decision for effluent sprayfields in addition to any appropriate state of Florida
regulations (Chapter 17-640 F.A.C.) for public access areas.

As suggested above, the USEPA also supports implementation of vegetated
buffer zones on outer borders of sprayfields, implementation of internal
sprayfield vegetated corridors, reduction of sprayfield spraying during windy
days and during the night (to the extent feasible) when atmospheric conditions
promote aerosol dispersion, in order to help contain spray irrigation aerosols
on-site sprayfields. In regard to groundwater monitoring of sprayfields, the
USEPA understands from the city that the state of Florida groundwater standards
used by the City for groundwater monitoring are the drinking water standards for
fecal coliforms, i.e., no (zero) fecal coliforms, so that City compliance with
these standards would result in no additional fecAl coliforms in the groundwater.

The spray application of wastewater effluent on golf courses and other
public access areas having greater public access than agricultural or
silvicultural sprayfields, would require additional effluent treatment for
suspended solids removal and high-level disinfection under state of Florida
regulations (Chapter 17-610 F.A.C.). Compliance with these regulations should
greatly reduce the health risks associated with aerosols at golf courses and
other public access irrigation areas. Irrigation of golf courses is not uncommon
in Florida. However, such public access irrigation areas would need an alternate
disposal method available as a backup so that irrigation at these sites could be
discontinued as necessary (it is the understanding of the USEPA from the city
that such a backup method does not currently exist for Alternative 1).

Also related to human health is the utilization of crops grown for
consumption on sprayfields and sludge fields (see below).

o Crops Grown on sprayfields And Sludge Fields

The USEPA understands from the city that crops for animal feed and/or
processed food for humans are grown and harvested on City sprayfields. Crops
include corn, canola, rye/rye grass and soy beans (processed foods probably would
include soy bean and canola oils). Cattle are also grazed on irrigated fields.
Also, sludge fields (Class B or equivalent) are used by the City for the harvest
of bermuda grass for hay for cattle feed (harvesting 30 days after last sludge
application).

The FDEP stipulates that all agricultural products produced from effluent
irrigated sprayfields are not for direct human consumption (Chapter 17-610
F.A.C.s Rules 17-610.200(13), 17-610.310(d), 17-610.320(2), 17-610.425,
17-610.426, 17-610.475, and possibly others). Consistent with Chapter 17-610
F.A.C., "edible" crops intended for human consumption must be "peeled, skinned,
cooked or thermally processed before consumption is allowed" (Rule 17-610.475).
Also, cattle providing milk for human consumption are not to be grazed on
irrigated fields until 15 days from the last field application of reclaimed water
(Rule 17-610.425). Accordingly, irrigated agricultural crops produced by the
City from the proposed Alternative 1 may only be utilized as animal feed and/or
as processed food for humans to the extent consistent with Chapter 17-610 F.A.C.
Grazing of cattle on proposed or existing irrigated sprayfields may also only be
conducted to the extent consistent with Chapter 17-610 F.A.C.

The USEPA understands from the City that a significant number of cattle
(perhaps 100 head) died during one winter (cerca 1990) at the City's SE
sprayfield. Although the city does not believe that the deaths were related to
the cattle grazing on the sprayfield, the cattle were not autopsied. The cattle

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were buried on site.

State of Florida regulations (Chapter 17-640 F.A.C.) also address the
utilization of crops grown on sludge fields. class B restrictions regarding
field buffer zones and crop utilization are specifically addressed in Rule
17-640(6) F.A.C. Essentially, crops grown on Class B sludge fields for
consumption as animal feed or human food (fruits and vegetables that do not touch
the soil/sludge that are to be consumed raw; pasture vegetation) can not be
harvested until 30 days after the last sludge application. Root crops that do
touch the soil/sludge can not be harvested until 18 months after the last sludge
application. Accordingly, City of Tallahassee utilization of crops for animal
feed grown on sludge fields must be consistent with Chapter 17-640 F.A.C.

o Project Environmental Impact Mitigation

The County (July 15, 1992 letter) has concerns regarding the lack of
mitigation presented in the EIS Supplement for the more undesirable environmental
impacts of the proposed expansion of the city's SE Sprayfield. The EIS
Supplement approach to such projected impacts was in the form of "pollution
prevention/ reduction" through the implementation of "Environmental Protection
Measures" which are provided below and characterized as to the likelihood of
implementation by the City. Some of the important proposed measures include:
retainage/creation of vegetated buffer strips along outer borders of the
sprayfield, retainage of wildlife corridors and habitat within the sprayfield
area, coordination with the state of Florida (Florida Game & Fresh Water Fish
Commission) regarding effects on the Gopher Tortoise and Gopher Frog and other
protected species, avoidance of wetlands, completion of an on-site archaeological
survey, use of agricultural spray irrigation and silvicultural spray irrigation
(small demonstration project) to minimize habitat losses and global climate
change impacts associated with land-use conversions from forests to sprayfields,
avoidance of sprayfield drainage into Karstic sinkhole areas, prevention of the
use of irrigated agricultural products for direct human consumption, and
continuance of the city's effluent and groundwater monitoring. The USEPA also
supports mitigation of unavoidable project impacts as well as the correction of
any project violations of relevant federal, state, and local regulations.

The city suggested (October 27, 1992 letter) that mitigation would not be
needed for public improvement projects such as sanitary sewer and proper
treatment projects that reduce public health risks and environmental damage,
while it is clear that competent sewer systems and treatment are beneficial to
the public, the USEPA does not believe that the environmental impacts of such
improvements should not be minimized through environmental prevention methods as
well as mitigation, as appropriate, if impacts are unavoidable.

o Citv of Tallahassee Timeframe

The City has expressed concern regarding the length of time taken to prepare
this FEISS. It may be noted, however, that this FEISS is a discretionary EIS
Supplement presently proposing no use of federal funds or a major federal action.
Nevertheless, the USEPA recognizes that the proposed project is locally
significant; this discretionary EIS supplement has been prepared by the USEPA to
provide technical guidance to the city of Tallahassee sewer Division as well as
other local decision-makers for facility expansion planning.

o state of Florida Reorganization

The Florida Department of Environmental Regulation (FDER) and the Florida
Department of Natural Resources (FDNR) were reorganized effective July 1, 1993,
to become a single Florida Department of Environmental Protection (FDEP).
References made to "FDER" and "FDNR" in the DEISS and in the remaining text of
this FEISS may therefore appropriately be updated to "FDEP" (with the exception
of citations published prior to July 1, 1993).

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>>•* *5^

B'gSiD of County Commissioners

Leon County Courthouse
Tallahassee, Florida 32301
(904) 488-4710

Commissioners:

ANITA L DAVIS
otana 1

GAYLE NELSON
DMCI2

MANNY JOANOS

DMrta3

DON C. PRICE

0Mia4

GAKYYOROON

DtsMaS

MAHJORIE TURN8ULL

AtUq*

J. LEEVAUSE

PARWEZALAM
County AdmMsraor
(904)4884962

HERBEHT WA THIELE
Corny A&omay

(904)487-1008

LEON COUNTY PUBLIC WORKS
Leon County Courthouse
301 South Monroe Street
2nd Floor, Room 201
Tallahassee, Florida 32301
904 / 488-8003

July 15, 1992

Mr. Heinz J. Mueller, Chief
Environmental Policy Section EPA, Region IV
345 Courtland Street, N.E.

Atlanta, Georgia 30365

RE: Comments on Draft Copy of the EPA Tallahassee Wastewater Management
Final Environmental Impact Statement Supplement (FEISS)

Dear Mr. Mueller:

Upon a review of the subject document we have identified what are believed to be the

following shortcomings of text:

1.	It has been found that the document generally ignores and otherwise fails to
mention our locally adopted "Southern Strategy." It is our observation that all
of the alternatives evaluated consider southerly expansions of both wastewater
treatment and disposal facilities which deviates from the intent of these
important local planning guidelines.

2.	The document fails to address the restraints placed on an implementation of
alternatives:

A.	How would the City of Tallahassee expand or supply additional
southeast disposal facilities being that the Board of County
Commissioners has recently denied the City all necessary franchise
areas and right-of-way placement permits to support these undertakings?

B.	How is the City of Tallahassee to expand its southeast disposal facility
being that the City Commission has recently directed city staff to drop
all pursuits of this work? In addition, does not the City presently have
a consultant working to identify a means of optimizing the use of lands
upon which existing disposal facilities are sited in lieu of constructing
additional facilities on adjacent lands? It is noted that it is our belief
that the hiring of this consultant also follows the direction of the City

US-18

An equal opportunity/affirmative action employer

-------
Commission.

C. The document fails to mention that the proposed additions of a northeast
treatment plant and northeast effluent disposal areas may now be moot
considerations. It is believed that on March 11, 1992 the Tallahassee
City Commission elected to terminate its contract with consultant
working to amend the City's Master Sewer Plan and that this may have
put an end to the northeast treatment plant. These new facilities were
to be the primary focus of this report.

The document generally fails to identify and otherwise ignores what we believe

to be the establishment of other viable alternatives:

A.	None of the alternatives evaluated focuses completely upon a
decentralized approach to wastewater management. It is our observation
that the primary consideration of all the alternatives evaluated is the
future propagation and expansion of the City of Tallahassee's central
sewer system.

B.	The future role of other significant providers of local sewer service,
namely those supplied through Talquin Electric Cooperative and others,
fails to be a consideration of this document.

C.	The future role of package treatment plants in accomplishing local
wastewater management goals fails to be a consideration of this
document.

D.	The future viability of traditional and "hybrid" septic tank systems as
a wastewater management option is generally ignored by this document.

E.	The interrelationships of City water distribution to City sewerage
generation rates is generally ignored. Does not the possible
implementation of heightened water management practices including
system-wide reductions of pressure, water conservation programs, or the
adoption of incentive-based rate structures at least bear consideration in
this report. It is our observation that the report generally fails to
explain why all of the additional City sewer facilities need to be
constructed when several good water conservation options are known to
exist.

The document generally fails to substantiate or validify the selection of data:

A. Unless mistaken, this document is prepared based upon the use of pre-

US-19

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1990 population estimates. It is pointed out that subsequent to this time
the 1990 census has been released (showing that earlier estimates of the
local population base may have been too high), a local Comprehensive
Plan has been adopted and put into effect (including comprehensive
revisions of land use maps impacting developmental density and the
resulting population projections of areas still yet to be developed) and
an economic recession has gained a stronghold on the area impacting
development and slowing growth. It is highly doubtful that the
population estimates used to assemble the report are any longer valid in
light of these current events.

B.	It is our observation that the per capita estimates utilized in this
document are among the highest, if not the highest, , in use anywhere in
our region of the Country. How have you substantiated the selection
and usage of such an inflated per capita consumption rates as 160
gpcpd? Can it be that this is truly a realistic figure? Does not the use
of such a high figure as 160 gpcpd vastly overestimate sewer flow?
Could it not result in a tendency to recommend that we vastly
overconstruct "needed" sanitary sewer facilities?

C.	Problems are observed in the cost analysis section of report. It is
presently not clear as to whether or not there are any distinctions made
between what are to be public and private costs. Should there be any-
public interest in the private costs of accomplishing wastewater
management so long as these systems do not become eventual public
problems?

5. The document generally fails to fully assess the environmental impacts of the

alternatives considered:

A.	Only failures of decentralized facilities (package plants/septic tanks) are
noted. Not included are the impacts of numerous repeat sewage spills
from city systems such as those evidenced throughout 1991 (LaJce
Munson, Lake Lafayette). What are the environmental impacts of these
failures and how have they been assessed?

B.	Why are man-made wetlands discredited without discussion when the
technology is so rapidly emerging in Florida and with successful
demonstrations already in existence located as near to us as the City of
Orlando?

C.	It is not clear how the impacts of constructing additional centralized
facilities were assessed and what these impacts are. Also, why have

US-20

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you not advised us as to what forms of mitigation are in order to offset
the more undesirable consequences realized through an analysis of the
impacts?

This concludes our desire to comment on the EIS supplement as of this time. In the
event that you may find questions relating to any of our various comments, please feel
free to call.

Chief of Engineering Design
Enclosures

cc: Board of County Commissioners

Parwez Alam, County Administrator

Herb Thiele, County Attorney

Brent Wall, Assistant to the County Administrator

Michael C. Willett, Public Works Director

Tony Park, P.E., Director of Engineering Services

US-21

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17 y£-/

CITY OF TALLAHASSEE

CITY HALL
300 S. ADAMS ST.
TALLAHASSEE. FL
32301-1731

904/599-8100
904/599-8210 FAX

DOROTHY INMAN-CREWS
Mayor Pro Tem-
Commissioner

BOS HIGHTOWER

Mayor-Commissioner

STEVE MEIS8URG
Commissioner

DEBORAH A. UGHTSEY
Commissioner

PENNY SHAW HERMAN
Commissioner

ROBERT a INZER
City Treasurer-Clerk

DANIEL A. KLEMAN
City Manager

October 27, 1992

Mr. Chris Hoberg
Environmental Protection Agency
Environmental Policy Section
Federal Activities Branch
345 Courtland Street, N.E.

Atlanta, GA 30365

Dear Mr. Hoberg:

Tha„k you for -b.. a s - L-.	r

zfjjs —-»—-- -in ^

(attached).

a n„ iniv 13 1991 the County denied two franchise applications for an effluent force
main from the T. P. Smith Plant to the Southeast Sprayfield and for the expansion of
rtTfteld itself The City Commission and County Commission subsequently made
aoDointments to an advisory committee which has looked into alternatives. During this
oS the County Commission stated that "the sole eastern expansion of the
Seldtno loZ a consideration of this Commission. ¦ We do not believe that the
dL is closed forever on a sprayfield expansion; and, in fact, it >s one of the least
costly of the alternatives considered. The City Commission is expected to review this
matter on November 16, 1992.

2 B Due to the July 23, 1991 action by the County Commission, the City is obviously not
spending a great deal of money on the Southeast Sprayfield expansion. After the City
Commission reviews the work of the citizen committee, the City's effluent consultant
(CDM), and staff, it may readdress the Southeast Sprayfield option.

The City did complete work, throughout its consultant and & technical committee, on
addressing the question of whether or not more effluent could be directed toward the
existing Southeast Sprayfield. The conclusion was that the field cannot accept more
water than currently permitted (3.16 inches/week application). The County was
included on the technical committee.

Item

US-22

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Mr. Hoberg
Page 2

October 27, 1992

2.C.	The City Commission did not terminate work on the master sewer plan update, but
rather put this work "on hold" because of County action. The County had sent
proposed amendments to the State's Department of Community Affairs (DCA) which
would allow small lots (down to 1/2 acre) to develop on septic tanks and would have
allowed package treatment plants to serve urban needs. The City was opposed to these
County proposals; and, in fact, the DCA within the last month rejected the County's
proposed amendments.

A second County action also led to the City Commission's action to hold the master
plan update in abeyance. The County took the unilateral action of defranchising City
water and sewer zones which lie beyond the city limits. Since 1980, the City and
County have acted within the confines of a 1980 City-County agreement which
provided water and sewer zones within which the City could operate. Upon
defranchising these areas, the City was left with an unknown as to what it will serve in
the future.

3.C.	The City remains opposed to package treatment plants in the Urban Services Area
because of bad experiences nation-wide with these systems. In addition, there are
current package treatment plant problems within Leon County with known problems.

3.D. You have been involved with readdressing the Environmental Impact Statement of 1983
because of septic tank failures. A joint City and County Commission letter was sent to
EPA in 1987 requesting that you revisit the 1983 decision. This request was prompted
by septic tank failures in the County, beyond the city limits. It's difficult to imagine
that the County continues to promote the septic tank approach given the problems that
are encountered with these in the clay soil areas.

3.E. There are numbers of reasons why the City is currently constructing numerous sewer
facilities. I assume that Mr. Brantley is referring to the current plant expansion and
large force main projects. In either case, water conservation would not have resulted in
these projects not being done. The plant is being expanded because of peak monthly
flows in 1987 and 1988 which resulted in our slightly exceeding the plant's average
capacity. Even though we continued to produce high quality effluent, which met all
DER requirements, DER felt that we should expand the plant and sprayfield. A
memorandum of understanding was agreed to by DER and the City which called for the
expansions. The force main has been installed, again primarily because of peak flows.
In the near term, it will handle diversions from an existing trunk which became
overloaded during very wet periods. In the longer term, it will handle new growth.
Conservation would not have been sufficient to preclude either of these projects.

I must point out that since 1988, the City has had a very aggressive Infiltration/Inflow
(I/I) reduction program. We have smoke tested the entire sewer system once and have
started smoke testing it for a second time. We've found leaks both in City right-of-way

US-23

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Mr. Hoberg
Page 3

October 27, 1992

and on private property and have repaired 75 percent of the leaks found with work
continuing on the remaining leaks. This has reduced our peak flow during wet weather
considerably. Attached is a recent report which summarizes the result of our
aggressive I/I reduction program.

4.B.	There may be a misunderstanding regarding the 160 gpcd wastewater flow rate. It is
not the average sewage use by residents. It is very simply the total flow at the plants
(residential, industrial, commercial, and institutional) divided by the total population
served by the sewer system. Because we have a very significant sewage flow from
other than residential, the per capita figure is higher than what one resident contributes.
It is also influenced by the fact that much of this non-residential flow is the result of
people living beyond our sewer system but working in Tallahassee.

5.	A. This area received extremely heavy rainfall in January and March 1991. During those

periods, several City trunk lines received more infiltration and inflow than they could
handle and spills occurred. In addition, a pipe broke in the very bottom of one of our
pump stations so a spill occurred until crews could make the repair. As a result of
drier weather, the I/I program, and our capital improvement program, we have not had
these types of problems in 1992. I would point out that the total volume that was
spilled in 1991 from our system was about 0.4 percent of the estimated volume which
flows from septic tanks within Leon County annually. We are not happy about the
1992 incidents but these were very unusual in nature and due to our capital
improvements, won't be repeated again.

5.C. I fail to understand why mitigation would be needed to compensate for a public
improvement. Sanitary sewers and proper treatment have been a necessity in our urban
society and have been a major factor in reducing environmental damage and public
health risk.

Thank you for your consideration of my comments. I would be happy to answer questions.

James H. Peters, P.E.
Director

Water & Sewer Department

JHP/je

Attachments

xc: Tom Brantley, Leon County

John Dean, Supt.-Wastewater Operations

US-24

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of County Commissioners

Leon County Courthouse
Tallahassee. Florida 32301
(904) 48&4710

Commissioners:

ANITA L DAVIS
Oistna 1

GAYUS NELSON
Oistna 2

MANNY JOANOS
Oistna 3
DON C. PRICE
Oistna 4
GARY YOROON

oiwtas

MAIUORIE TURNBUU.
At-tjvg«

J. leevause

Ai-Lirg*

PARWEZ AUkM
County Administrator
(904)488-9902

HERBEHT W.A. THIELE
County Anorn«y
(904) 487-1008

LEON COUNTY PUBLIC WORKS
Leon County Courthouse
301 South Monroe Street
2nd Floor, Room 201
Tallahassee, Florida 32301
904 / 488-8003

July 15, 1992

Mr. Heinz J. Mueller, Chief
Environmental Policy Section EPA, Region IV
345 Courtland Street, N.E.

Atlanta, Georgia 30365

RE: Comments on Draft Copy of the EPA Tallahassee Wastewater Management
Final Environmental Impact Statement Supplement (FEISS)

RECEIVED

OCT 141992

WASTEWATER DIVISION

Dear Mr. Mueller:

Upon a review of the subject document we have identified what are believed to be the
following shortcomings of text:

1.	It has been found that the document generally ignores and otherwise fails to
mention our locally adopted "Southern Strategy." It is our observation that all
of the alternatives evaluated consider southerly expansions of both wastewater
treatment and disposal facilities which deviates from the intent of these
important local planning guidelines.

2.	The document fails to address the restraints placed on an implementation of
alternatives:

A.	How would the City of Tallahassee expand or supply additional
southeast disposal facilities being that the Board of County
Commissioners has recently denied the City all necessary franchise
areas and right-of-way placement permits to support these undertakings?

B.	How is the City of Tallahassee to expand its southeast disposal facility
being that the City Commission has recently directed city staff to drop
all pursuits of this work? In addition, does not the City presently have
a consultant working to identify a means of optimizing the use of lands
upon which existing disposal facilities are sited in lieu of constructing
additional facilities on adjacent lands? It is noted that it is our belief
that the hiring of this consultant also follows the direction of the City

US-25

An equal opportunity/affirmative action employer

-------
Commission.

C. The document fails to mention that the proposed additions of a northeast
treatment plant and northeast effluent disposal areas may now be moot
considerations. It is believed that on March 11, 1992 the Tallahassee
City Commission elected to terminate its contract with consultant
working to amend the City's Master Sewer Plan and that this may have
put an end to the northeast treatment plant. These new facilities were
to be the primary focus of this report.

The document generally fails to identify and otherwise ignores what we believe

to be the establishment of other viable alternatives:

A.	None of the alternatives evaluated focuses completely upon a
decentralized approach to wastewater management. It is our observation
that the primary consideration of all the alternatives evaluated is the
future propagation and expansion of the City of Tallahassee's central
sewer system.

B.	The future role of other significant providers of local sewer service,
namely those supplied through Talquin Electric Cooperative and others',
fails to be a consideration of this document.

C.	The future role of package treatment plants in accomplishing local
wastewater management goals fails to be a consideration of this
document.

D.	The future viability of traditional and "hybrid" septic tank systems as
a wastewater management option is generally ignored by this document.

E.	The interrelationships of City water distribution to City sewerage
generation rates is generally ignored. Does not the possible
implementation of heightened water management practices including
system-wide reductions of pressure, water conservation programs, or the
adoption of incentive-based rate structures at least bear consideration in
this report. It is our observation that the report generally fails to
explain why all of the additional City sewer facilities need to be
constructed when several good water conservation options are known to
exist.

The document generally fails to substantiate or validify the selection of data:

A. Unless mistaken, this document is prepared based upon the use of pre*

US-26

-------
1990 population estimates. It is pointed out that subsequent to this time
the 1990 census has been released (showing that earlier estimates of the
local population base may have been too high), a local Comprehensive
Plan has been adopted and put into effect (including comprehensive
revisions of land use maps impacting developmental density and the
resulting population projections of areas still yet to be developed) and
an economic recession has gained a stronghold on the area impacting
development and slowing growth. It is highly doubtful that the
population estimates used to assemble the report are any longer valid in
light of these current events.

B.	It is our observation that the per capita estimates utilized in this
document are among the highest, if not the highest, in use anywhere in
our region of the Country. How have you substantiated the selection
and usage of such an inflated per capita consumption rates as 160
gpcpd? Can it be that this is truly a realistic figure? Does not the use
of such a high figure as 160 gpcpd vastiy overestimate sewer flow?
Could it not result in a tendency to recommend that we vastly
overconstruct "needed" sanitary sewer facilities?

C.	Problems are observed in the cost analysis section of report. It is
presently not clear as to whether or not there are any distinctions made
between what are to be public and private costs. Should there be any
public interest in the private costs of accomplishing wastewater
management so long as these systems do not become eventual public
problems?

5. The document generally fails to fully assess the environmental impacts of the

alternatives considered:

A.	Only failures of decentralized facilities (package plants/'septic tanks) are
noted. Not included are the impacts of numerous repeat sewage spills
from city systems such as those evidenced throughout 1991 (Lake
Munson, Lake Lafayette). What are the environmental impacts of these
failures and how have they been assessed?

B.	Why are man-made wetlands discredited without discussion when the
technology is so rapidly emerging in Florida and with successful
demonstrations already in existence located as near to us as the City of
Orlando?

C.	It is not clear how the impacts of constructing additional centralized
facilities were assessed and what these impacts are. Also, why have

US-27

-------
you not advised us as to what forms of mitigation are in order to offset
the more undesirable consequences realized through an analysis of the
impacts?

This concludes our desire to comment on the EIS supplement as of this time. In the
event that you may find questions relating to any of our various comments, please feel
free to call.

Chief of Engineering Design
Enclosures

cc: Board of County Commissioners

.Parwez Alam, County Administrator

Herb Thiele, County Attorney

Brent Wall, Assistant to the County Administrator

Michael C. Willett, Public Works Director

Tony Park, P.E., Director of Engineering Services

US-28

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MEMORANDUM

RECEIVED

SEP 0 21992

TO:	Andrew J. Davis	WATER & SEWER DEPT.

Wastewater Collection Supervisor

FROM:	James Love ^

I/I Reduction Supervisor

DATE:	September 1,1992

SUBJECT: I/I Report

Infow Reduction Report
As of August 31,1992
Cummulative Totals

Public	Private

R-O-W	Property	Total

Leaks Discovered

844

1,199

2,043

Volume Discovered

5,971,017

1,729,372

7,700,389

Leaks Repaired

502

1,036

1,538

Percentage Repaired

59%

86%

75%

Volume Eliminated (Gal.)

3,657,422

1,540,744

5,198,166

Percentage Eliminated

61%

89%

67%

Leaks Remaining

342

163

505

Volume Remaining (Gal.)

2^13,595

188,628

2,502,223

Note: Due to the necessity for using the I/I Repair Crews to perform repairs on City and County roads,
prior to street resurfacing, I/I repairs have decreased this month.

xc John L. Dean
James Peters

US-29

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Inflow\Infiltration	R

Repairs	Com

a

i

oj
O

Mar. 31,
Apr. 30, 1992
May 31,
June 30,
July 31,
Aug.31, 1992

Public
Private
Total

0 200 400 600 800

-------
Inflow\Infiltration	R

Volume of I\I Eliminated (Gallons):

Mar. 31,1992
Apr. 30,1992
May 31,1992
June 30,1992
July 31,1992
Aug. 31,1992

0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000

Private

Public

Total

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CHAPTER 1

CHAPTER 2
CHAPTER 3
CHAPTER 4
CHAPTER 5
CHAPTER 6
APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX D

APPENDIX E
APPENDIX F

PURPOSE OF AND NEED
FOR PROPOSED PROJECT

ALTERNATIVES DEVELOPMENT

ALTERNATIVES EVALUATION

PREFERRED ALTERNATIVE

EIS COORDINATION

LIST OF PREPARERS

ALTERNATIVE WASTEWATER
CONVEYANCE CONFIGURATIONS

ALTERNATIVE WASTEWATER
TREATMENT FACILITIES

ALTERNATIVE WASTEWATER DISPOSAL
FACILITIES

ALTERNATIVE SLUDGE TREATMENT
AND DISPOSAL FACILITIES

GLOSSARY

BIBLIOGRAPHY

TABLE OF CONTENTS

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FINAL ENVIRONMENTAL IMPACT STATEMENT SUPPLEMENT
TALLAHASSEE-LEON COUNTY WASTEWATER MANAGEMENT
TALLAHASSEE, LEON COUNTY, FLORIDA

tart.r OF CONTENTS

Page

EXECUTIVE SUMMARY 		ES-1

PROJECT UPDATES SUMMARY	US-1

TABLE OF CONTENTS		1

LIST OF APPENDICES		vi

LIST OF TABLES	vii

LIST OF FIGURES		i*

LIST OF ACRONYMS		X

CHAPTER 1 PURPOSE OF AND NEED FOR PROPOSED PROJECT

1.1	Purpose and Scope of the EIS Supplement	1-1

1.1.1	impetus for the EIS Supplement 		1-1

1.1.2	USEPA NEPA Compliance	I-2

1.1.3	Centralization Versus Decentralization 		1-3

1.1.4	Study Area Definition	

1.2	Background and Issues	1-5

1.2.1	The 1983 EIS	1-5

1.2.2	The EIS Supplement Public Scoping Meeting 		1-5

1.3	Previous Studies			1-6

1.3.1	Tallahassee-Leon County, Florida 201

Facilities Plan	I-6

1.3.2	Final Environmental Impact Statement,

Tallahassee-Leon County, Florida,

wastewater Management 		1-7

1.3.3	city of Tallahassee Master Sewer Plan,

1987-2010		1-8

1.3.4	Preliminary Leon County Master Water and Sewer

Service Plan	1-10

CHAPTER 2 ALTERNATIVES DEVELOPMENT

2.1 Existing Wastewater Management 	 . .	2-1

2.1.1	City of Tallahassee 		2-1

2.1.1.1	Interceptors		 .	2-1

2.1.1.2	Pumping stations 		2-1

2.1.1.3	Treatment Facilities 		2-1

2.1.1.4	Effluent Disposal Facilities 		2-1

2.1.1.5	Sludge Disposal 		2-4

2.1.2	Talquin Electric Cooperative, Inc		2-4

2.1.3	Leon County	2-5

2.1.4	On-Lot Wastewater Management 		2-5

i

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TABLE OF CONTENTS
(continued)

Page

2.2	Background Information 		2-6

2.2.1	Regulatory Criteria 		2-6

2.2.1.1	State Regulations for Effluent

Disposal	2-6

2.2.1.2	Federal Regulations for Effluent

Disposal and Sludge Disposal .... 		2-6

2.2.1.3	Federal Regulations for Activities

Affecting Wetlands 		2-8

2.2.1.4	Sewer Expansion 		2-9

2.2.2	Population Projections 		2-9

2.2.3	Flow Projection Analysis	2-10

2.2.4	Flow Reduction Measures	2-14

2.3	Description of wastewater Management Components	2-17

2.3.1	Alternative Wastewater Conveyance Configurations 		2-17

2.3.2	Alternative Wastewater Treatment Facilities 		2-17

2.3.3	Alternative Wastewater Disposal Facilities 		2-18

2.3.4	Alternative sludge Treatment and Disposal

Facilities	2-33

2.3.5	Alternative Decentralized Wastewater Management

Facilities				 .	2-33

2.3.5.1	On-Lot systems 		2-33

2.3.5.2	Area Systems	2-36

2.3.6	Management options 		2-36

2.3.7	Industrial Pre-Treatment			2-37

2.4	Alternative Wastewater Management Systems Screening 		2-37

2.4.1	Alternative Wastewater Management system

Composition			2-37

2.4.2	Preliminary Cost Evaluation 		2-40

2.4.3	Environmental Evaluation 		2-40

2.4.3.1	System Alternative 1 		2-54

2.4.3.2	System Alternative 2 	 .2-59

2.4.3.3	System Alternative 3 		2-59

2.4.3.4	System Alternative 4	!	2-6 0

2.4.3.5	System Alternative 5	!	2-61

2.4.3.6	System Alternative 6 		2-61

2.4.3.7	System Alternative 7	\	2-62

2.4.3.8	System Alternative 8			*	2-62

2.4.3.9	System Alternative 9	!	2-62

2.4.4	Technical and Institutional Feasibility 		2-63

2.4.5	Implementability and Environmental

Protection Measures 		2-67

2.4.5.1	Conveyance Facilities 		2-67

2.4.5.2	Wastewater Disposal Facilities 	 !	2-68

2.4.5.3	On-Lot Treatment and Disposal Facilities ....	2-68

2.4.5.4	Public Acceptance 	 [	2-73

ii

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TABLE OF CONTENTS
(continued)

Page

2.4.6 System Alternatives Selected for Detailed

Evaluation	2-73

2.4.6.1	System Alternative 1		 2-73

2.4.6.2	System Alternative 2		 2-74

2.4.6.3	System Alternative 3		 2-74

2.4.6.4	System Alternative 4		 2-74

2.4.6.5	system Alternative 5		 2-74

2.4.6.6	System Alternative 6		 2-74

2.4.6.7	System Alternative 7		 2-74

2.4.6.8	System Alternative 8		 2-75

2.4.6.9	Selected System Alternatives with Flow

Reduction Measures 	 2-75

2.5 Affected Environment 	 2-75

2.5.1	Description of the study Area 		2-75

2.5.2	Existing Natural Environment 	 2-77

2.5.3	Existing Man-Made Environment	t	2-83

CHAPTER 3 ALTERNATIVES EVALUATION

3.1 Cost and Implementability Evaluation	3-1

3.1.1 Cost Effectiveness				3-1

3.1.1.1 Project Costs 		3-1

3.1.1.1.1	system Alternative 1:

Treatment South, SE Agricultural

and Golf Course Spray Irrigation . . 3-1

3.1.1.1.2	System Alternative 2:

Treatment South/ SE Forest and

Golf spray Irrigation 	 3-2

3.1.1.1.3	System Alternative 7: Treatment
North and South, SE and NE

Artificial wetlands 		3-2

3.1.1.1.4	System Alternative 9:

Decentralized 		3-2

3.1.1.2	Financing Options 		3-2

3.1.1.2.1	Federal Grants 		3-3

3.1.1.2.2	Municipal Revenue Bonds 		3-3

3.1.1.2.3	Privitization . . . 		3-3

3.1.1.3	Annual Household Costs 		3-3

3.1.1.3.1	Household Characteristics 		3-3

3.1.1.3.2	Annual Debt Payment 		3-5

3.1.1.3.3	Annual Operating, Maintenance, and
Replacement Costs 		3-5

3.1.1.3.4	Assessment 		3-8

3.1.1.3.5	Total Annual Cost 		3-8

3.1.1.4	Alternative Cost-Effectiveness Summary	3-12

iii

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TABLE OF CONTENTS
(continued)

Page

3.1.2	implementability 		3-12

3.1.3	Reliability			3-15

3.2	Environmental Evaluation 		3-16

3.2.1	Primary Impacts	3-16

3.2.1.1	surface Water Resources 		3-16

3.2.1.2	Groundwater Resources 		3-18

3.2.1.3	Ecological Resources 		3-20

3.2.1.4	Floodplains and Wetlands 		3-21

3.2.1.5	Archeological, Historical and

Recreational Resources 		3-21

3.2.1.6	Noise, Odor and Air Quality	3-22

3.2.1.7	Human Health Effects 		3-23

3.2.2	secondary Impacts 		3-23

3.2.2.1	Land Use		3-23

3.2.2.2	Economics and Employment 	3-23

3.2.2.3	Transportation 		3-24

-3.2.2.4 community Services and Facilities 		3-24

3.2.2.5	Water Quality 		3-24

3.2.2.6	Ecological Resources 		3-24

3.2.2.7	Environmentally-Significant Agricultural

Lands	3-25

3.2.2.8	Archeological, Historical, and

Recreational Resources 		3-25

3.2.3	Alternatives Impacts Summary 		3-25

3.3	Environmental Prbtection Measures 		3-27

3.3.1	Surface Water		3-29

3.3.2	Groundwater	3-29

3.3.3	Ecological Resources 		3-29

3.3.4	Floodplains and Wetlands	3-30

3.3.5	Archeological, Historical, and Recreational

Resources	3-30

3.3.6	Noise, Odor, and Air Quality		

3.3.7	Human Health Effects 		3-31

3.3.8	Land Use	3-33

3.3.9	Economics and Employments	3-33

3.3.10	Transportation 		3-33

3.3.11	community Services and Facilities 		3-33

3.3.12	summary of Alternatives Environmental

Protection Measures 		3-33

CHAPTER 4 PREFERRED ALTERNATIVE

4.1	selection of the Preferred Alternative		

4.2	Success of City's SE and SW Sprayfield Operations		

4.3	status of Local Decision-Makers selection Process 		4-3

4.4	Description of the Preferred Alternative	4-4

4.5	Soil Associations of the Preferred Alternative	4-5

4.6	Environmental Impacts of the Preferred Alternative 		4-9

4.6.1 Primary Environmental Impacts 		4-9

iv

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TABLE OF CONTENTS

(continued)

4.6.2	Secondary Environmental Impacts 	 4-13

4.6.3	Permitting Requirements	4-15

4.7 Environmental Protection Measures 	 4-17

CHAPTER 5 EIS COORDINATION

5.1	Introduction	5-1

5.2	Coordination with Local, Regional, state and Federal

Agencies	5-1

5.3	Public Participation Program 	 5-1

5.3.1	1983 EIS Public Participation		 . 5-1

5.3.2	EIS Supplement Scoping Meetings and

Public Hearings 	 5-3

Public Notice 	 5-9

Written Comments on DEISS and USEPA Responses 	 5-11

Public Hearing Transcript 	 5-121

USEPA Responses to Public Hearing Comments 	 5-138

CHAPTER 6 LIST OF PREPARERS	6-1

V

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TABLE OF CONTENTS

(continued)

Page

LIST OF APPENDICES

Appendix A Alternative Wastewater Conveyance Facilities

Section A-l	Treatment South	A-l

Section A-2	Treatment North and South	A-2

Appendix B Alternative Wastewater Treatment Facilities

Section B-l	Lake Bradford Road Wastewater

Treatment Plant 		B-l

Section B-2	T.P. Smith Wastewater Treatment Facility ....	B-l

Section B-3	Northeast Wastewater Treatment Facility ....	B-l

Appendix c Alternative Wastewater Disposal Facilities

Section C-l	SE Agricultural.Spray irrigation 	 C_1

Section C-2	NE Agricultural Spray irrigation 	 c-4

Section C-3	SE and NE Forest spray irrigation	c-5

Section C-4	Power Plant Cooling Water 	 c-9

section c-5	Golf Course Irrigation 	 C-9

Section c-6	Golf Course, and State Ornamental Garden

irrigation			 . c-11

Section C-7	Power Line Right-of-way irrigation 	 c-11

Section c-8	Existing Sludge Disposal Field

irrigation	c-12

Section C-9	Rapid Infiltration Basin 	 C-13

Section C-10 Landscape irrigation and Disposal in

Percolation Ponds (Redistribution) 	 C-13

Section C-11 Point Source Discharge to Surface waters .... c-14

Section C-12 Deep Well Injection	C-15

Section C-13 Artificial (Constructed) Wetlands 	 c-16

Appendix D Alternative Sludge Treatment and Disposal Facilities

Section D-l	Land Spreading	

Section D-2	Pelletization 	 d-1

Appendix E Glossary 	 e-1

Appendix F Bibliography			

vi

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TABLE OF CONTENTS
(continued)

Page

LIST OF TABLES

2-1 Existing Wastewater Treatment Facilities	2-3

2-2 Population Projections by Service Area 		2-11

2-3 Flow Projections for centralized Service 		2-12

2-4 Population and Flow Projection Summary .	2-13

2-5 Assumptions for Estimating Potential for Flow

Reductions	2-15

2-6 Flow Reduction Projections by service Area	2-16

2-7 Alternative Wastewater Conveyance Components 			2-19

2-8 Alternative Wastewater Treatment Components 		2-24

2-9 Alternative Wastewater Disposal Components 		2-26

2-10 Alternative Sludge Treatment/Disposal Components 		2-34

2-11 system Alternative 1 . 		2-41

2-12 system Alternative 2		2-42

2-13 System Alternative 3	2-43

2-14 System Alternative 4	2-44

2-15 System Alternative 5	2-45

2-16 System Alternative 6		2-46

2-17 System Alternative 7	2-47

2-18 System Alternative 8 		2-48

2-19 System Alternative 9	2-49

2-20 Summary of system Alternatives Project Costs and

Present Worth Values 	 ...	2-52

2-21 summary of Environmental Characteristics of

Effluent Disposal Sites 		2-55

2-22 Potential installation and Operation Problems

of System Components	2-64

2-23 Summary of the Technical Feasibility of

Centralized vs. Decentralized Systems 		2-66

vii

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TABLE OF CONTENTS

(continued)

Page

2-24 Wastewater Land Disposal Techniques,

Implementability, Advantages

and Disadvantages	2-69

2-25 Failures and Remedial Actions, On-Lot Systems 	 2-72

2-26 Summary of Costs With and Without Flow Reduction

Measures for the Four System Alternatives Selected

for Further Consideration 	 2-76

2-27	Protected Flora and Fauna which May Occur In The

Study Area	2-81

3-1	Household Projections by Service Area 	 3-4

3-2 Estimated Median Annual Household Incomes and USEPA

Recommended Maximum Costs					3-6

3-3 calculation of Debt Payment for Sewered Population	3-7

3-4 Estimated Annual Operation, Maintenance and

Replacement Costs 	 3-9

3-5	Estimated Annual Household costs 		3-10

3-6	cost-Effectiveness Analysis Ratings . . 		3-11

3-7	Implementability Analysis Rating ... 		3-14

3-8	Reliability Analysis Rating			3-17

3-9	Environmental Impact Analysis Rating 		3-28

4-1	Summary of Selected System Alternative Rankings 		4-1

5-1	Agency Contacts	5-2

5-2 comment Letters Received by USEPA for Tallahassee-Leon
County Wastewater Management DEISS During the 45-day

Comment Period 	 5_4

5-3 Attendees at the USEPA Public Hearing; City Hall; City

commission chambers; Tallahassee, Florida; August 9, 1990. . . . 5-6

5-4 Public Hearing speaker comments Provided at the USEPA
Public Hearing; Tallahassee-Leon county wastewater
Management DEISS; City Hall; City Commission Chambers;

Tallahassee, Florida; August 9, 1990	 5-7

viii

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TABLE OF CONTENTS
(continued)

LIST OF FIGURES

1-1	sewer Service Areas 	 1-4

2-1	Existing Wastewater Management Facilities 	 2-2

2-2 Alternative and Existing Conveyance system,

Treatment South 	 2-22

2-3 Alternative and Existing Conveyance system,

Treatment North and South	2-23

2-4 Alternative Sprayfield Disposal sites and Area

Treatment Plants		2-32

2-5 Decision Tree for selected System Alternative Development .... 2-39

2-6 centralized Wastewater Management system Alternatives

1 through 4	2-50

2-7 centralized Wastewater Management System Alternatives

5 through 8	2-51

2-8 Physiographic subdivisions in Leon county 	 .... 2-78

2-9 Archeological Resources 	 2-82

4-1 Soils Map of the Eastern Expansion Area	4-6

4-2 Wildlife corridors (Proposed) and Sensitive

Resources, Preferred Alternative 	 • 4-7

4-3 Wildlife corridors (Suggested) and Sensitive

Resources, Preferred Alternative 	 4-8

ix

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LIST OF ACRONYMS

1983 EIS

201 Plan
Area systems

City

City Comp Plan
city MSP
county

county mw&ssp

EIS Supplement

FDEP

FDER

FDNR

FG&FWFC

gpcd

gpd

LBR Plant
LCPH

MAP Plant

mgd

NEPA

NE Plant

NPDES

RIB

SE Plant
SE sprayfieId

Original USEPA Final Environmental Impact Statement,
Tallahassee-Leon County Wastewater Management,
Tallahassee-Leon County, Florida (1983)

Tallahassee-Leon County, Florida, 201 Wastewater
Facilities Plan (Draft 201 Plan approved in April 1977)

Wastewater Management facilities with design average daily
flows less than 500,000 gallons per day (gpd). FDEP refers to
these facilities as Type II (flows between 100,000 and 500,000
gpd) and Type III (flows between 2,000 and 100,000 gpd)

City of Tallahassee, Florida

City of Tallahassee Comprehensive Plan

City of Tallahassee Master Sewer Plan, 1987-2 010 (1988)

Leon County, Florida

Preliminary Leon county Master water and Sewer Service Plan
(1988); Plan not approved by Leon County Board of
Commissioners

Environmental Impact statement supplement, Tallahassee-Leon
County Wastewater Management, Tallahassee-Leon County, Florida
(Supplement to the USEPA 1983 EIS)

Florida Department of Environmental Protection

Florida Department of Environmental Regulation

Florida Department of Natural Resources

Florida Game and Fresh Water Fish Commission

Gallons per capita per day

Gallons per day

Lake Bradford Road Wastewater Treatment Plant
Leon County Public Health Department
Municipal Airport Wastewater Treatment Plant
Million gallons per day

National Environmental Policy Act of 1969, as amended

Northeast Wastewater Treatment Plant

National Pollutant Discharge Elimination System

Rapid-Infiltration (Basin) System

Southeast Wastewater Treatment Plant

Southeast Wastewater Effluent Sprayfield (SESF)

x

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LIST OF ACRONYMS

(continued)

SHPO

SW Sprayfield

TECO

TLCPD

TPS Plant

USEPA

USDA FS

USDA SCS

USFWS
USGS

State Historic Preservation officer

Southwest Wastewater Effluent Sprayfield (SWSF)

Talguin Electric cooperative, Inc.

Tallahassee-Leon County Planning Department

Thomas P. Smith Wastewater Treatment Plant

United States Environmental Protection Agency

United States Department of Agriculture, Forest Service

United States Department of Agriculture, Soil Conservation
Service

United States Fish and wildlife Service
United States Geological Survey

xi

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CHAPTER 1

PURPOSE OF AND NEED
FOR PROPOSED PROJECT

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CHAPTER 1 PURPOSE OF AND NEED FOR PROPOSED PROJECT

1.1 PURPOSE AND SCOPE OF THE EIS SUPPLEMENT

1.1.1 impetus for the EIS supplement

since the mid-1970s, wastewater management alternatives have been developed
and evaluated for the Tallahassee-Leon county (Florida) area in four major
studies, including:

1977 -	Tallahassee-Leon County, Florida; 201 Facilities Plan (201

Plan); Draft 201 Plan approved in April 1977.

19 83 -	Final Environmental Impact Statement Tallahassee-Leon County

Wastewater Management, Tallahassee-Leon County, Florida (1983
USEPA EIS)

1988 -	City of Tallahassee Master Sewer Plan, 1987-2010 (City MSP)

1988 -	Preliminary Leon County Master Water and Sewer Service Plan

(County mw&ssp)

The City of Tallahassee (City) prepared a 201 Facilities Plan (201 Plan)
that proposed the expansion of the City's central sewers to serve growth areas
in Leon County. A draft 201 Plan was approved in April 1977. The 1983 EIS
further evaluated the 201 plan alternatives and the "No-Federal-Action"
alternative. The 1988 city MSP documented several basic alternatives (with many
sub-alternatives) that reflect the city's current requirements and concepts for
future wastewater management. The preliminary county MW&SSP presented eleven
generalized alternatives; five which entail county provision of water and sewer
services; five which rely on provision of water and sewer services by
organizations other than the County; and one which entails county provision of
water services only and relies on provision of seven services by others. The
preliminary County MW&SSP does not include the selection of a preferred
alternative. Further evaluations and the selection will be included in a future
revision. Sections 1.3.1 through 1.3.4 in this report describe in more detail
the alternatives developed and evaluated for each study referred to above.

The 201 Plan and the 1983 EIS were required in part because the City had
intended to use federal grants to fund the majority of a proposed expansion of
the City's wastewater collection and treatment facilities. The 1983 EIS "...
addressed the Federal Action of the provision of Federal funds for Phase II
wastewater facilities as proposed by the Draft 201 Facilities Plan for
Tallahassee-Leon County" (USEPA, 1983). The proposed Phase II wastewater
facilities were intended to service growth areas that would not be served by 201
facilities that were already approved for federal funding.

The 1983 EIS considered four federal-action alternatives which proposed
wastewater facility construction of either: 1) a new treatment plant in northeast
Leon county (to serve the northeast growth areas) and the expansion of the
existing Thomas P. Smith (T.P. smith) Wastewater Treatment Plant/Southwest (SW)
Treatment Facility beyond its Phase I capacity (to serve the southwest and
southeast service areas), with treated effluent disposal for the Northeast (NE)
Plant by means of rapid infiltration in the northeast and disposal of the T.P.
smith/sw Plant by conveyance to the expanded Southeast (SE) Sprayfield; or 2) an
alternative similar to above except disposal of all treated effluent would be at
the SE sprayfield; or 3) expansion (with conservation measures) of the T.P.
Smith/SW Treatment Facility by 0.3 mgd capacity and continuing to operate the
existing Lake Bradford Plant, with treated effluent disposal at the expanded SE
Sprayfield and facilities serving as a regional treatment system in either case;
or 4) construction of a new SE Treatment Plant (serving the southeast and

1-1

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northeast growth areas) to supplement the expanded T.P. Smi/	arowth

Facility (serving the southwest service area and projected southwest growth
areas), with treated effluent disposal at the expanded SE Spraytleia.

in addition to these four federal-action alternatives, * fifItQh-'
the No-Federal-Action alternative, was also considered in the 1983 Eis. x s
alternative considered the given condition within the Tallahassee-Leon County
area without changes and described wastewater treatment that would be available
without new federal funding. Generally, the No-Federal-Action alternative
assumed that no centralized, structural alternative would be conatrueted, witn
expansion of existing facilities only continuing to Phase I levels and new growth
for wastewater disposal to be provided by on-lot and small community systems.
The No-Federal-Action alternative was the baseline for evaluating environmental
impacts of the structural alternatives considered in the 1983 EIS. The No-
Federal-Action alternative was selected as the preferred alternative in the 1983
EIS.

Since the USEPA issuance of the 1983 EIS, investigations into failures of
on-lot septic systems within the study area and compilations of information
relating to soil types, water tables, and density have provided data which were
not available during the EIS study. Subsequently, the city of Tallahassee, Leon
county's Board of Commissioners, and the USEPA have determined the need to re-
evaluate the No-Federal-Action alternative selected in the 1983 EIS.

in 1988, the City prepared an MSP that proposed expanding their'facilities
within the City boundaries, with the County's approval, this expansion was to
also include unincorporated portions of the county, and use monies from a 5-year
capital improvements program. These monies would be from local sources and would
not be expected to include federal funds. Given the decision to re-evaluate the
No-Federal-Action preferred alternative of the 1983 EIS and the availability of
local funds, several other options of the No-Federal-Action alternative could be
considered. These option alternatives primarily included centralized system
alternatives which involved the concept of spray irrigation of wastewater
effluent or other forms of wastewater disposal and some improvement of existing
wastewater treatment plants, and a decentralized system alternative which
involved some improvements and use of on-lot systems. These option alternatives
are addressed in the present EIS, which is a supplement to the original 1983 EIS.
A Draft EIS supplement (DEISS) was issued by the USEPA on June 29, 1990 and is
hereby being followed by this Final EIS supplement (FEISS).

The EIS supplement addresses direct and indirect impacts of wastewater
management alternatives for the study area for a 20-year planning period (1990
through 2010). The study area boundaries used in the EIS Supplement are those
boundaries defined for eight service areas in the 1988 City MSP. These
boundaries were used because the City is the only entity proposing centralization
of wastewater management facilities.

1.1.2 USEPA NEPA Compliance

The City of Tallahassee presently has not requested any federal funds to
implement the 1988 City MSP, nor does the implementation of the MSP as proposed
otherwise constitute a -major Federal action" under Section 102(2)(C) of the
National Environmental Policy Act (NEPA) of 1969, as amended, and NEPA does not
mandate that an EIS Supplement be prepared. Although there presently are no
federal funds and no major federal action proposed for the alternatives of this
EIS Supplement, the USEPA has prepared this discretionary EIS supplement to
provide guidance to the city of Tallahassee Sewer Division as well as other local
decision-makers for facility expansion planning. Unless the proposed project
a m?^°r	acti°n, the selection of an appropriate alternative for

the City of Tallahassee wastewater management alternative would be a local
decision, since no federal action is currently planned, the USEPA presently does
PJ*Pfr? * R*c°rd of Decision (ROD) for this EIS supplement. If,
however, local decision-makers should ultimately include federal involvement in

1-2

-------
the city MSP at the level of a "major Federal action," the EIS supplement (the
DEI?j vf	FEISS) will serve to meet the requirements of NEPA (and a ROD

would be prepared) unless a significant amount of time has passed before project
implementation and significant changes have occurred in the project as proposed,
in the impacts of the project, and/or- in the project area. After appropriate
examination of such considerations, the need for a supplemental EIS to update the
present EIS Supplement could be determined.

1.1.3	Centralization Versus Decentralization

*	t8fnS Mc?nt"3ized" and "decentralized" are used in the EIS Supplement

for the development of the system alternatives, centralized, as used in the EIS
supplement, refers to a regional system that has a large collection system to
convey sewage from the source to one or two large treatment facilities. These
facilities are generally operated and maintained by a government agency or
authority. Decentralized, as used in the EIS Supplement, refers to a system that
includes a multitude of single-customer, on-lot systems and small
collection/treatment systems (e.g., package plants) servicing a cluster of
customers. The decentralized alternative of the EIS supplement is similar to the
No-Federal-Action alternative of the original 1983 EIS. The centralized
alternatives of the EIS supplement would also be No-Federal-Action alternatives
provided local funds, i.e., no federal funds, were used.

1.1.4	Study Area Definition

Development of alternatives for tfcis EIS Supplement is based on
centralization versus decentralization of wastewater management facilities.
Because the City is the only entity proposing centralization as per their city
MSP, the study area was defined as the service areas delineated in the city msp
which are illustrated in Figure 1-1. (Update: The city sewer services area
depicted in Figure 1-1 has since been updated due to a Leon Countv-Citv of
Tallahassee (1993) "Water Sewer Agreement" dated February 14, 1993. In addition
to general configurational changes to the service area boundary (depicted in the
figure as bold lines), the new sewer services area constitutes an area reduction
in the SE quadrant (north of old Tram Road) as well as a relocation of the
boundary through Lake Jackson instead of around it along its southern (Old Ouincv
Highway) and eastern boundaries.)	1

The City MSP divided the metropolitan Tallahassee area into eight service
areas, while the 1983 EIS utilized only three. A comparison of these service
areas is presented as follows.

1983 EIS

Citv MSP

Northeast

«



Pump Station No. 12 (small portion

northeast of Lake Jackson)

Northeast (except small southwest portion)

Southeast

Buck Lake (except small west portion)
Southeast (outside capital Circle)

southwest







Pump Station No. 12 (except small portion
northeast of Lake Jackson)

Northeast (small southwest portion)

Buck Lake (small west portion)

Southeast (small portion south of Capital
Circle)

Lake Bradford Plant (all)

Riggins Road (except small portion north of

1-10)

spring Hill Road (all)

T. P. Smith Facility (all)

1-3

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r



..J

LAKE JACKSON

' - „

V ^

*-1?

\y

PUMP STATION
NO. 12

. "c. ?o

=5^f ^	SI%'

PEHSJCOIH \STBCFT LAKE

NORTHEAST/



'riggins,

-ROADJ

BRADFORD
ROAD
PLANT

BUCK
LAKE

-A	ALFC

' V	AM

:







¦v^ iiwfi!.







U.S. RTC. 10



I



Aw B



i





"V„-



JAPIU^

'SPRINGHILL
ROADt

TP smiths-
facility

SOUTHEAST





N

I

LEGEND

SEWER SERVICE AREA
7) LAKE
— ROAD

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT

SEWER SERVICE AREAS

BASE MAP SOURCE.

US.&S. TOPOGRAPHIC QUAD SHEET
DAIA SOURCE.

CITY OF TALLAHASSEE

torn

sat

20000

Jans

SCALE IH FEtT

GAMCTT FLElMi OMMNMEHTU. CNONEEK,MC.
HARMSajne. PCIMYLVAMU FEMUARY, l»

FIGURE l-l

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1.2 BACKGROUND AMD ISSUES

1.2.1	The 1983 EIS

During the preparation of the 1983 EIS, seven issues were considered
(U3EPA, 1983):

1.	Potential public health risks associated with land application of
wastewater, including aerosol pathogens and potential groundwater
contamination.

2.	Potential over-estimate of wastewater flow projections.

3.	Potential detrimental impacts to wetlands from development in
northeast Leon county.

4.	Potential incompatibility of the proposed northeast treatment plant
and residential use of the area.

5.	Potential detrimental impacts on wetlands and the dam at Lake
Lafayette from construction, operation, and maintenance of the
proposed northeast plant force main to the Southeast sprayfield.

6.	cost-effectiveness of renovating the Lake Bradford Plant (LBR Plant)
versus closing it.

7.	potential impacts on the habitats of threatened and endangered flora
and fauna by any of the alternatives being considered at that time.

since the preferred alternative of the 1983 EIS was the No-Federal-Action, these
issues were not necessarily resolved by the EIS, but were left for local

consideration•

1.2.2	Thm EIS Supplement Public Scoping Meeting

on April 19, 1988, a Public Scoping Meeting was held in the city to solicit
public input for the scoping process and the identification of issues relevant
to the proposed funding of wastewater treatment facilities. From the notes of
the meeting and the written comments received by usepa, a list of project
concerns was developed. Some of these concerns related to the original 1983 EIS
issues; some were unique to the EIS Supplement situation; and others were only
remotely related to either of the aforementioned.

Based upon the 1983 EIS issues, the concerns raised during the EIS
supplement Public Scoping Meeting, and the availability of information, a list
of issues to be addressed during the preparation of the EIS supplement was
developed. These issues are presented below. Issues 1 through 7 are from the
previous EIS, and issues 8 through 10 are from the EIS supplement scoping

process.

1.	Land Application Impacts

a.	Disease transmittal by spray aerosols and animal vectors.

b.	Groundwater contamination.

c'. Long-range impacts on vegetation.

2.	wastewater Flow and Population Projections
a. New data.

3.	Development Potential in Northeast Leon County
a. incompatible land use.

1-5

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4.	Proposed Northeast Wastewater Treatment Plant
a. Incompatible land use.

5.	Northeast Force Main to Southeast Sprayfield

a.	construction impacts.

b.	Operation and maintenance problems.

6.	Abandonment of the LBR Plant

a.	Reduced environmental impacts.

b.	Economics.

7.	impacts on Vegetation and wildlife

a.	Loss of habitat.

b.	impact on protected species.

8.	Performance of Existing wastewater Treatment Facilities

a.	Failing on-lot/community systems.

b.	odor problems.

9.	Siting of wastewater Treatment Facilities

a.	socioeconomic impacts.

b.	Non-point source impacts.

c.	Accurate mapping.

10. Project Coordination with Local Agencies, organizations, and
Individuals

a.	overlap of similar ongoing or proposed studies.

b.	Public participation.

1.3 PREVIOUS STUDIES

1.3.1 Tallahassee-Leon county. Florida. 201 Facilities Plan (201 Plant

The scope of a step 1-201 Plan is confined to planning for publicly-owned
wastewater collection, treatment, and disposal systems. Other point sources of
pollution, such as privately-owned package treatment plants and industrial
dischargers operating under National Pollutant Discharge Elimination System
(NPDES) permits, are noted only if they might one day become part of the
municipal system. Likewise, nonpoint source pollution has a bearing on the 201
Plan only if storm water entering the sewers must be eliminated or treated and
disposed by the facilities proposed in the plan. The control of the sources of
nonpoint pollution does not fall within the jurisdiction of the 201 Plan, but
rather is the concern of 208 planning. A 208 Plan has been conducted by the
Tallahassee-Leon County Planning Department (TLCPD). Through cooperative
agreements between the County and City, those wastewater management issues which
would be covered by both the 201 and the 208 Plans were identified to ensure a
thorough investigation and avoid duplication.

The draft 201 Plan was approved in April 1977 by the city and County
Cananissioners, and received initial approval from the Florida Department of
Environmental Regulations (FDER) and the USEPA. USEPA subsequently made a
decision to initiate step II Grants for only those facilities which would relieve
existing water quality problems. This decision was made, in part, due to the
opposition of citizens and private organizations to portions of the 201 Plan.
It was further decided that an EIS would be prepared on those portions of the 201
Plan that included anticipated population growth and could possibly result in
significant environmental impacts. All Phase I facilities funded by USEPA, have
been completed and include the following:

•	upgrading of 2.5 mgd southwest Treatment Plant,

•	New southwest Holding Pond and Pumping station,

1-6

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•	New 22.5 mgd Southwest to Southeast Force Main,

•	New 10.0 mgd southeast Holding Pond and Pump Station,

•	Expansion of T. P. Smith Plant (TPS Plant) to 17.5 mgd,

•	Expansion of Southeast Wastewater Effluent sprayfield (SE
Sprayfield) to 18.3 mgd, revised to 22.0 mgd, and rerated to
23.25 mgd,

•	Abandonment of the Dale Mabry Plant (abandoned in 1982),

•	New 17.5 mgd Sludge Handling Facility (completed in 1983), and

•	Additional Interceptors and Pump stations.

Those proposed Phase II portions of the 201 Plan which were addressed in
the 1983 EIS included the following!

•	New 5.0 mgd Northeast wastewater Treatment Plant (NE Plant),

•	New 60,000 Linear-foot Force Main to SE Sprayfield from NE Plant,

•	Expansion of 2,000-acre southwest Wastewater Effluent Sprayfield (SW
Sprayfield),

•	Expansion of TPS Plant beyond 17.5 mgd,

•	Additional Interceptors to Growth Areas, and

•	Abandonment of the LBR Plant.

1.3.2 Final Environmental Impact Statement. Tallahassee-Leon County.
Florida. Wastewater Management <1983 EISl

Four comprehensive alternatives were developed for the Tallahassee-Leon
County area in the 1983 EIS. Each of these alternatives incorporated complete
wastewater management systems for the metropolitan Tallahassee area.

In developing the alternatives, the situations presented below were
considered:

•	The 1983 EIS wastewater flow projection for the planning period
(through the year 2000) was 22.3 million gallons per day (mgd)
without conservation measures. The 201 Plan projected flow for the
year 2000 was 30.4 mgd.

•	The 1983 EIS identified three major wastewater generation areas:
the southwest, the northeast, and the southeast. Alternatives were
developed for serving these three areas.

•	The evaluation of conservation measures for the 1983 EIS study
showed that a flow reduction of 2.4 mgd by the year 2000 is<
feasible. The costs and structural configurations of each
alternative were described with and without conservation.

•	The only wastewater disposal options evaluated in detail were land
application options. Surface water discharges and other options
were eliminated as inappropriate for cost, environmental or
technical reasons.

9 Alternatives that produce sludge beyond the 201 Plan Phase I
capacity of 17.5 mgd were to be disposed by landspreading at the TPS
Plant site or on city-owned land adjacent to the airport.

•	FDER requires secondary treatment prior to application of effluent
to the land. USEPA decisions regarding funding of pre- application
levels of treatment prior to land application were to be determined
on a case-by-case basis.

•	The Dale Mabry Plant was to be closed.

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The wastewater management alternatives developed for the 1983 EIS were

described as follows:

, ^1-ternative lAt This alternative included construction of a new NE
plant to provide service in the northeastern growth areas of the
County and the developed portions of the northeast presently served
by on-lot and small community systems. Effluent from the plant
would be disposed by rapid infiltration at a northeast disposal
site. The TPS Plant/Southwest Facility would be expanded beyond
17.5 mgd to service the southwest and southeast service Areas. The
SE sprayfield would also be expanded to receive additional effluent
from the TPS Plant.

•	jiltarnative IB: This alternative was the same as 1A except that the
treated effluent from the NE Plant would be conveyed to the expanded
SE sprayfield for disposal.

a Alternative 2: For this alternative, existing facilities would
serve as a regional treatment system. The structural configuration
depended upon whether or not conservation measures were implemented.
Without conservation measures, the most cost-effective system is
continued operation of the LBR Plant at 4.5 mgd and expansion of the
TPS Plant by 0.3 mgd. With conservation measures, an expanded TPS
plant would serve the entire sewered area as a regional treatment
plant with a 19.9 mgd capacity. This alternative included extensive
construction of interceptors to serve the northeastern and eastern
portions of the 201 Plan planning area. Effluent disposal would be
carried out as in Alternative 1. (Motet The USEPA understands from
the City of Tallahassee that the City, although conceptually not
opposed to water conservation, believes that water conservation
would be very difficult to implement in Tallahassee due to abundant
local water supplies; also, the city considers that the above-
referenced proposed 19.9 mgd capacity treatment plant would be an
under-capacity system for 1993 conditions).

•	alternative 3: under this alternative, a new Southeast Wastewater
Treatment Plant (SE Plant) would be constructed to supplement the
treatment capacity of the expanded TPS Plant. The SE Plant would
serve growth areas in the southeast and northeast. The TPS Plant
would serve projected growth areas in the southwest and the existing
service area. For both plants, effluent would be disposed at the SE
Sprayfield.

•	Alternative 4: This, the Mo-Federal-Action Alternative, was
described by considering the present situation in the Tallahassee-
Leon County area and projecting future conditions with no changes in
public policy or private practices. Expansion of the wastewater
system would continue only until the limits of 201 Plan Phase I
expansion were reached. New growth in wastewater generation would
be handled by on-lot and small community systems. Population
infilling would take place in the City's service area and some
additional collectors would be necessary.

Alternative 4, "No-Federal-Action," was chosen as the preferred alterna-
tive in the 1983 EIS based upon low population growth projections and the
anticipated ability of on-lot and small community wastewater treatment facilities
to serve the existing and projected population.

1.3.3 Citv of Tallahassee Master Sewer Plan. 1987-2010 (Citv MSP)

The four system alternatives presented in the City MSP, prepared by William
M. Bishop Consulting Engineers, Inc. (May 1988), were developed from 17 sub-

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alternatives, moat of which involved variations in the wastewater conveyance
system.

in developing the alternatives, the following situations were considered
by the City:

•	The expansion of the TPS Plant by 7.5 mgd, to 25.0 mgd would serve
the city until 1997. After the existing TPS Plant is re-rated for
an additional 2.5 mgd, the 7.5 mgd expansion will serve the City
until the year 2000. An additional 4.67 mgd will be needed to carry
the City to 2010. Estimates for future capacity were based on a per
capita flow of 175 gallons per day.

•	The most significant demand on future wastewater management
facilities would come from the northwest and northeast areas of
Tallahassee, followed by southeast and southwest.

•	Land application by spray irrigation was the most feasible method of
effluent disposal.

•	Land spreading was the most feasible method of sludge disposal.

•	The city would continue to operate two treatment facilities, the TPS
Plant and the LBR Plant, with the Municipal Airport Plant (MAP) to
be closed with its flow diverted to the TPS Plant.

•	The conveyance system on the east side and in the city was
overloaded and needed immediate attention.

•	The TPS Plant and LBR Plant were experiencing peak flow problems.

The four system alternatives developed in the city MSP are summarized as
follows <

•	Alternative 1: This alternative involved treating all of the
wastewater at either the LBR Plant or the TPS Plant. Effluent from
both treatment plants would be pumped to the SE sprayfield for
disposal.

Wastewater from the Northeast and southeast service Areas would be
collected and then transported to the TPS Plant through a new force
main that would follow centerville Road and Capital Circle. A new
pump station would be constructed near the intersection of Nahnish
Way and Bragg Drive to eliminate overflows in the trunkline and
Springhill Road pump station.

•	Alternative 2i This alternative involved construction of a new NE
Plant adjacent to interstate 10 and the phasing out of the LBR
Plant. Effluent from the TPS Plant would be pumped to the SE
Sprayfield for disposal. Effluent from the NE Plant would be pumped
through a new force main to the SE Sprayfield.

Wastewater from the NE service Area would be pumped to the treatment
plant through force mains serving the areas north, west, and south
of the NE Plant. The southeast service Area would be served through
the existing transmission system. A new pump station would be
constructed near the intersection of Wahnish Way and Bragg Drive to
eliminate overflows in the trunkline and Springhill Road pump
station.

•	Alternative 3: This alternative involved construction of a new SE
Plant in the vicinity of Tram Road and Capital Circle and phasing

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out of the LBR Plant. Effluent from the TPS Plant would be pumped
to the SE spr&yfield for disposal. The effluent from the SB Plant
could initially be pumped directly into the existing effluent force
main from the TPS Plant to the SE Sprayfield.

Wastewater from the Northeast and southeast service Areas would be
collected and then transported to the SE Plant through a new force
main that would follow Centerville Road and Capital Circle. A new
pump station would be constructed near the intersection of Wahnish
Way and Bragg Drive to eliminate overflows in the trunkline and
Springhill Road pump station.

•	Alternative 4: This alternative involved treating all of the
wastewater at either the LBR Plant or the TPS Plant. Effluent from
both treatment plants would be pumped to the SE Sprayfield for
disposal.

Wastewater from the Northeast and Southeast Service Areas would be
collected and then transported to the TPS Plant through a new force
main that would follow centerville Road and Capital Circle. A force
main would be constructed from Riggins Road pump station to Capital
Circle which would divert flow from the trunkline near Wahnish Way
and Bragg Drive.

Originally, Alternative 1 of the MSP was selected as the preferred
alternative. This was changed later due to public opposition to the construction
of a pump station at Wahnish Way and Bragg Drive. Alternative 4 of the MSP was
then developed and selected as the preferred alternative, providing for a
Centerville Road/Capital Circle force main to divert flow from the wahnish Way
and Bragg Drive area.

1.3.4 Preliminary Leon County Master Water and Sewer Service Plan <19881
icounty MWfcSSPi

Leon county considered two basic premises in developing wastewater
management alternatives for the unincorporated areas of the Countyt (1) the
County remaining in a non-provider role, and (2) the County changing to a
provider role. The County considered the following goals to guide the
development of alternatives under both premises:

•	Manage the impact of growth.

•	increase ability to respond to oitizens' needs.

•	Develop tools for managing services.

•	Provide sewer services at lowest possible costs.

The eleven alternatives, six provider (one is the water only), and five non-
provider, presented in the Leon County MM&SSP, are summarized as follows <

•	Alternative l. Non-Provider: This is the "status quo" alternative
where the City would remain "the sole local governmental entity to
authorize the planning, .construction, and operation of sewage
disposal utility services in the unincorporated area of...Leon
county." This would result in the expansion of the various service
roles of others and the continued decline of the present role of the
county in this respect.

•	Alternative 2. Non-Provider: This alternative is similar to
Alternative 1 above except that the administration of sewer services
by the county would be revised. The purpose of updating these
documents would be to remove several noted deficiencies that exist
in the current authorized service area and/or zone application fees,
to establish a "grace period" for remaining unauthorized systems to

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apply for service area status with the County, to re-define the
County's relationship with the City in granting extensions to the
City's water and sewer zone, and to implement a program for
monitoring water and sewer systems.

Alternative 3. Non-Provider; in this alternative, the County would
cease to process future water and sewer service area applications
altogether. In place of this task, the County would negotiate and
establish assigned service areas to the existing water and sewer
services providers. Under this alternative, service area boundaries
could be derived using any number of criteria, and then assigned
between those entities best suited to provide these services. This
alternative is basically envisioned as a "one-time" assignment and
all presently unauthorized service areas would remain within the
unincorporated area of the County.

Alternative 4. Non-Provider: This alternative follows the same
basic logic as Alternative 3, with the exception that all presently
unauthorized service areas of the county would be negotiated for
assignment to the city in its entirety. in fact, the City has
recently offered its proposal to the County to accomplish this very
task. This proposal basically involves the city's offer to share
service revenues with the County over a 30-year period of time in
exchange for the exclusive granting of water and sewer service
privileges within all presently unauthorized water and sewer
territory.

Alternative 5. Non-Provider: This alternative involves the
establishment of negotiated service area boundaries between
providers, much in the same fashion that is presented in Alternative
3, but only enacted to moderate limits, under this alternative, the
County would retain its exclusive authority in the outermost regions
of the County under either the existing or revised criteria as
discussed in both Alternatives 1 and 2, and make assignments to
providers only in those areas where immediate attention will be
necessary.

Alternative 6. Provideri This alternative involves the county
ceasing to grant water and sewer service to others altogether, thus
allowing the County to pursue the provision of water and sewer
services in unserviced areas from County-owned/operated systems.

Alternative 7. provider /Water Only) i This alternative assumes that
the county would elect to enter as a provider of water services
only. The basic workings of this alternative would not differ
considerably from that discussed in Alternative 6 above, but would
apply to the scope of water services provision only.

Alternative 8. Provider: This alternative is similar to Alternative
6, but rather involves the County entering as only a minor provider
of water and sewer services while continuing to allow the further
franchising of service areas by other providers. This approach
would basically encompass the assumption of operation and
maintenance responsibility over small isolated water or sewer
systems as an alternative to having such responsibilities being
accepted by others.

Alternative 9. provideri This alternative follows the same basic
approach as does Alternative 8, with the exception that systems
assumed for county operation and control would be required to fit a
large central system concept. This would be the situation if the
county desired constructing its own sewage treatment plant, and then

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soliciting system connections in direct competition with the city
and/or Talquin Electric Cooperative, Inc. (TECO).

•	Alternative 10. Provider: This alternative would basically consist
of the County making contractual arrangements with a qualified
outside entity to design, construct, operate, and maintain a major
new sewage treatment facility.

•	Alternative 11. Provider: Under the pursuit of this alternative,
the County would seek to assume control of existing water systems,
sewer systems, or both. This alternative basically consists of the
County attempting to acquire, either by purchase or by gift,
existing systems inclusive of existing user populations. It offers
the County its clearest means of entering the picture as a provider
of water and sewer services in service areas of known quantity and
demonstrated potential.

The USEPA understands from Leon county (personal communication, 1991) that
the Leon county Board of Commissioners has not approved the 1988 preliminary Leon
County Master Water and Sewer service Plan.

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CHAPTER 2

ALTERNATIVES
DEVELOPMENT

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CHAPTER 2 ALTERNATIVES DEVELOPMENT

2.1 EXISTING WASTEWATER MANAGEMENT
2.1.1 Cltv of Tallahassee

The City Master Sawar Plan (MSP:1988) prepared by Bishop Engineers
described the city's existing service areas, interceptor lines, pumping stations,
treatment plants, effluent disposal systems, and sludge handling facilities.
Summary descriptions, current through September, 1989, follow.

2.1.1.1	Interceptors

The city's sewer system contains about 100 miles of pipeline with
diameters ranging from 12 inches to 42 inches. The alignment of these
interceptors is illustrated in Figure 2-1.

2.1.1.2	Pumping Stations

The city operates approximately seventy-five (75) pumping stations
as part of the wastewater collection system. Of these, seven are considered part
of the interceptor system and are located on Figure 2-1. At least two of the
pumping stations are known to be overloaded during periods of extreme wet
weather. These are Pump station No. 12 and Springhill Road Pump station. The
City has already initiated construction to expand Pump station No. 12 and divert
flow away from springhill Road Pump station.

2.1.1.3	Treatment Facilities

The city operates three wastewater treatment facilities. They are:
(1) T. P. Smith Facility (TPS Plant and SW Plant), (2) Lake Bradford Road (LBR)
Plant, and (3) Municipal Airport Wastewater Treatment Plant (MAP). The locations
of these facilities are shown on Figure 2-1. Table 2-1 identifies the treatment
type for each facility.

2.1.1.4	Effluent Disposal Facilities

Table 2-1 also identifies the disposal technique used for each of the
treatment facilities, with the exception of the small MAP Plant, all of the
effluent from the city-owned wastewater treatment plants is disposed by spray
irrigation. The spray irrigation facility (SE Sprayfield) consists of a 1,900-
acre sprayfield with a 22.0 mgd capacity (Update: rerated to 23.25 mgd on
9/8/89) constructed approximately eight miles east of the T. P. Smith Facility.
The facility components include a 52 million gallon holding pond and 22.0 mgd
iupdate: rerated to 23.25 mgd on 9/8/89) pumping station at the T. P. Smith
Facility, 40,000 feet of 36-inch force main, and a 48-million gallon holding pond
and a 22.0 mgd fupdate: rerated to 23.25 mgd on 9/8/89) pumping station at the
sprayfield. The sprayfield consists of thirteen center pivot irrigators. There
is also a 102 acre, 1.25 mgd agricultural sprayfield adjacent to the TPS Plant
referred to as the southwest Sprayfield (SW Sprayfield). The locations of the
disposal facilities are shown in Figure 2-1 (Update: The City sewer services area
depicted in Figure 1-1 has since been updated due to a Leon County-City of
Tallahassee (1993) "Water Sewer Agreement" dated February 14, 1993. In addition
to general configurational changes to the service area boundary (depicted in the
figure as bold lines), the new sewer services area constitutes an area reduction
in the SE quadrant (north of old Tram Road) as well as a relocation of the
boundary through Lake Jackson instead of around it along its southern (Old Quincy
Highway) and eastern boundaries.

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SEWER SERVICE AREA
EXISTING SEWER
~ EXISTING PUMPING STATION
O EXISTING WASTEWATER TREATMENT PLANT
\///\ EXISTING SPRAYFIELO

ROAO

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT

OUSTING WAStEHATOt
MANAGEMENT FACILITIES

Gannett flemng envromjcntal engȣEAS,ic.

HARMSSUftC. PEfMSriVANU FEBRUARY, iMl

FIGURE 2-1

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TABLE 2-1

EXISTING WASTEWATER TREATMENT FACILITIES

P1«n» M.m.

Deaign Flow

Waatewatar

Traataent Tvp» and Dl»poaal

Sludge

1. T. P. Smith Facility
SW Plant

2.5*1'	High-rata Trickling Filtar

Rotating Biological Contractor!
Spray Irrigation

Anaarobic Oigaation
Land Spreading

TPS Plant

17.5

(1)

Activated Sludga
Spray Irrigation

Aarobic Digaation
Thickening and Dewatering
Land Spreading

2. LBR Plant

4.5

Trickling Filter
Activated Sludge
Spray Irrigation

Anaarobic Digaation
Land Spreading

3. MAP Plant

O.OC

Trickling Filter
Evaporation/Percolation Pond

Anaerobic Digaation
Land Spreading

(1|Updata» TPS plant (trickling filtar and activated aludge ceaponente) wae rerated froa 17.5 agd to 20.0 agd
(2.5 agd + 17.5 ngd) on 9/t/89. Spray irrigation capacity at the SB Sprayfield wai rerated from 22.0 agd
to 23.25 ngd on 9/6/89.

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The farm management facility at the SE spray fie Id consists of five silos, loading
and unloading equipment, scales, a maintenance equipment shed, and an operators'
building. This facility is used to harvest and store the crops, including corn,
soybeans, canola, and rye/rye grass that are grown on the sprayfield. All
agricultural crops produced from the effluent sprayfields are not to be used for
direct human consumption, consistent with state of Florida regulations.
Accordingly, irrigated crops produced by the City are to only be used as animal
feed and/or processed food for humans (e.g., canola oil; soybean oil) to the
extent consistent with chapter 17-610 F.A.C.

A pumping station and force main are also in place to allow the
effluent from the LBR Plant to be pumped to the holding pond at the T. P. Smith
Facility. The SH Sprayfield immediately east of the TPS Plant utilizes fixed
head spray guns and accepts approximately 1.25 mgd. Coastal Bermuda grass is
grown on this site and is harvested as hay for animal feed.

2.1.1.5 sludge Disposal

All of the sludge from the City-owned wastewater treatment facilities
is disposed of by some form of land application. The majority of sludge is
landspread in the liquid form on land the city owns around the municipal airport.
Approximately 456 dry tons/year, or 0.31 dry tons/mgd of plant flow, of
anaerobically digested sludge is hauled from the LBR Plant. The TPS Plant is
currently generating 1,909 dry tons/year, or 0.42 dry tons/mgd of plant flow, of
aerobically and anaerobically digested sludge.

The T. P. smith Facility has a dissolved air flotation unit which is
used to thicken aerobic digested sludge. The thickened sludge is usually hauled
directly to the airport for landspreading. However, the thickened sludge can
also be sent to one of five belt presses at the site for dewatering. Sludge that
has been dewatered is also landspread at the airport.

The actual acreage available for sludge disposal by landspreading
consists of 490 acres at the municipal airport, 102 acres at the sprayfield next
to the T. P. Smith Facility, 12 acres of area around the T. P. Smith Facility
grounds, and 202 acres of City-owned pine forest west of the municipal airport,
for a total of 806 acres.

It is the USEPA'S understanding from the FDER that the City sludge
field near the municipal airport is in compliance with the State's nitrogen
application criterion (500 pounds of nitrogen per acre per year: 500
lbs/N/ac/yr). However, the sludge field is apparently at capacity based on FDER
nitrogen level determinations. Continued use of the sludge field, particularly
if greater nitrogen application is planned in association with selection of a
wastewater disposal alternative, should be evaluated in light of the fact that
the field is at capacity. The sludge field must remain in compliance with the
State of Florida requirements.

2.1.2 Talauin Electric Cooperative, inc. 

TECO owns and operates six community wastewater treatment facilities in
Leon and Wakulla counties providing wastewater services in five geographic
locations. Three of these facilities serve communities located in Leon County.

The Lakewood Community wastewater Treatment Facility (Lakewood Facility)
located in western Leon County is a two-plant complex with a total of 0.3 mgd of
wastewater treatment capacity. At present, the Lakewood Facility serves
approximately 450 accounts, primarily residential, but including a limited amount
of commercial and industrial development.

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The Meadows Wastewater Facility (MeadowB Facility) is located in east Leon
County with a total treatment capacity of 0.07 mgd. This facility serves 215
residential accounts.

TECO'b newest, and soon to be largest wastewater treatment facility, is
located in northern Leon County at Killearn Lakes. At present, the Killearn
Lakes plant is a 0.10 mgd plant, but engineering design is underway to expand
thiB facility by 0.25 mgd for a total capacity of 0.35 mgd. This plant is
serving approximately 100 residential units and a small number of commercial
operations. The location of the plant is shown in Figure 2-1.

2.1.3	Leon County

The County does not currently own or operate any wastewater management
facilities and has stated in the past that it does not desire, except as a last
resort, to become a provider of these services. The County's present role in the
area of sewer services is to authorize and monitor sewer system franchises to
other providers in unincorporated areas.

The current extent of sewer system franchises within the County involves
those areas authorized to the city, TECO, and other small private entities. The
Preliminary Leon County Master Hater and sewer Service Plan (County MW&SSP)
identified nine community wastewater systems in addition to TECO's facilities.
Four of these are authorized and five are unauthorized, according to FDER and
Leon County Public Health Department (LCPH) records. The County's position
concerning these additional private providers is that they are important for
providing service to remote, rural areas of the county and will be considered on
an individual basis for future small developments. However, they are not capable
of providing the level of sewer services addressed in this EXS supplement and
subsequently are not considered as potential providers in this report.

2.1.4	On-lot Wastewater Management

on-lot treatment and disposal systems are in common use in the Tallahassee-
Leon county area. The systems most frequently used are septic tanks with either
subsurface or mound drainfields. Only a few areas within the City limits utilize
on-lot systems and those areas are progressively being added to the city's sewer
system. The area between the City limits and the outer limits of the wastewater
service areas include small (five to ten lots) and larger subdivisions that are
utilizing on-lot systems. This area and the remainder of the County also include
isolated small clusters and single resident on-lot systems.

Septic tank drainfield failures have been investigated and documented for
the Killearn Lakes Subdivision area. Generally it was found that the combination
of poor soil conditions (slowly permeable soils), water table elevations
(artificially perched on confining layers), storm water runoff ("sheet flow"
drainage system), and the density of development (small lots of 1/4 acre) were
the major factors involved. The study prepared for this area by the Leon County
Public Health Unit (LCPHU) recommended installing a central sewage system and an
adequate stormwater collection system. It also advised that restrictions should
be made for issuing on-lot sewage disposal system permits.

Currently the County is compiling a computer-based inventory of septic tank
drainfield failures. However, this inventory only includes new failures and
therefore cannot provide a historical record to quantify the problem caused by
failures or to identify all specific problem areas.

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2.2 BACKGROUND INFORMATION

2.2.1 Regulatory Criteria

2.2.1.1	State Regulations for Effluent Disposal

FDER regulates effluent disposal pursuant to the Florida
Administrative Code (F.A.C.), Chapter 17-6 Wastewater Facilities and Chapter 17-
610 Reuse of Reclaimed Water and Land Application. Specific regulations or
environmental conditions that have severely restricted or eliminated the use of
particular disposal techniques for the study area include the following:

•	Surface water discharge - FDER has classified the Ochlochonee
and St. Marks Rivers as "Outstanding Florida Water" thereby
imposing a zero effluent limitation.

•	Deep well injection - FDER requires (1) the identification of
a saline formation that has a dissolved solids concentration
of 10,000 mg/1 (preferably two confining geological layers
should be present between this saline zone and a freshwater
zone), and (2) the availability of reasonable transmissivities
(rate of flow into aquifer). Specifically, Chapter 17-28 of
the fac would apply to deep well injection proposals relative
to suitable injection zones and well construction, usda Soil
Conservation Service (SCS) has stated that there are few or no
confining layers separating the freshwater and saline layers
of the Floridan Aquifer, which is the main water supply source
for the study area. However, there is a possibility of an
anhydride layer below the limestone formation of the Floridan
Aquifer that might serve as a confining layer, but excessive
depths (3,500 feet or greater, i.e., below the Floridan
Aquifer) and probable low permeabilities limit the potential
for deep well injection. A test well drilled in 1977 in
Gainesville, Florida, showed little potential for water
disposal and the project was terminated. Also, the USGS
(1979), in cooperation with the FDER, has stated that Area II,
which includes Leon county, "...is the least suitable in
Florida for waste injection."

2.2.1.2	Federal Regulations for Effluent Disposal

and Sludge Disposal

The 40 Code of Federal Regulations (CFR) section 122.1(b)(1) states
that a National Pollutant Discharge Elimination System (NPDES) permit is required
for the discharge of pollutants from "any 'point source' into 'waters of the
united States'" (point source is defined in 40 CFR Part 122.2 as "any
discernable, confined, and discrete conveyance, including but not limited to any
pipe, ditch, channel, tunnel, conduit, well, discrete fissure, container, rolling
stock, concentrated animal feeding operation, landfill leachate collection
system, vessel, or other floating craft from which pollutants are or may be
discharged) into waters of the United states." Part 122.2 also states that
"[t]his term does not include return flows from irrigated agriculture or
agricultural storm water runoff." Failure to obtain proper authorization for
discharges under the NPDES Program may result in the assessment of
administrative, civil, and/or criminal penalties under Section 309 of the Clean
Water Act (CWA).

Pursuant to the existing NPDES permitting program (40 CFR Parts 122
and 124) and to the "NPDES Permit Application Regulations for Storm Water
Discharges" (55 FR 47990 dated November 16, 1990), an NPDES permit is required
for point source storm water discharges to waters of the United states from the
facility actually treating domestic wastewater. This provision applies to

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domestic wastewater treatment facilities that have design flows of at least
1.0 mgd. The NPDES storm water regulations of November 16, 1990, also require
that point source storm water discharges to waters of the United states from all
construction activities (including the initial clearing, until revegetatod, of
spray irrigation sites) disturbing a total of five or more acres must be
permitted under the NPDES program. The permit application deadline for these
discharges is 90 days prior to commencement of construction. construction
activities needing NPDES permit coverage can be made through a general permit
recently issued by EPA/Region IV.

storm water point source discharges to waters of the united States
from the operation (spray irrigation) of non-agricultural/non-silvicultural land
application sites (such as golf courses, rights-of-way, and landscape areas)
receiving domestic wastewater treated to the quality required by Chapter 17-610
F.A.c. for the land application of reclaimed water are not required to be covered
by NPDES permits, unless the USEPA specifically requires a facility to submit an
application on a case-by-case basis. Therefore, no NPDES permit is needed for
the operation of such land application sites for the city's proposed project (if
storm water point source discharges exist to waters of the United States for such
sites) unless specifically requested by the USEPA. However, dedicated discharges
of reclaimed water, without land application, are required to be covered by NPDES
permits. It may also be noted that storm water discharges from the land
application of wastewater effluent on agricultural and silvicultural sites are
exempt from the NPDES permitting program if the sites are consistent with 40 cfr
Part 122.3(e), so that the operation of such sites for the City's proposed
project would not require an NPDES permit if consistent with 40 CFR 122.3(e).

For the operation (spray irrigation) of land application sites that
are not exempt from NPDES permitting and that would only have infrequent point
source discharges during bypass or upset conditions and during rainfall
conditions that exceed the capacity of systems designed to contain storm water
up to a 10 year-24 hour storm event, a "No-Discharge" NPDES permit*would be
appropriate. Application for such discharges is required under the NPDES
permitting program. If a site is determined to be discharging without NPDES
coverage, the owner/operator would be subject to administrative, civil, and/or
criminal penalties under Section 309 of the Clean Hater Act. Also, for land
application sites not having point source discharges (zero discharge sites), no
NPDES permit would be required for operation, in any case, however, a -sludge
Only" permit (Bee below) would be required for the disposal/reuse of generated
sludge, in addition, the above storm water NPDES regulations (55 FR 47990 dated
November 16, 1990) would apply during the construction of either case as well as
for the treatment plants actually treating the effluent for spray application as
described previously.

included in the proposed spray irrigation of wastewater effluent in
the preferred Alternative 1 is the generation of and land application of
wastewater sludge. section 405(d) of the Clean Water Act requires that the
disposal or reuse of sewage sludge be regulated. This regulatory activity is to
be accomplished through the utilization of permits based upon technical federal
regulatory standards. The USEPA established federal sludge disposal/reuse
standards which were promulgated in the Federal Register at 40 CFR 503 on
February 19 1993. In general, these standards must be complied with by all
treatment works treating domestic sewage by February 19, 1994. Violation of
these standards would be a violation of the Clean Water Act. It is anticipated
that current and proposed sludge disposal/reuse activities would be regulated
through an NPDES permit, where applicable, or through issuance of a "Sludge-Only"
Permit. This federal permitting activity would be issued by the USEPA/Region iv
until program authorization is given to the State of Florida. Therefore, the
newly promulgated federal regulations are in addition to the state of Florida
sludge disposal/reuse regulations.

2-7

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An administrative penalty may be assessed by the Administrator of the
USEPA (the Administrator) for a violation of Section 301, 302, 306, 307, 308,
318, or 405 of the CWA. Administrative penalties for Class I violations are not
to exceed $10,000 per violation, with the maximum amount of any Class I penalty
assessed not to exceed $25,000. Penalties for Class II violations are not to
exceed $10,000 per day for each day during which the violation continues, with
the maximum amount of any Class II penalty not to exceed $125,000.

The Administrator is authorized by the CWA to commence a civil action
for appropriate relief, including a permanent or temporary injunction, for any
violation for which he is authorized to issue a compliance order under subsection
(a) of Section 309 of the CWA.

The CWA provides that any person who negligently violates Sections
301, 302, 306, 307, 308, 318, or 405 of the CWA is subject to criminal penalties
of $2,500 to $25,000 per day of violation, or imprisonment of not more than 1
year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than
$50,000 per day of violation, or imprisonment of not more than 2 years, or both.
Any person who knowingly violates such sections is subject to criminal penalties
of $5,000 to $50,000 per day of violation, or imprisonment of not more than 3
years, or both. In the case of a second or subsequent conviction for a knowing
violation, a person shall be subject to criminal penalties of not more than
$100,000 per day of violation, or imprisonment of not more than 6 years, or both.
Any person who knowingly violates Sections 301, 302, 306, 307, 308, 318, or 405
of the CWA, and who knows at that time that he thereby places another person in
imminent danger of death or serious bodily injury, shall, upon conviction, be
subject to a fine of not more than $250,000 or imprisonment of not more than 15
years, or both. In the case of a second or subsequent conviction for a known
endangerment violation, a person shall be subject to a fine of not more than
$500,000 or imprisonment of not more than 30 years, or both. An organization,
as defined in Section 309(c)(B)(iii) of the CWA, shall, upon conviction of
violating the imminent danger provision, be subject to a fine of not more than
$1,000,000 and can be fined up to $2,000,000 for second or subsequent
convictions.

The permitting guidance outlined above in this section (and in this
document in general) is very general and is not intended to be used to make final
decisions on the applicability of the npdes or sludge regulations. site-specific
conditions are always important factors in making these determinations.
Additional information on the USEPA NPDES permitting program can be obtained
from:

Mr. Roosevelt Childress, Chief
storm Water and Municipal Unit
Water Permits and Enforcement Branch
Water Management Division

USEPA, Region IV
345 Courtland Street, N.E.

Atlanta, OA 30365
(404) 347-3012; Extension 2980

2.2.1.3 Federal Regulations for Activities Affecting wetlands

Any unavoidable wetland losses due to construction of an alternative
land application project (e.g., land clearing and grubbing; access road
development; facility construction) would be subject to Section 404 (Clean Water
Act: CWA), wetland permit determinations by the U.S. Army Corps of Engineers
(COE), i.e., the federal 404 permitting agency, as well as the state of Florida
and Leon County, as appropriate. Direct loss of wetlands through dredge-and-fill
activities is generally not anticipated for the actual spray irrigation fields,
since hydric (wetland) soils are not suitable/desirable for spray irrigation.

2-8

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The permitting information outlined above in this section (and in
this document in general) is very general and is not intended to be used to make
final decisions on the applicability of Section 404 of the CWA. Site-specific
conditions are always important factors in making these determinations.
Additional information on 404 permits may be obtained from the Jacksonville,
Florida District COE, and from the USEPA, which reviews individual 404 and some
nationwide permit applications for the COE:

Mr. Tom Welborn, Chief
wetlands Regulatory Section
Wetlands, oceans and Watersheds Branch
water Management Division

USEPA, Region IV
345 courtland street, N.E.

Atlanta, GA 30365
(404) 347-4015

2.2.1.4 sewer Expansion

County Ordinance 80-29 regulates sewer expansion in unincorporated
portions of the County. This ordinance includes provisions for an application
procedure that is to be used in securing a franchise for providing water or sewer
service by private providers, or by the City, in the event that the area to be
serviced is not contiguous to the City's existing service zones.

The city/county Water and Sewer Agreement regulates sewer expansion
in unincorporated portions of the county by providing a stream-lined application
procedure for use by the city in performing contiguous area expansions of its
designated water and sewer service zones.

As stated in the county KW6SSP, the County has attempted to use these
regulatory documents to bring all water and sewer systems in unincorporated areas
under its authority. Such efforts have met with limited success in that there
are still a number of existing water and sewer systems in the county which have
failed to come into compliance with ordinance 80-29.

The USEPA understands from the City that the County'Commissioners
of Leon County have unanimously denied (1991) issuance of a Leon county sewer
franchise which the county maintains is needed for the expansion of the existing
SE Sprayfield. As a consequence, the City's proposed expansion to the Eastern
Expansion area is presently denied by Leon county.

2.2.2 Population Projections

Population estimates by traffic zone (May, 1988) were obtained from the
Tallahassee-Leon County Planning Department (TLCPD). The estimates used in this
Els supplement are for the medium growth scenario and include the planning years
1990, 2000, and 2010. Estimates of the population projections for the EIS
Supplement's service areas were determined by overlaying the service area
boundary map and the traffic zone map. The percentage of each traffic zone lying
within the service area boundaries was determined and multiplied by the
corresponding population count for each traffic zone.

Based on the traffic zone population projections, the pattern of population
growth shows growth areas clustered in the portion of the County north of the
city and not evenly dispersed throughout the County. Ownership of undeveloped
land surrounding the city could be a limiting factor in the future growth of the
area, particularly for those areas owned by the usda Forest service 
-------
refers to those residents or equivalent units to be serviced by centralized
wastewater treatment and disposal facilities. The unsewered population refers
to those residents or equivalent units to be serviced by on-lot and/or area
facilities. The percentage of the total population that would be sewered in the
future was determined by analyzing the characteristics of each traffic zone in
the service area and using the percentage served values for each service area
provided in the city MSP.

Parts of the traffic zones north of Bannerman and Bradfordville Roads of
the Northeast service area are not included in the population projections.
TECO's Killearn Lakes facility currently serves a large portion of this area.
In addition, traffic zones south and east of Capital Circle and Old St. Augustine
Road of the Southeast service area are assumed to remain unsewered with the
exception of a small portion of traffic zone 358 which is currently part of the
city's service area. The preliminary 1988 Leon County MWASSP has identified
these zones as areas with "surplus septic acreage" based on proposed development
and soil characteristics.

More recent population information also exists. According to the
Tallahassee-Leon County Planning Department (1992) statistics dated February 14,
1992, the 1990 census population of Leon County including the city of Tallahassee
and university students is 192,493 and a population projection for the year 2010
of 261,600 (35% increase since 1990). According to the Tallahassee Chamber of
Commerce, the 1990 population of the City of Tallahassee is 124,733 (presumably
also for 1990 and including university students).

2.2.3 Flow Projection Analysis

Monthly average wastewater flows at the TPS/sw Plants and the LBR Plant
were obtained from the City for the years 1983 through July, 1988. These flow
values were analyzed to determine a base flow estimate for each service area.
The peak monthly average flow on record for the study area was found to be 21.61
mgd for the month of March 1988. This value was, therefore, selected to be the
base flow estimate.

Wastewater flow increases for the future were based on the medium
population projections presented in the previous section' and a per capita flow
rate for future growth of 140 gallons per capita per day (gpcd). I Update: It
is the USEPA's understanding from the. City of Tallahassee that 160 gpcpd is the
peak flow and 140 gpcpd is the average daily flow, the latter being used in the
EIS Supplement). This estimated flow rate includes commercial and industrial
flows as a part of the residential flow. Table 2-3 lists the wastewater flow
projections for each service area.

Both the base flow estimate of 21.61 mgd and the per capita flow rate for
future growth of 140 gpcd were agreed upon for use in this study by USEPA, the
City, and FDER.

The alternative development process of the EIS supplement requires
distinguishing between expanding service to accommodate infilling within the
city's existing service area and expanding service to handle additional areas
outside of the existing service area boundaries. Also, the current and proposed
service provided by TECO in the study area must be accounted for in the
alternatives. Table 2-4 summarizes the flow estimates for the various
categories. These estimates were determined by overlaying the traffic zone map
with the service area map, and the Leon County Planning Department sewer service
franchise map. in cases where existing flow values were available, but the
numbers of customers served were not, the flow rate of 140 gpcd was used to
calculate a population estimate.

2-10

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TABLE 2-2

POPULATION PROJECTIONS BY SERVICE AREA

Centraliaed sawarad Population	Pnaawarad Population***' ^)		Total Population

Sarvica Area

1967

1990

2000

2010

lM

1990

2066

2010

1987

1990

"4656

2010

Lake Bradford
Road

36,616

36,514

36,452

36,443

0

0

0

0

36,618

36,514

36,452

36,443

P.S. No. 12

31,352

37,211

48,497

55,271

13,437

9,303

5,389

2,909

44,789

46,514

53,886

58,180

Riggina Road

17,795

20,083

23,061

29,596

0

0

0

0

17,795

20,083

23,061

29,596

Northaaat

6,145

B,070

12,396

16,938

6,964

7,808

8,469

8,388

13,109

15,878

20,865

29,326

Springhill Rd

24,293

25,668

28,213

30,427

0

0

0

0

24,293

25,668

28,213

30,427

T. p. Smith

499

1,039

1,537

1,948

1,495

1,038

659

487

1,994

2,077

2,196

2,435

Southeast

565

1,580

2,234

4,777

7,211

7,489

12,898

17,434

7,776

9,069

15,132

22,211

Buck Lake

442

1.010

2.920

9.199

3.975

4.039

4.380

2.300

4.417

5,049

7.300

11.499

Totals

117,709

131,175

155,310

184,599

33,082

29,677

31,795

31,518

150,791

160,852

187,105

216,117

(1) Includaa populations using on-lot and small community waatawatar traatnant and diapoaal facilitiaa.
Baaad on aarvica parcantagaa provided in tha City HSVf Tabla 4.1-B.

2-11

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TABLE 2-3

FLOW PROJECTIONS FOR CENTRALIZED SERVICE

Sarvica Araa

1990

2000

2010

Laka Bradford
Road

-104

-166

-175

P.S. No. 12

5,859

17,145

23,919

Riggina Road

2,288

5,266

11,801

Northaaat

1,925

6,251

10,793

Springhill Rd

1,375

3,920

6,134

T. P. Smith

540

1,038

1,449

Southaa*t

1,015

1,669

4,212

Buck Laka

568

2.478

8,757

Totala

13,466

37,601

66,890

Incraaaa in Population	Total Projactad Flow

Sine* 1987		Baaa Flow		(HOP)	

IHGDI	I?Ig 2000 2010

«.t8

s.ia
3.10
1.66
4.46

0.13
0.13
0.07
21.61

C.87

6.86



86

6.00

7.58

8

53

3.42

3.84

4

75

1.93

2.54

3

17

4.65

5.01

5

32

0.21

0.28

0

33

0.27

0.36

0

72

0.15

0.42

1

30

23.50

26.89

30

97

2-12

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TABU 2-4

POPULATION AMD PLOW PROJECTION SUMMARY

Population?low (mod)

I.Bis* Year 1987

A.City* Existing Service Are*

Total 139,138 24.61

SiivmI by City
Served by On-lot

B.	Propoaed Maatar Plan Expansion Araa

Total

Served by TECO
Sarvad by On-lot

C.	Total Study Araa

Total

Sarvad by City
Sarvad by TECO
Sarvad by On-lot

117,709
21,419

11,663
714
10,949

150,791
117,709
714
32,368

21.61
3.00

1.63
0.10
1.53

26.24
21.61
0.10
4.53

(!)

(1)

XI.

Oasign Yaar 2010

A.	Centralised Alternatives

Total

Sarvad by City
(Baae)

(Infilling)
(Expansion)

Sarvad by TECO
Sarvad by On-lot

B.	Daoantraliiad Altarnativa

Total

Sarvad by City
(Baae)

(Infilling)
(Sxpanaion)

Sarvad by TECO
Sarvad by On-lot

216,117
184,599
(117,709)
( 42,957)
( 23,933)
2,500
29,018

216,117
131,352
(117,709)
( 20,643)
(	0)

2,500
75,265

35.38
30.97
(21.61)
( 6.01)
( 3.35)
0.35
4.06

35.38
24.50
(21.61)
( 2,89)
( 0)
0.35
10,53

(«)

(3)

(2)

(4)

(2)
<5>

Only includaa tha Killaarn Lakaa araa (0.1 mgd) bacauaa tha aarvica araaa of Lakewood (0.3 mgd) and tha Maadowa
(0.07 mgd) a ra outs id# of tha study araa avan though tha traataant facilj.ti.aa ara inaid* tha study araa.

This providaa for tha plannad axpansion at tha Killaarn Lakea facility to allow it to receive 0.35 mgd flows.

This aasuaes all infilling growth will ba sarvad by 2010.

Thia ia tha maximum flow that can ba managed by tha City's facilitiaa at thair currant lavalai

-	LBR Plant	- 4.5 mgd

-	TPS Plant - 20.0 mgd (raratad)

24.5 agd

An altarnata varsion of tha Decentraliaed Altarnativa could involva tha axpanaion of araa facilitiaa to handle
soma of wastewater flow that ia indicated to ba racaivad by on-lot ayatama. Tha daciaion to uaa on-lot varaua
araa facilitiaa should ba made baaad on tha aoila and/or danaity of development.

Tha evaluation of cantrali«ad altarnativaa waa baaad on a deaign flow of 30.97 mgd bacauaa tha remaining study
araa flow, 4.41 mgd (34.38-30.97), ia not being considered for centralised service aa described in Section
2.2.2.

2-13

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2.2.4 Flow Reduction Measures

Flow reduction measures refer to water conservation techniques. These
measures are nonstructural techniques which can reduce treatment operating costs,
relieve overloaded wastewater treatment, collection and disposal facilities, and
reduce the capacity required for new facilities. The nonstructural measures with
potential application in the Tallahassee Leon County area include plumbing codes,
flow-control devices, and educational programs to reduce water use and the
resulting wastewater flow.

The usepa understands from the City of Tallahassee that the City, although
conceptually not opposed to water-saving devices, presently has no prepared plan
to implement water-saving devices and believes such devices would be difficult
to locally implement since Tallahassee has an abundant water supply.

Table 2-5 shows the list of assumptions used in estimating the potential
for wastewater flow reduction in the study area. The effects of these flow
reduction measures on wastewater flow projections were estimated by considering
that per capita reductions in wastewater flows at new and renovated homes are
estimated at 20 gpcd for residents and 6.75 gpcd for commercial/institutional
employees based on the assumptions. These flow rate reductions result in a per
capita flow rate of 117 gpcd for new growth after 1990. (Update: Mo earlier
than sometime after issuance of this feiss, although as indicated above, the city
presently has no prepared plan to implement water-saving devices). Flow
projections for Leon County with the simulated water-saving fixtures are shown
on Table 2-6. The effect of water-saving fixtures at new and renovated
residences and commercial/institutional establishments is to reduce projected
year 2010 average flows to treatment plants from 30.97 to 29.75 million gallons
per day (mgd). This amounts to only a 4% reduction but is considered a
reasonable! figure because water-saving devices will not be required for existing
or non-renovated houses.

Such a water conservation program would not be difficult to implement nor
would it require significant sacrifices by people in new or renovated structures.
Water-saving toilets and shower heads have been used without complaints or public
health concerns in other areas, operation and maintenance of fixtures would not
be costly or frequent.'

The use of these water-saving devices will, however, reduce water and sewer
revenues. other adverse impacts include initial costs and increased
concentrations of wastewater constituents reaching a wastewater treatment plant.

Benefits which would be obtained from 1.22 mgd of lower flow in the year
2010 are the following:

•	Less need for expansion of wastewater collection, treatment and
disposal systems.

•	Less need for expansion of water supply wells, treatment, dis-
tribution and storage systems.

•	Lower operation, maintenance and energy costs for wastewater and
water supply systems.

•	Reduced size of geographical area which is impacted by the disposal
of wastewaters.

•	Groundwater sources are better conserved for future use.

•	Improved chances for proper operation of on-site wastewater treat-
ment and disposal systems.

2-14

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TABLE 2-5

ASSUMPTIONS FOR ESTIMATING
POTENTIAL FOR FLOW REDUCTIONS

1.	Water-saving devices will be required only for residences and
establishments built or renovated beginning in 1990 (updatei no earlier
than sometime after issuance of this FEISS).

2.	No devices will be installed at faucets.

3.	conventional residential toilets use 5 gallons per flush; conventional
commercial/institutional toilets use 4.5 gal/flush. Water-saving toilets
will use 3.5 gallons per flush or 30 and 22 percent less water,
respectively, than conventional toilets.

4.	Conventional shower heads emit 6 gallons per minute; water-saving shower
heads emit 3.5 gallons per minute or 42 percent less water than
conventional shower heads.

5.	Each resident flushes a toilet 5 times per day.	Each
employee/institutional resident flushes a toilet 3 times per day.

6.	Each resident and 30 percent of the employee/institutional population
takes a five-minute shower each day. Time to take a shower is assumed to
be the same with and without water-saving shower heads.

7.	15 percent of existing residences will be renovated between 1990 (Update;
No earlier than sometime after issuance of this FEISSt see item 1 above)
and 2010 requiring the installation of water-saving toilets and shower

• heads. This assumption is based on an average age for home renovation of
50 years and that 15 percent of existing homes will be 50 years of age by
the year 2010.

8.	The per capita wastewater flow rate of 140 gpcd used for future growth
consists of the following components: 75 gpcd for residential flows, 10
gpcd for inflow and infiltration in the collection system, and 55 gpcd for
commercial and industrial flows. 
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TABLB 2-6

PLOW REDUCTION PROJECTIONS BY SERVICE AREA

Sarvlca Aril

Laka Bradford
Road

P.S. No. 12

Riggina Road

Northaaat

Spring Hill

T.P. Smith
Soathaaat
Buck Laka
Total*

Incraaaa in Population
Batwaan 1990 and 2010

-71

18,060
9,513
8,868
4,759

909
3,197
8.189
53,424

Without
1990	Plow

Baaa Plow Raduction
 Haaauraa

Proiactad 2010 Flow 

<.87

6.00
3.42
1.93
4.65

0.21
0.27
0.15
23.50

6.86

8.53
4.75
3.17
5.32

0.33
0.72
1.30
30.97

"wltlT
Plow
Raduction
Haaauraa

6.set1'

8.11
4.53
2.97
5.21

0.32
0.64

_1ill

29.75

Eatiaatad
Raduction

0.00

0.42
0.22
0.20
0.11

0.01
0.08
0.19
1.22

Thia raaulta froa a dacraaaa of population by 71 with an avaraga flow valua of 140
gpcd (UpdataI It ia tha USEPA'a understanding froa tha City of Tallahaaaaa that 160
gpcpd ia tha paak flow and 140 gpcpd ia tha avaraga daily flow, tha lattar baing
uaad in tha IIS Supplaaant).

2-16

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•	Lower sewer, water and energy costs for each water-conserving
residence and establishment.

•	National water conservation goals are supported by responsible
action.

The wastewater management alternatives selected for detailed evaluation
in the EIS supplement (Refer to Section 2.4.6) are evaluated with and without
flow reduction measures to demonstrate the positive effects of flow reduction
measures and to address the "worst-case" scenario, respectively.

2.3 DESCRIPTION OF WASTEWATER MANAGEMENT COMPONENTS

Cost estimates in this section are in third-quarter 1989 dollars.

2.3.1	Alternative wastewater conveyance configurations

The City has a well established conventional wastewater conveyance
system consisting of gravity sewer lines, pump stations, and force "^ins-
Alter native wastewater conveyance components have been identified for service
area expansions. These alternative components are related to the location of
the treatment components. Table 2-7 summarizes the alternative conveyance
components, components Cl and C2 include the costs for conveyance of collected
wastewater to treatment facilities. The remaining components include the

costs for conveyance of treated wastewater to disposal /jfa diaooaal Bitfa°arf
be noted that the pump stations to be constructed *t.^e

not included in the conveyance costs off this tabie but are wde i part of
effluent disposal facility costs of Table 2-9. sections A 1 and A-2 of
Appendix a describe in mo/e detail the elements of the wastewater conveyance
compSneJts Bince they contribute significantly to a total system alternative's
capital costs" The configurations of wastewater conveyance components Cl and
C2 are illustrated on Figures 2-2 and 2-3, respectively.

2.3.2	Alternative wastewater Treatment facilities

The FDER requires secondary level of treatment for public and private

... ^ r f \ * (.-niH'aa The treatment process must achieve a ninety
wastewater treatment fac	•	OXyqen demand (BOD), and total suspended

SSSS^/iSV Additionally"^SinfuSd to irrigate public access Seas,
solids (TSS).	Virst receive filtration to reduce TSS, and high

la i 9° x corses' ° ® olated effluent must not add contaminants to the
level disinfection. The percolatja •rriuwi violat6 sa£e drinking water

groundwater aquifer in eo ff-ent disposal method used may require that

' Thar®f°re'	treatment be employed to remove pollutants such

additional advanced wastewater treatment d p ¦»	heaw metals or toxic

as nitrogen, phosphorus, chemical oxygen demand (COD), heavy metals, or toxic
compounds and total suspended solids (Tssj.

alternative components presented here either
The wastewater treatment altern	exiBting facilities or will be

meet the secondary level of treatment	in the

case of new or

designed to meet the secondary	must be capable of handling the peak

expanded facilities. Also, ^^^/aervice areas. Table 2-8 summarizes

thi ^i£l0W%?enerattlwate£ 'treatment components. Note that treatment compo-
the alternative wastewater trea	Plant (T2) and for constructing a

nents for improving and e^anding the TPS PXant ( ,	phosphoru8 removal

o!W " Plant !T3) ^ClUdl nrovide for the use of artificial wetlands and
apabilities. This was done to P.., components, which require additional
power plant cooling as effluent	Figure 2-4 illustrates the

Phosphorus removal to meet	treatment facilities. Appendix B

location8 of the proposed a 4_, ® Pal__Bnts Qf the treatment alternative
describes in more detail, the elements ot

components.

2-17

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The se plant proposed in the 1983 EZS was not included in the
alternative development process as an option to the NE Plant because it was
determined that "good engineering practice" requires treatment of wastewaters
as close to the source as possible, in this case the Northeast service area.
The use of long interceptors for transporting untreated sewage creates
anaerobic conditions in the pipelines. This leads to undesirable biological
transformations, especially the generation of hydrogen sulfide. These
transformations cause problems such as the corrosion of sewers and other
facilities and the need for control of odorous/toxic gases in sewers. The
treatability of the wastewater is also reduced because of the significant
increase in the immediate oxygen demand of the wastewater arriving at the
plant, and the significant growth of filamentous microorganisms (from slime
layer accumulation) that affect the operations of a treatment process. All
these problems increase both the capital and annual operation and maintenance
costs for a facility and are difficult to quantify in the planning process.
It should be noted that the treatability of wastewater may be an issue for the
alternative component involving an expanded TPS Plant to accept flows from the
northeast. It is assumed that the additional costs to overcome any problems
that may occur are offset by the lower costs for expanding an existing
treatment plant versus the higher coBts for siting, constructing, and
operating a separate new plant.

The 0.25 mgd expansion of the existing Killearn Lakes Plant is
currently underway. No consideration was given to the possibility of
expanding this facility beyond that capacity, in that a larger expansion would
be similar to the alternative for the construction of the .proposed NE Plant.

2.3.3 Alternative Wastewater Disposal Facilities

Table 2-9 summarizes the alternative disposal components. The applic-
ability of these disposal components is related to corresponding treatment
components. It should be noted that for disposal components using the SE
disposal site (01, D2, Dll, and D16), land costs are incorporated into the O&M
costs. Currently the City has a lease agreement with the St. Joseph Land and
Development Company, the owners of the SE land. The agreement sets a lease
rate for the land based on the market value price of two (2) cords of pulpwood
per acre per year plus property taxes. A similar type of agreement is
expected to be used for any additional lands.

As stated in the preliminary county MW&SSP, the USEPA agreed to
amend the scope of the EIS Supplement from that of the originally authored
document to include additional lands presently under consideration by the city
of Tallahassee for an expansion of its effluent spray disposal facilities.
These lands are situated in the Apalachicola National Forest, and are owned by
the USDA Forest Service (FS).

The City approached the USDA FS with a proposal for a land exchange in
order to obtain the subject lands for this purpose. The USDA FS did not
commit to the proposed trade, but expressed that they would require an EIS be
prepared to address the issues surrounding the action prior to any consider-
ation of such an exchange. After the August 15, 1989 Public Workshop
concerning the EIS Supplement, USDA FS forest lands were removed from further
consideration as locations for effluent disposal by USEPA, though the USEPA
does support the use of effluent irrigation for biomass production in
appropriate sites. The public and the Florida Game and Fresh Water Fish
commission (FG&FWFC) expressed concern over losing valuable longleaf pine-
wiregrass habitat found in these forested areas and the restriction of public
access to these areas for recreation. The primary issue in question is the
available longleaf pine-wiregrass habitat, jjo£ the existing vegetation. The
FG&FWFC recommends that such habitat in Florida is critical to maintain and
should also be restored to the fullest extent possible. As such, this is a
perfect site for the reintroduction of longleaf pine and the cutting of the

2-18

-------
TABU 2-7

ALTERNATIVE WASTEWATER CONVEYANCE COMPONENTS

ID Description

Design
Plow(nqd)

CI Traataant South, 31.0
Convayanca to La lea
Bradford Road
Plant and
T.P. Smith
Plant

It an

Sawar
Pump

Continganoy
Total

Annual Langth of	Number of

Capital*1'	O * M Pipa (feet)'2' Pump Station*

30,037
10,424
12,13!
52,586

IBS
216

404

254,53$ 7H
125,000 GS

18

C2 Traataant North 31.0
and South,

Convayanca to Lake
Bradford Road
Plant, and naw
NE Plant

Sawar	19,108

Puap	8,743

Contingancy	8,356

Total	36,207

155	167,335 FH 17

178	121,100 GS

333

C3

Convayanca from
T. P. Smith Plant
to SB

Disposal Sita

C4

C5

2.5

3.8

7.5

9.0

Convayanca from 5.0
T.P. Saith Plant to
Forest Sarvica Land
Naar Airport

Convayanca froa 5.0
T.P. Saith Plant to
T.P. Saith Disposal
Sita

Holding Pond

311

-

Sawar

866

8

Puap

109

14

Contingancy

386

-

Total

1,672

22

Holding Pond

472

-

Sawar

1,317

12

Puap

165

22

Contingancy

587

-

Total

2,541

34

Holding Pond

932

-

¦•was

2,600

23

Puap

326

43

Contingancy

1,157

-

Total

5,016

66

Holding Pond

1,119

-

Sawar

3,120

27

Puap

391

52

Contingancy

1,389

-

Total

6,019

79

Sawar

1,568

8

Puap

1,247

43

Contingancy

845

-

Total

3,660

51

Sawar

-

-

Puap

1,277

23

Contingancy

374

-

Total

1,621

23

42,000 FN

(axpand axiating
puap station)

17,000 FM

2-19

-------
TABLS 2-7
(continued)

ALTSRHAZXVB WASTEWATER CONVEYANCE COMPONENTS

Design	Annual Length of	Number of

ID Deacrlptlon	Plow (mad) It—	Capital*1 > 0 t H Pipe (feetl<*> Pump Stationa

c«

Conveyance from
MB Plant to KB
Disposal Sita

5.2

Sever
Pump

Contingency
Total

1,296
389
1,685

39
39

0



1

C7

Convayanca from
KB Plant to I.P.
Smith Disposal Sita

5.2

Sewer
Punp

Contingency
Total

7,945
1,296
2,772
12,013

39
65

104

82,800

PM

1

Cfl

Convayanca from
HI Plant to SB
Disposal Sita

5.2

Sewer
Pump

Contingency
Total

6,400
1,297
2,309
10,006

32
64

96

66,700

FM

1

C9

Convayanca from
NE Plant to Forest
Service Land Naar
Airport

5.2

Sawer

Pump

Contingency
Total

9,576
1,296
3,261
14,133

48

66

114

99,800

FX

1

CIO

Convayanca from
T.P. Smith Plant
to Golf Courses

3.0

Sewer
Pump

Contingency
Total

1,396
1,538
880
3,814

7
51

58

38,000

FM

1

CU

Convayanca from
Lake Bradford Road
Plant to Oolf
Couraea

3.0

Sever
Pump

Contingency
Total

1,321
1,538
858

3,717

6

50

56

36,200

FN

1

C12

Convayanca froa
¦B Plant to Golf
Couraea and County
Club

0.5

Sever
Pump

Contingency
Total

246

256
151
653

1

12
0

13

20,000

FM

1

C13

Conveyance froa
T.P. Smith Plant
to Power Plant

3.0

Sewer
Punp

Contingency
Total

2,204
1,538
1,122
4,864

11
41

52

44,800

FM

1

C14

Conveyance from
MB Plant to Golf
Course, County
Club, and ABM

1.0

Sever
Pump

Contingency
Total

554
513
320
1,387

3
23

26

10,000

FM

1

Stat* Gardens

2-20

-------
TABLE 2-7
(continued)

ALTERNATIVE WASTEWATER CONVEYANCE COMPONENTS

ID Description
C15

Design
Plow Imqdl

Conveyance from 1.0
T.P. Smith to Power
Line Right-of-way
Arm

C16 Convayanca from 3.9
T.P. Smith to
Existing Sludge
Dispoaal Fields

CI 7 Convayanca from

T.P. Smith to Rapid
Infiltration Baaina
at SE Slta

C18 Convayanca from 1.5
T.P. smith to
Irrigation Site(a)
and Parcolation
Ponda

Itam

Savar
Pump

Contingency
Total

Sawar
Pump

Contingancy
Total

Sawar
Pump

Contingancy
Total

Annual
capital*1* 0_

Langth of
_H Plpa (feet)

Number of

• ' Pump Stations

3,382
1,025
1,322
5,729

1,107
1,999
932
4,038

17
74

91

5
31

36

(Sama aa C3)

2,043

10

769

109

844

-

3,656

119

154,SOO FM

20,000 FN

79,100 FM

C19 Treatment Dacan- 0.25
tralizad (Convayanca
Syatam for Araa
systems)

Total

1,008

(3)

11,000 Fm

1 PS/

Araa Syatam

(1) Include, contingancy coat# at 30%	/uring construction). Cost astimates are in third quarter

administrative costs, and 5% for interest
1989 dollara.


-------
EXISTING SEWER
ALTERNATIVE SEWER
EXISTING PUMPING STATION
EXISTING WASTEWATER TREATMENT PLANT
EXPAMKD EXISTINC PUMPING STATION
ALTERNATIVE PUMPING STATION

tZZZ) existing sprayfield
lake

ROAO

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT

AUiSttATlVE AND EXISt It*
CONVEYANCE SYSTEM
TREATMENT SOUTH

UM WAP souncei

uses Tprooumic ouao s*cet

DATA SOUHCCi

CITY OF T Alt ANAS SEC AM) CAMCTT FUMNC

SCAU IN FEET

OANNETT FLEIMC ENVItONMCHTAL OOCERS. K.
HAfMSURG, PEMISYLVAMA FEBRUARY, ft*

FIGURE 2-2

-------
LEGEND

EXISTING SEWER

—^	 ALTERNATIVE SEWER

~ EXISTING PUMPING STATION
0 EXPANDED EXISTING PUMPING STATION
A ALTERNATIVE PUMPING STATION
O EXISTING WASTEWATER TREATMENT PLANT
O ALTERNATIVE WASTEWATER TREATMENT PLANT
\S //\ EXISTING SPRAYFIELO
LAKE

	ROAD

southeast

SPRAYFIELD

8»SE UAP source.

uses TYPOGRAPHIC OUAD 5>CET

DATA SOURCEi	m _UI_

CITY Of TAUAHA55EE AND CANNE7T FlEMINC

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT

ALTERNATIVE AND EXISTING

CONVEYANCE SYSTEM
TREATMENT NORTH AND SOUTH

CANNETT FLEMINC £NV«ONfc£NTM. ENGINEERS. IMC.
HARR1S8UPG. PENNSYLVANIA	FEBRUARY. 1991

EICURE 2-3

-------
TASXJE 2-8

ALTERNATIVE WASTEWATER TREATMENT COMPONENTS

ID

Deicri.pti.on

T1 Lake Bradford Road Plant
Improvnn nt

Design
Flow (agd)

4.5

T2 T. P. Smith Plant Improvement
and Expansion from 20.0 mgd

Additional coat for Phoaphorua
Removal'3)

21.3

27.5

3.8

C.O

».o

Costs /Thou*and Si	

Annual

Itam	Capital'1* om

Treatment

Conting.

Total

587

17<
763

Treatment

Coating.

Total

Treatment

Coating.
Total

Treatment

Conting.

Total

94

94

Without P Removali
Treatment	2,246

Conting.	337

Total	2,583

13,959
1,943
14,902

With P Removalt

Treatment	707

Conting.	212

Total	919

1,023
307
1,330

1,301
390
1,691

332

332

1,916

1,916

122

122

193

193

290

290

Design Characteristics)

Influent/effluent pump rataa
- 6.75 mgd

Add flow equalization tank
and aludge thickener
Modify influent division
structure, bar screen and
grit chamber, and sewer
division headquarters

Increase maater pump
station rata to equal a
peak flow rata
Add primary clarifiers,
aeration tanks, secondary
clarifiers, a return sludge,
pump station, an aarobic
digester, a bar screen, a
preliminary treatment
dswatering unit and dual
conveyor belts, flow e<)ual-
isation tanks, pump station
and undardraina for raw
sewage overflow
Modify grit chambera,
Parshall flume and chlorine
contact chamber
Optional phoaphorua removal
unit (alum addition)

Doaan't include disposal
coata of axtra aludge
generated by phoaphorue
removal

T3 Northeast Plant Construction

Additional coat for Phoaphorua
Removal'3'

Without P Removali
5.2	Land	143

Treatment 16,309 453
Conting.	4,893

Total	21,345 453

5.2	With P Removal!

Treatment	505	97

Conting.	151

Total	«56	97

Secondary treatment level
with activated aludge waste-
water treatment, chlorina-
tion, flotation aludge
thickening,anaerobic aludge
digestion, and mechanical
aludge dewatering
Optimal phosphorus removal
unit (biological A/O unit)

2-24

-------
TABLE 2-8 (Cont'd.)

ALTERNATIVE WASTEWATER TREATMENT COMPONENTS

ID

Description

T4 On-lot Systems (include
disposal)

Design
Flow (mod)

6.25

Costs (Thousand $)

Item

Annual
Capital11» OtM

Septic Tank 25,793 142

and Soil

Absorption

Saptio Tank 67,SOS 779

and Sand

Mound

Design Characteristics^2*

3.125 mgd handled by septic
tank* with aoil absorption
fields (typical unit haa a
1,000 gallon septio tank
and 750 square foot fiald
with a 30 minute/inch par-
eolation rata

T5 Araa System*

0.25

Total	93,298 921 o 3.125 mgd handled by aeptic

tanks with sand mounds
(typical unit has a 1,000
gallon septic tank, a mound
height between 3.5 and 5
teat, and a centrifugal
pump with a rate of 30
gallon/minute)

Xillaarn 1,130 145 o Contact stabilization
Lake Plant	treatment with land

Expanaion	application disposal

'*' Conting. « Contingency costs assumed to be 30t of construction costa (151 for engineering, 10% for legal
and administrative coats, and 5t for interest during construction). Component T2 excludes the
engineering contingency costs because the design stage is completed. Cost estimates are in third quarter
1989 dollar*.

'2' In addition the characteristics listed, all effluent to be used for spray irrigation requires filtration
to 5 mg/1 Total Suspended Solids (TS8) and high-level disinfection such a* golf course irrigation.

'3' Additional phosphorus removal i* required for effluent diapoaal options D5 (Power Plant Cooling) and
D16/D17 (Artificial Wetlands). For artificial wetlands, phosphorus would be the limiting nutrient and
would require considerably more land if not removed during the treatment process.

2-25

-------
TABLE 2-9

ALTERNATIVE WASTEWATER DISPOSAL COMPONENTS

Coats (Thousand S>

Description

Southeast Agricultural
Spray Irrigation

Design
Flow

raid)

Item

Annual
Capital'1> OtM

Design Characteriatlca

02

Northeast Agricultural
Spray Irrigation

2.5

Land

-

22

o

Application rataa of 2

( 469 acres)

Facilities

1,468

327



in/wk



Conting.

440

-

o

Storage facility for a



Total

1,908

349



maximum of 7 days of flow

3.8

Land

-

33

0

Crop rotation management

< 712 acres)

<2> Facilitiea

2,231

497



similar to axiating system



Conting.

669

-

o

OIK costs include land



Total

2,900

530



laaaa costs

7.5

Land

-

65





(1,410 acres)

Facilitiea

4,403

980





Conting.

1,321

-







Total

5,724

1,045





5.2

Land

22,350

_

o

Application rate of 0.75

(2,235 acres)

<2> Facilities

7,195

669



in/wk

Conting.

2,159

-

o

Storage facility for a



Total

31,704

669



maximum of 7 days of flow

03

Southeaat Forest
Spray Irrigation

3.8

7.5

Land



34

> Faoilitiea

4,848

167

Conting.

1,454

-

Total

6,303

201

Land

-

<8

> Facilities

9,428

316

Conting.

2,828

-

Total

12,256

384

Crop rotation management
similar to existing ayatam
at SB Sprayfiald
Capital coata includa land
purchase coats

Buried, solid-set
sprinklers with C0'x80'
sprinklar and pip* spacing
(approx. 9 sprinklers/acre)
and operating pressures
batman 53 and 70 psi
Application rataa of 2
in/wk for mature growth and
1.5 in/wk for growth 2
years and under
Trea speciea include alaah
pine, loblolly pine and
pond (swamp) pina
"Whole tree" harvesting
every 10 years
Storage facility for a
maxi mtm of 7 daya of flow
OtM costs include land
lease coat

2-26

-------
TABLE 2-9 (Cont'd.)

ALTERNATIVE WASTEWATER DISPOSAL COMPONENTS

Deacriotion

Northeast Forest Spray
Irrigation

Deaign
Flow (mad I

5.2

(2,725 acres)

Costa (thousand S)

Annual

Itaa Capital*11 OtH

Power Plant Cooling at
A. B. Hopkins Generating
Station

3.0

Land	27,250

Facilities	14,111

Conting.	4,233

Total	45,594

Facilitiea 4,270
Conting.	1,281

Total	5,551

Golf Course Irrigation
o FL State Univeraity
o Jake Gaither
a Capital City Country Club
o Hilaman Municipal

3.0

Facilities 2,307
Conting.	S91

Total	2,996

SCO

SCO

265

265

78

78

Design Charactariatlca

Same aa Alternative Com-
ponent D3 except applica-
tion rates are 0.75 in/wk
for mature growth and 0.40
in/wk lor growth 2 years
and under

Capital coats include land
purchase coata

T. P. Smith Facility to be
upgraded to include filtra-
tion and high-leval disin-
fection

Storage facility for 3 mg
The expected Blowdown of
leas than 1.0 agd would
require a modification of
the existing NPDIS permit
for the Hopkins Power
Station in order to
continue diecharging the
blowdown into a tributary
of Lake Talquin.

Use existing golf couree
ponds for flow storage
Uae existing irrigation
aysteas for distribution
Treatment Facility to be
upgraded to include filtra-
tion and high-level diain-
fection

Golf Course Irrigation
at Killearn Golf Course
and Country Club

0.5

Facilities

Conting.

Total

390
117
507

23

23

Sana as Alternative
Component D6

2-27

-------
TABLE 2-9 (Cont'd.)

ALTERNATIVE WASTEWATER DISPOSAL COMPONENTS

Costs (thousand S)

Design	Annual

ID	Description	flow (mqd)	Item	Capital *1> 04M

D8 Golf Course Irrigation	1.0	Facilities	871 44 o

at Killearn Golf Course	Conting.	261

and Country Club and at	Total	1,132 44 o

Alfred B. Maolay Stat*

Gardana

o

D9

Power Line Right-of-Way
Araai

2.0

Facilities

Conting.

Total

3,460
1,038
4,498

111

111

D10

Exiating Sludge Disposal
Fields

3.9

Facilities

Conting.

Total

523
157
680

72

72

Design Characteristics

Sane as Alternative Com-
ponent D6

Storage facility for 0.5
ag needed at the State
Gardens

Evaluation of State
Gardens' plant species
needed to determine
acceptable irrigation
areas

T. P. Smith Facility to be
upgraded to include
filtration and high-level
disinfection
Application rate of 2.0
in/wk

Right-of-way areas to have
an average width of 100
feet; therefore, 26.67
oilea of right-of-way are
required

Buried, solid set

sprinklers

Ho storage facility

Application rata of 2.0
in/wkO

Center pivot sprinklers
Mo storage facility
Evaluation to determine
poesible adverse effects
of < spray irrigation on'
airport activities

2-28

-------
TABLE 2-9 (Cont'd.)

ALTERNATIVE WASTEWATER DISPOSAL COMPONENTS

Daaign

Coata I thomand S)

Annual

Dll

Daacrjptlon

Rapid Infiltration Baain*
at SB Sit*

It*m

012 Rapid Infiltration Baaina
at MS Sit*

3.8

La.nd



9

o

(190 acraa)

(2>Pacilitiai

3,725

347





Conting.

1,117

-





Total

4,842

356



6.0

La.nd

-

14

o

(300 acraa)

Pacilitiaa

5,882

547





Conting.

1,764

-

o



Total

7,646

561

o

9.0

Land

-

21



(450 acraa)

Pacilitiaa

8,822

801

o



Conting.

2,646

-





Total

11,468

822

0

5.2

(260 acraa)

Land

Pacilitiaa

Conting.

Total

2,600
5,097
1,529
9,226

474

474

Daaign Charactarlatlc*

May raquira traatmant for
additional nitrogan
ramoval to pravant ground-
watac contamination
Application rata of 10
in/vk

Mo atoraga facility
RIBa to ba conatructad as
•mall, ona-aera calla
Bxtanaiva groundwater
monitoring raquirad
Evaluation of ainkhola
activity to pravant "ahort
circuiting* of tha infil-
tration ayatan
OiM coata includa land
laaaa ooata
Sana aa Altarnativa Com-
ponant Dll axcapt that
land ia purchaaad not
laaaad

Capital coata includa land
purchaaa ooata

D13 Landacapa Irrigation and
Diapoaal in Parcolation
Ponda (radiatribution)

1.5

Pacilitiaa

Conting.

Total

1,461
439
1,900

65

65

D14 Surfaca Watara

St. Mark'a Rivar (pipa
langth - 15 mil*)

5.0

Convay.

Conting.

Total

9,870
2,961
12,831

55

55

St. Mark'a Rivar ha* baan
claaaifiad by PDER aa a
Spacial Watara (0 affluant
limitation)

Ochlockonaa Rivar
(pipa langth >9.8 mila)

5.0

Convay.

Conting.

Total

7,323
2,197
9,520

112

112

Ochlockonaa Rivar haa baan
claaaifiad by FDER aa a
Spacial Watara (0 affluant
limitation)

Ocaan Outfall (Gulf of
Maxico, pip* langth »
22.4 milaa)

5.0

Convay.

Conting.

Total

16,707
5,012

21,719

90

90

Outfall oonaiata of a 1
mila long, buriad pip*

2-29

-------
TABLE 2-9 (Cont'd.)

ALTERNATIVE WASTEWATER DISPOSAL COMPONENTS

Costs (thousand S)

ID	Description

015 Deep Wall Injection

Daaign
Plow (mad)

5.0

D16 Artificial (Conatructed)
Wetlands at SE
Disposal Sits

Item

Test Prog.

Pump

Wall*

Conting.

Total

3. a	Land

(234 acras) Facility
Conting.
Total

6.0	Land

(370 acraa) Facility
Conting.
Total

9.0	Land

(554 acraa) Facility
Conting.
Total

Annual
Capital'1) O&M

767
1,247
1,610
1,087
4,711

4,653
1,396
6,049

7,285
2,186
9,471

10,774
3,232
14,006

129
60

189

11
51

62

17
75

92

26
97

123

Daaian Characteristics

Install a tast wall to
idantify a geologic forma-
tion suitable for
injection

Costs assume a well depth
of 4,000 feat and an
injection pressure of 75
psi

Subsurface flow systems
Pilot program to be devel-
oped prior to full-scale
construction to determine
pollutant removal effi-
ciencies

Detention time « 14 days
Maximum loading rata - 6
acre-in/wk

Maximum nutrient loading
rata » 75 g/mJ/yr total
nitrogen

Maximum affluent content
fraa wetlands • 5 mg/1 '
BOD; 5 mg/1 TSS; 3 mg/1
Total Nj and 1 mg/1 Total
P

Fill is a 30 inch deep
gravelly sand mixture
(maximum lot diameter 8
mm) that ia planted with
bulrushes

Media is lined with an
artificial or compacted
clay liner with a
permeability ¦ 1x10"®
maters/sec

Slope of ayatem • 1.51
Integrated diacharga
system with RIBs
O&M coats include land
leaaa ooata

2-30

-------
TABLE 2-9 (Cont'd.)

ALTERNATIVE WASTEWATER DISPOSAL COMPONENTS

Costs (thousand S)

ID

Description

Design
Flow (mad)

Annual

Ifm	Capital.*1* 04M	Design Characteristics

D17 Artificial (Constructed)	5.2

Wetland* at NE Diapoaal (320 acres)
Constructed Sita

Land
Facility
Conting.
Total

3,200

6 ,355 69
1,907
11,462 69

o Santa aa Alternative Com- .
ponent D16 except that
land ia purchaaed not
leaaed

o Capital costs include land
purchaae coata

Conting. - Contingency coata aaauned to be 30% of conetruction coata (151 for engineering, 101 for
legal and administrative coata, and St for interest during construction). Coat eetimates are in third
quarter 1989 dollars.

Land requirenenta vary due to application rates and buffer areas for acreagea shown under "Design
Flow" column. Application ratea shown under "Design Characteristica" are the maximum application rate
of the land considered for disposal (based on aoil survey (USDA [SCS] and USFS, 1961) aasessments as
opposed to actual on-site percolation testing). Average application rates could bs lower or higher
than maximuma praaented.

The City of Tallahassee has calculated the acreage needs for the footnoted components shown under
"Design Flow." An average "rule-of-thumb" application rate of 2 inches per week was assumed. In
general, the revised acreage eatimatea appear to be less (by varying percentages) than thoae presented
in this table. The examplea of updated acreages provided by the City aret

Component D1

City'a calculated average acreage ia 322 acrea vs. 469 acres for 2.5 mgd flow; 490 acres va. 712 acres
for 3.S mgd flow; and 967 acrea va. 1,410 acrae for 7.5 mgd flow.

Component D2

City'a calculated average acreage is 1,786 seres vs. 2,235 acres for 5.2 mgd flow.

Component D3

City's calculated average acreage is 490 acrea va. 747 acres for 3.8 mgd flow; and 987 acres vs. 1,475
acres for 7.5 mgd flow.

Component Dll

City'a calculated average acreage is 98 acrea va. 190 acres for 3.8 mgd flow.

Differences in the acreage estimates are apparently due to the use of maximum rates versus average (2
inches/week) application ratea. The USEPA recommends actual on-aite percolation teating prior to
implementation of any alternative. The local deciaion-makers may or may not chooae to reconaider
the acreage valuea for these examplea (and possibly others where necessary during the alternatives
selection process. Changes in acreages could also accordingly affect other related factors itemized
in Table 2-9 such aa capital needa.

The USEPA understands from the City of Tallahassee that if affluent and sludge are co-disposed,
groundwater Nitrate-N limits will be exceeded under an application rate of 2.0 in/wk. Therefore, the
City recanmenda that the application rate ahould initially be limited to 1.0 in/wk for at least a trial
period. The City ia currently spreading sludge in 200 acres of pine forest and 500 acres of hay
fielda, i.e., (700 acrea) (1.0 in/wk) (0.00388) • 2.7 mgd.

2-31

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N

I

LEGEND

O existing wastewater treatment plant
© expanoed existing wastewater treatment plant

O ALTERNATIVE WASTEWATER TREATMENT PLANT
\///\ EXISTING SPRATFIELO
&Z/Z4 ALTERNATIVE SPRATFI ELD

lake

	 ROAD

WESTERN SOUTHEAST EASTERN
EXPANSION SPRAYFIELD EXPANSION

BASE UAP SOURCEi

USCS TPPOCRAPHIC OUAO SHEET

DATA SOLRCEl

CI TT OF TALLAHASSEE ANO CANNETT FLEMING

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT

ALTERNATIVE SPRAYFIELD
DISPOSAL SITES AND
AREA TREATMENT
PLANTS

SCALE IN FEET

GANtCTT FLEMNG ENVIRONMENTAL ENGINEERS, NC.
HARRtSBURG. PCNNSUVANU FEBRUARY. 1991

FIGURE 2-4

-------
present slash pine. Figure 2-4 illustrates the locations of the alternative
disposal facilities including the USDA FS facilities. Appendix c describes in
detail each of the alternative components.

2.3.4	Alternative Sludge Treatment and Disposal Facilities

Table 2-10 summarizes the alternative sludge handling components.
Appendix D describes each of the components in more detail.

2.3.5	Alternative Decentralized Wastewater Management Facilities

2.3.5.1 on-lot systems

On-lot wastewater treatment systems in Tallahassee are generally
limited to septic tanks, although sand filters and extended aeration systems
have also been used (USEPA, 1981). on-lot systems are mostly associated with
individual residents, although some institutions and commercial facilities also
use the systems. Subsequently, the on-lot component assumes the use of septic
tanks for residential lots.

Septic tanks alone do not meet secondary treatment levels; they
rely on the biological activity in the soil absorption drainfield to complete
the Moondai7 level treatment. Additional treatment takes place as the

effluent percolates through the soil. Septic tank with	SoSdltlonl

can operate effectively with limited maintenance as long as soil conditions,

land slopes and land use are suitable,
drainfield. du.1°tPrth"eio;0™ig»ph°itc

^^iWoA" condition"	..vr.Xy influence

drainfield placement in the County.

1 e«ii Mao" for Leon County in the 1981 Soil
Based on the Genera	countv is dominated by three soil

Survey (USDA [SCS] AND USFS, 198 >'	association in the northern part of

associations: the Orangeburg-Lucy-No^	Dorovan-Talquin-Chipley

Leon county and the ^rshaw-ortega-Alpin and tne^	eburg_*ucy_Norfolk

associations in the southern part of Leoia c * L1 well-drained while the
soils and the Kershaw-Ortega-Alpin soils. are ^"^drained. Specifically,
Dorovan-Talquin-Chipley soils are	*burg_Lucy-Norfolk soils as "well

the 1981 Soil survey classifyes	in goii8 as "excessively drained and

drained soils" and the Kershaw- Ortega.Alp Dorovan_Talquin-chipley soils are
moderately well drained soils,» while the Doro	8oils.« of the two

considered "somewhat poorly drained to very p y aandy associations differ
well-drained soil associations, the	°8foiifl lre flandy to only 20-inch

significantly: the Orangeburg-Lucy-l~ndv 20-40 inches deep with loam below or
depths with loam below, compared to sandy^20I 40y	igFdefined in the 1981

are loamy throughout (Note: "loam 13	(28-50%), and sand (<52%)

Soil survey as a mix of clay _	J' «lDin soils are sandy to 80 inches

particles.) By contrast, the Kefshaw"°^®^*llaav below 45-inch depths,
or more, with some having loamy layers (lamellae) below inc y

.. u«iitiAa of thssd soil associations for
Regarding the a^tabiliti ^ ig81 Soii survey presents the

septic tank absorption fields. Table ii	tvoes. All listed Orangeburg,

"restrictive soil features" of listing soil	percs alowlY» and/or

Lucy and Norfolk soil types are elas". defined as having unfavorable soil
moderate: wetness," with "moderate" being K«ihaw soils Ire classified as
Properties for the given activity. The	Generally favorable for the

"Blight- which i. defined a. .oil	«¦»•»«•: poor filter,*

activity. oretega and Alpin .oil. «• clawntiM £	f/r th.

with "severe" being defined as soil properties very uuj.

2-33

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TABU 2-10

ALTERNATIVE SLODGE TREATMENT/DISPOSAL COMPONENTS

ID
SOI

Dascriotion

Land Spreading

Traataant South

Sludga Hauling
Sludge Disposal

Treatment north and South
Sludga Hauling
Sludge Disposal

Design
Capaeity
'Drv Tona/«od>

0.34

Coat (Thousand S)

Total

Total



26}

1.196

l,Ui
134

2.848

i,i»i

Annua
OtH

2)

252

m

w
209

Hoi

SD2

Palletization

0.36

10,251

2,435

Coat eatiaatea ara in third quarter 191* dollars.

I'' Cost differencee are duo to different hauling diataneaa and land eosta at tha two faoilitiea.

2-34

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activity. The Dorovan, Talquin and Chipley soils are classified as "severe:
wetness" or "severe: floods, wetness." These classifications indicate that
only the Kershaw soils have properties favorable for septic tank absorption
field infiltration while the others do not adequately drain or drain too well
and therefore do not provide proper filtration (i.e., adsorption of inorganics
(metals), microbes, etc.). Leon county therefore appears to be a mix of soil
types with "slight," "moderate" or "severe" classifications regarding the
suitability for septic tank activity. The preliminary 1988 Leon county MWtssp
also addresses the issue of soil suitability for septic tanks within Leon
County.

From discussion with the usda scs and the lcph, it is evident
that use of the soils in the northeast area for septic tank effluent
drainfields is somewhat limited. USDA SCS and LCPH employees involved with
permitting on-lot systems indicated that, as house densities increase on areas
of marginal soils, the incidence of drainfield failures increase. in
particular, USDA SCS and LCPH employees feel the problems experienced in the
Killearn Lakes subdivision are intensified due to the small (1/4 acre) lot
size and the semi-controlled sheet flow for stormwater management.

The predominant soil type, which experiences septic tank
operation problems, is the Dothan soil series. The USDA SCS description of
this soil indicates a perched water table at 3-1/2 to 4 feet during portions
of the year The experience in Killearn Lakes is that the water table is at 2
inches above ground to 12 inches below ground for extended periods of time.
The USDA scs and LCPH personnel believe that the septic tank failures are due
to the elevated groundwater table brought on by water added to the soil
profile through the on-lot systems effluent drainfields and by small lots with
closely spaceddrainfields. The problem is exacerbated by the directed sheet
flow over numerous lots in the area.

Drainfield failures on lots on Dothan soils occur in other
Within th. county; hov.v.r. th. f«Uur. r.t. la, otb.r portion, of th.
County is low in comparison to the Killearn Lakes failure rates. This is
primarily due to localized natural variations in the soil and larger lot sizes

in other subdivisions.

To overcome less than ideal conditions, various processes have
, j Iu	the treatment and disposal capabilities of on-lot

been developed that enhance the trea«ne utilia.3in some soils that are not

,Sand mou"d, on«oil drai™ fields. Rather than a five- to .ix-foot

den^i* 5 C¦romiired for soil percolation, only a three-foot depth to

wȣ 3 ?r	vimiired with sand mounds. The mound itself provides

water table is normally required wi	with increased wastewater

an unsaturated soil depth for add;Ltiowl 'trwtoeat with increased wastewater

retention capacity which results in higher treatment efficiency.

«	-r<» beino used in isolated instances within the

Mound systemi	varying degrees of success. some of the

Droh?arn Lakes. subdiVIsi°" se individual systems are that the grade of the
problems associated with	tittle area on the lots being available for

ouge and septic tank results . n(j whan the groundwater level is very
the mound without the need for pumping,	laterally out of the mound

shallow the water moving through themounu dld lot.

^suiting in surface ponding or flow over the aevexopea

ba(ja allow wastewater to be utilized by
Bli .	Evapotranspirat:here. These beds can be used only where

ei«« a?d •vaporat* ?	exceeds precipitation. Within Leon County,

Juration and transpiration e	q£ #vapotranspiration beds during the

"•tKS? B^th^ oT thePryVrr b.cius. rainfall exceeds evaporation by more than 2

inches per month.

2-35

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Component T4 uses a combination of conventional soil absorption
fields and innovative sand mounds for costing purposes. Costs for this
component are presented in Table 2-8.

2.3.5.2 Area Systems

The area system treatment component will have to meet the same
secondary treatment levels and required advanced wastewater treatment as the
larger conventional facilities. The area system disposal components include
evaporation-percolation ponds and irrigation systems as well as soil absorp-
tion drainfields and sand mound systems. Both ponds and irrigation systems
become more competitive as larger flows are handled. Land requirements for
each type of system are variable depending on soil percolation rates, evapo-
transpiration, and treatment system buffer requirements established by state
and local agencies.

These systems will most likely be located in the outer fringe of
the City's existing service areas and elsewhere in the unsewered areas of the
county. It is also possible that existing developments with failing on-lot
systems could be retrofitted with area systems as opposed to connection with
the existing conventional system. The actual size and location of these
systems would vary on a case-by-case basis. For this report the component,
T5, only includes the costs for the proposed TECO facility at Killearn Lakes.
Costs for this component are presented in Table 2-8.

2.3.6 Management options

Management as used here refers to owning, planning, constructing,
operating, and/or maintaining of wastewater service facilities. Development
of management options requires a review of the management of existing waste-
water services as was done in Section 2.1.

The entities identified as currently managing major wastewater
facilities include the city and teco. other small private providers exist but
are not considered capable of managing the level of services needed in the
future and therefore are not identified here. It is realized, however, that a
limited amount of services will be provided by such companies. The County's
current management role involves only the authorization for planning,
constructing, and operating wastewater services and includes no direct
management of facilities.

In the County MWSSSP, alternatives were presented for the provision of
wastewater services in unincorporated areas of the County. The -provision" of
wastewater services as used in the County MW&SSP is similar to the definition
of management presented in this section. These "provision" alternatives are
summarized in Section 1.3.4 of this FEXSS. The basic premises considered in
developing these alternatives were: (l) the County remaining in a non-
provider role and (2) the county changing to a provider role.

The development and selection of management options depends on the
physical wastewater facilities to be used for future needs, the existing
management scenarios, and the potential management entities' capabilities.

A large centralized facility can probably be best operated and main-
tained by a single large organization. This is due to the technical sophis-
tication normally required for large centralized wastewater collection, treat-
ment, and disposal units. A single, large organization has the resources and
continuity to best meet the needs of such a system. Potential management
entities in the study area include the City or the County (or if feasible a
joint venture between the two). The City has an existing water and Sewer
Department that is experienced in managing large systems. TECO's ability to

2-36

-------
manage a large centralized facility is unknown in that it is presently only
experienced with managing facilities that process flows of 0.3 mgd or less.

Small area facilities, such as those currently operated by TECO, and a
combination of small private entities can be managed individually as is
currently done or they can be managed by one large organization such as that
described for a large centralized facility. Having one organization manage
many small wastewater facilities has the advantage of conformity to one uni-
form set of standards for operation and maintenance and of access to a large
pool of specialized labor force and inventories that small, individual
managers may not have* The disadvantages of centralized management for a
decentralized system is the logistic problems that occur when managing remote
facilities distributed over a large geographic area and the potential slowing
of response time to problems occurring at these remote sites due to the
requirements of bureaucratic procedures normally found in large organizations.

A variation of individual - management and centralized management of
decentralized facilities is a joint-venture. The joint—venture can take one
of several forms. One scenario could have a large entity, such as the city or
the county, plan, construct and/or own the facilities and another entity or
group of entities operate and maintain the facilities.

In regards to on-lot wastewater systems, management normally consists of
the county Department of Health approving the site, the private owner building
and maintaining the facility, and the Department of Health inspecting problems
as they occur. No management option is proposed to replace this procedure but
it is recommended that the county continue to document all inspections and
problems to provide information for future wastewater management planning
tasks and to control adverse environmental impacts.

2.3.7 Industrial pre-Treatment

The USEPA/Region IV has primacy over industrial waste pre-trea^eot in

Florida since the USEPA/Region IV has primacy over t*?® ^lortSt Pollutant
Discharge Elimination system (NPDES) permitting program in Florida.

currently, the city of Tallahassee has no surface^ water ^discharges of

wastewater effluent and is not required to ^f^^v hS conduced aslvS
since they do not have any NPDES permits. . ^Lm lith fiow dfta on their
system Inventory Program which has provided th	categorical industries

^ ^ customers. The City does n^ fta^nima\ industrial development
connected to the sewer system and nas onxy aix'	, industrial sever

within their service area. Presently, the onljm	two TIT

customers include a crab processing plant, a gear	/

university laboratories.

The city is revising their Sewer Use Ordinance ^to include^ specific

Program by requiring industries to:

1.	Obtain industrial waste discharge permits;

2.	Meet specified discharge limits;

3.	Install monitoring manholesjand	t the results in a

4.	Conduct quarterly self-monitoring ana
report to the City.

2.4 ALTERNATIVE WASTEWATER MAHAGEMEHT SYSTEMS SCREENING

	. _ oerformed for the nine (9) system

Alternative wastewater Bcr®_e"^"g ,	Thj.B evaluation was developed

alternatives considered (Alternatives ) •	and 9) were selected

during 1989. Tour of these nine alternatives (1' '	durj.ng the DEISS

for further evaluation in the EIS supplement, specifically auring

2-37

-------
preparation stage (1989). The matrix rating evaluation of the four selected
system alternatives is addressed in Chapter 3.

2.4.1 Alternative Wastewater Management Svstem composition

combinations of the previously-described alternative components were
analyzed to compose total wastewater management system alternatives. Three
alternative system scenarios were devised based on the collection and
treatment components. These basic scenarios are as follows:

1.	Centralization with conventional conveyance and treatment of
wastewater in the south at the existing Lake Bradford Road Plant
and T. p. smith Facility.

Improve Lake Bradford Road Plant (4.5 mgd).
improve and expand T. p. smith Facility (27.5 mgd).

Total design flow - 31.0 mgd.

Components include CI, Tl, and T2.

2.	Centralization with conventional conveyance and treatment of
wastewater in the south at the existing Lake Bradford Road Plant
and T. P. Smith Facility and in the north at a new NE plant.

Improve Lake Bradford Road Plant (4.5 mgd).

Zmprove and expand T. P. Smith Facility (21.3 mgd).

Add new NE Plant (5.2).

Total design flow » 31.0 mgd.

Components include C2, Tl, T2, and T3.

3.	Decentralization

Continue to use on-lot systems and area systems to meet future

wastewater management needs.

Improve Lake Bradford Road Plant (4.5 mgd).

Components include C19, Tl, T4, and T5.

NOTE* Although the total City treatment capacity was rerated to
32.0 mgd (or 32.06 mgd if the HAP facility is included),
the flow projections in this Eis Supplement indicated that
only 31.0 mgd would be required for the planning period, »o
that 31.0 mgd was used in the EIS supplement (e.g., items
1 and 2 above and in Tables 2-11 through 2-19 below in
developing costs.

A "total system" alternative incorporates one of these basic scen«ri08
with selected components for the conveyance and disposal of treated Waste-
water. Figure 2-5 is a decision tree that illustrates the major
points that lead to the development of system alternatives. The selection
the components that are addressed in this decision tree was based on c*pital
costs in that those combination of components with the lowest capital
per unit of design flow were included, it should be noted that the ®ryificia^
wetland disposal component was merged with the Rapid Infiltration Basin
disposal component for system alternatives 3, 4, 7 and 8. Mo streams arQ
nearby that are permitted to receive the discharge from the wetlands*
therefore, ribs are proposed to receive the high quality wetland effluent.
Since ribs in the study area can safely handle only effluent that has ree*ive(j
high levels of treatment, merging the two as one disposal facility ov0C>cOiQtt8
these shortcomings and taJces advantage of the components.

Tables 2-11 through 2-19 are summaries of the composite "total "Vstem*
alternatives which were chosen based on the reasonableness of their CQ(.
estimates and implementability characteristics. Alternative system A.9
essentially the "No-Federal-Action" alternative that was the ••^•cted
preferred alternative of the 1983 EIS. Subsequently, it is included so th^+.
it will receive detailed evaluation along with the selected centralized "Vat®-,
alternatives. Figures 2-6 and 2-7 exhibit the major components of tne
(8) centralized system alternatives.

2-38

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NO NEW NE
PLANT

GOLF COURSE

SPRAY

RRIGATION

NO GOLF
COURSE SPRAY
IRRIGATION

SE AGRICULTURAL
SPRAY
IRRIGATION

SEFOREST

SPRAY

IRRIGATION

o

0

SE WETLANDS
AND RIBS

0

SE WETLANDS
AND RIB'S

0

TPS

PLANT

EXPANSION

LBR
plant

IMPROVEMENTS J

NEW NE
Lplant

NE DISPOSAL
SITE

NO NE DISPOSAL
SITE

NE AGRICULTURAL
SPRAY
IRRIGATION

©

NE FOREST

SPRAY

IRRIGATION

©

NE WETLANDS
AND RIB S

SE WETLANDS
AND RIB'S

0
0

NO
TPS
. PLANT
^EXPANSION

DECENTRALIZATION
(AREA AND ON-LOT SYSTEMS)

0

©

LEGEND

SYSTEM ALTERNATIVE ID

DECISION TREE FOR SELECTED
SYSTEM ALTERNATIVE DEVELOPMENT

FIGURE 2-5

-------
All system alternatives are sized to handle the total projected 2010
design flow of 31.0 mgd. The only exceptions are the TPS Plant and SE
Sprayfield expansions of 7.5 mgd. These are the city's current level of
planned expansions which would bring the total design flow capacities at the
T. P. smith Facility and the SE sprayfield to 27.5 mgd. These capacities,
together with the improved LBR Plant capacity of 4.5 mgd, provides a total
treatment capacity of 32 mgd.

It should be noted that treatment components T4 and T5, on-lot systems
and area systems, only include those flows (6.50 mgd) that would be connected
to a centralized facility if a centralized system was selected. The remaining
on-lot systems of the study area that handle a flow of 4.06 mgd (Refer to
Table 2-4) are not included because all system alternatives would have this
component.

The flows, acreages, and estimated costs presented in the tables are
only for the proposed new facilities and expansion components. Existing
facilities' flows, acreages, and annual 04M costs are not included with the
exception of the wastewater conveyance and the LBR Plant components. The
conveyance component design flow, 31.0 mgd, is the study area's total
projected flow for the year 2010. The LBR Plant's 4.5 mgd flow value is an
existing design flow that will be achieved when the existing facilities are
improved. The costs include the proposed plant improvements.

2.4.2	Preliminary Cost Evaluation

Tables 2-11 through 2-19 also provide cost estimates for capital project
and annual operation and maintenance costs for ®ach of the system
alternatives. These estimates are summarized in Table 2-20, and they include
a present worth value for each alternative. Present worth analysis is a
method of alternative comparison that incorporates both initial capital outlay
and future annual costs. These costs are the basis for the evaluation of the
four (4) system alternatives selected for further evaluation (1, 2, 7 and 9),
as presented in Chapter 3. Costs for the LBR Plant improvements, the TPS
Plant expansion, and the SE Agricultural Sprayfield expansion (including force
main conveyance) were based on costs taken from the ^ 8 j~^ear °®Pital
budget, costs for the Killearn Lakes Plant expansion ware based onestimates
obtained from teco staff. All other costs were calculated using cost curves
provided in various USEPA manuals and historical cost data provided by the
USEPA's NEPA contractor. The capital costs include contingencies which are
percentages of the construction costs (15% for engineering design, 10% for
legal and administrative costs, and 5% for interest during °°^uction) The

only exceptions are the capital costs f°r . . uaan Mnmiated and on int-
engineering design costs because design already has been completed) and on-lot

systems (no contingencies included).

it should be realized that alternatives incorporating agricultural

rr:Yrdi • s °ilv&:¦" >

^ountofrevanueawillvary greatly depending on the type of crop, the crop'.

=»r«M Lr£? v'lue,1 .„Tth. typ* of	VccounS?	tto ®oo«

y«r. subsequently, the.e revenue. «re not .ooounted for in the co.t

estimation process.

2.4.3	Environmental ^valuation

j This section summarizes the *igruficanJ
w th each of the nine (9)	* ibility to'select the system alternatives

*o?nL^.dC^u*Uot„ef«1f:r\rs:ctio"I.4tr6). The envi/on^enf! i*p.ct.

2-40

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TABLE 2-11
SYSTEM ALTERNATIVE 1 (1)

Component Description

Treatment Plant Conveyance
to Laka Bradford Road Plant and
T. P. Smith Plant

Flew
(mod)

31.0

Eatimatad Costs
Land	(Thouaand S)


-------
TABLE 2-12
SYSTEM ALTERNATIVE 2 <

Component Description

Treatment Plant Conveyance
to Lake Bradford Road Plant and
T. P. Smith Plant

Lake Bradford Road Plant
Improvement*

T. P. Smith Plant Improvement
and Expansion from 20.0 mgd

Plow
fmqd)

31.0

4.5

7.5

Estimated Costs
Land	tThousand S>

(Acres)	Capital	Annual OtM

52,586

763

14,902

404

94

1,916

Collection/Treatment Subtotal

68,251

2,414

Conveyance from T. P. Smith
Plant to SB Disposal Site

Southeast Forest Spray
Irrigation (expansion to
existing 22.0 mgd SE Sprayfield)'2'

Conveyance from Lake Bradford Road
Plant to Golf Courses

Coif Course Irrigation
o Florida State University
o Jake Caither
o Capital City Country Club
o Hilaaan Municipal

Disposal Subtotal

System Total

7.5

7.5

3.0

3.0

1,475

1,475
1,475

5,016

12,256

3,717

2,998

23,987
92,238

66

384

56

78

584

2,998

(1)

(2)

Cost estimates in third quarter 1989 dollars.

.. * - the Citv of Tallahassee that the 22.0 mgd design irrigation
Uodatei The USEPA understands from tne j	. t	„„ 9/a/89 (Also see footnote 3 of

of the City. SE Sprayfield has been r.rated to 23.25 »gd

Table 2-11).

2-42

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TABLE 2-13
SYSTEM ALTERNATIVE 3 (1'

Conomnt Description

Treatment Plant Conveyance
to Lake Bradford Road Plant and
T. P. Smith Plant

Lake Bradford Road Plant
Improvement*

T. P. Smith Plant Improvement
and Expansion from 20.0 mgd

Collection/Treatment Subtotal

Conveyance from T. P. Smith
Plant to SE Disposal Site

Artificial Wetland* at SE
Dispoeal Site

Rapid Infiltration Basins
at SE Disposal Site

Conveyance froa Lake Bradford Road
Plant to Golf Courses

Coif Course Irrigation
o Florida State University
o Jake Gaither
o Capital City Country Club
o Hilaman Municipal

Disposal Subtotal

System Total

Plow

(mgd)

31.0

4.5

7.5

7.5

6.0

6.0

3.0

3.0

Land
I Acres 1

370

300

Estimated Costs
(Thous""d

52,586

763
16,232

69,581
5,016
9,471
7,646
3,717
2,998

670
670

28,848
98,429

404

94

2, log

2,607
66

»a

56
'8

8S3
3'46o

(1)

Cost estimates in third quarter 1989 dollars.

2-43

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TABLE 2-14
SYSTEM ALTERNATIVE 4

Component Description

Treatment Plant Conveyance
to Lake Bradford Road Plant and
T. P. Smith Plant

Lake Bradford Road Plant
Improvements

T. P. Smith Plant Improvement
and Expansion from 20.0 mgd

Plow
(modi

31.0

4.5

7.5

Land
(»cre«)

Estimated Cost*
(Thousand Si
Capital	Annual OtM

52,566

763

16,594

404

94

2,206

Collection/Treatment Subtotal

Conveyance from T. P. Smith
Plant to SE Disposal Site

Artificial Wetlands at SE
Disposal Site

Rapid Infiltration Basins
at SS Disposal Sits

Disposal Subtotal

System Total

9.0

9.0

9.0

554

450

1,004
1,004

69,943

6,019

14,006

11,468

31,493
101,436

2,704

79

123

822

1,024
3,728

I1' Cost estimates in third quarter 1989 dollars.

2-44

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TABLE 2-15
SYSTEM ALTERNATIVE S I1)

Coiponant Daacriptlon

Treatment North and South
Conveyance to Laka Bradford Road
Plant, T. P. Smith Plant,
and new MB Plant

Laka Bradford Road Plant
Iaprovaaanta

T. P. Smith Plant Iaprovement
and Expansion from 20.0 mgd

Northeast Plant Conatruction

Collection/Treatment Subtotal

Plow
(aqd)

31.0

4.5

1.3

5.2

(Acraal

Estimated Coata
(Thouaand S)

Capital	Annual ot|i

36,207

763

2,583

£1x245
60,898

333

94

332

_A33
1# 212

Convayanca froa NE Plant
to NB Diapoaal Sita

Horthaaat Agricultural
Spray Irrigation

Convayanca from T. P. Smith
Plant to- SB Oiapoaal Sita

Southaaat Agricultural Spray
Irrigation (axpanaion to exist-
ing 22.0 agd SI Sprayfiald)'

Diapoaal Subtotal

Syataa Total

5.2

5.2

3.8

3.8

2,235

712

2,947
2,947

1,(85
31,704
2,541
2,900

38,830
99,728

39
««9

33
330

1/2?!
2»4«3

Coat aatimataa in third quartar 1989 dollara.

Update! Tha USEPA undaratanda froa thi
capacity of tha City'a SE Sprayfiald haa
Table 2-11).

1a City of Tallahaaaee that tha 22.0 agd daeign	,

a been raratad to 23.25 agd on 9/8/89 (Alao aaa footttot% io»

2-45

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TABLE 2-16
SYSTEM ALTERNATIVE 6 I1)

Component Description

Treatment North and South
Conveyance to Lake Bradford Road
Plant, T. P. Smith Plant,
and naw HE Plant

Laka Bradford Road Plant
Improvements

T. P. Smith Plant Improvement
and Expanaion from 20.0 mgd

Northeast Plant Conatruction

Collection/Treatment Subtotal

Plow
(mqdl

31.0

4.5

1.3

5.2

Land
tAcra»>

Estimated Coats
(Thousand S)

Capital	Annual OtM

36,207

763

2,583

21.345
60,898

333

94

332

453
1,212

Convayanca from NE Plant
to NE Disposal Sita

Northaaat Porast Spray
Irrigation

Convayanca from T. P. Smith
Plant to SB Dispoaal Sita

Southaaat Porast Spray
Irrigation (expansion
of existing Sprayfiald)

Disposal Subtotal

Systam Total

5.2

5.2

3.8

3.8

2,725

747

3,472
3,472

1,685
45,594
2,541
6,303

56,123
117,021

39

560

33

201

833
2,045

(*) Cost estimates in third quarter 1989 dollars.

2-46

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TABLE 2-17
SYSTEM ALTERNATIVE 7 (1)

Component Description

Treatment North and South,
Conveyance to Laka Bradford Road
Plant, T. P. Smith Plant,
and new ME Plant

Laka Bradford Road Plant
laproveaents

T. P. Smith Plant Improvement
and Expansion from 20.0 agd

Northeast Plant Construction

Collection/Treatment Subtotal

Conveyance froa NZ Plant
to NE Disposal Site

Artificial Wetlands at NX
Disposal Site

Rapid Infiltration Basins at
HI Disposal Site

Conveyance froa T. P. Saith
Plant to SI Disposal Site

Artificial Wetlands at .SE
Disposal Site

Rapid Infiltration Basins
at SE Disposal Site

Disposal Subtotal

Systea Total

Plow

(agd>

31.0

4.5

1.3

5.2

5.2

5.2

5.2

3.8

3.8

3.8

Land
(Acres)

320

260

234

1*0

1,004
1,004

Estimated Costs

(Thous«"d

Capital
36,207

763

3,502

22.001
62,473
1,685

11,462

9,226

2,541

6,049

4,842

35,805
98,278

Annual 0*H
333

94

454

550
1,431
39

69

474

33

67

356

1,038
2,469

(1)

Cost estimates in third quarter 1989 dollars.

2-47

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TABLE 2-18
SYSTEM ALTERNATIVE 8 < 1 >

f|napnmnt Deacrjptlon

Treatment North and South,
Conveyance to Laka Bradford Road
Plant, T. P. Smith Plant,
and new ME Plant

Laka Bradford Road Plant
Improvement!

T. P. Smith Plant Improvement
and Expanaion from 20.0 mgd

Northeait Plant Conatruction

Collection/Treatment Subtotal

Conveyance from NE Plant
to SE Diapoaal Site

Conveyance from T. P. Smith
Plant to SE Diapoaal Site

Artificial Wetland* at SE
Diapoaal Site

Rapid Infiltration Baaina
at SE Diapoaal Site

Diapoaal Subtotal

Syatam Total

Plow

(mgd)

31.0

4.5

1.3

5.2

5.2

3.8

9.0

9.0

Land
(Acreal

Eetimated Coata
(Thouaand S>

554

450

1,004
1,004

Capital
36,207

763

3,502

22,001
62,473
10,006

2,541

14,006

11,468

38,021
100,494

Annual 0*M

333

94

454

550

1,431
96

33

123

822

1,074
2,505

Coat eatimatea in third quarter 1989 dollara.

2-48

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TABU 2-19
SYSTEM ALTERNATIVE 9 <11

Component Deecrlption

Lake Bradford Road Plant
Improvement*

Flow	Land

tmgd)	(Acres)

4.5

Estimated Coats
(Thousand 5>

Capital	Annual Qtu

763	94

Treatment Dacantralizad	0.25			1,008	9

(Conveyance for Araa
System Traataant)

Area System Treatment

On-lot Systems

Conveyance from T. P. Smith
Plant to SB Disposal Site '''

Southeaat Agricultural Spray
Irrigation (expansion to exist-
ing 22.0 mgd SB Sprayfield)

0.25
6.25
2.5

2.5

469

1,130
93,298
1,672

1,90S

145
921
22

349

Syatea Total

99,779

1# 540

(1) Cost estimates in third quarter 1989 dollara.

Required expansion to handle flows from the Lake Bradford Road (LBR) Treatment Plant (4.5 Wgjjj

entire T.P. Smith (TPS) Treatment Plant (20.0 mgdi i.e., TPS Plant (17.5 mgd) and SW

mgd) - Update I The USBPA understands from the City of Tallahassee that the entire TPS Pl*„^(a*5

rerated to 20.0 from 17.5 mgd on 9/8/89. The total design treatment capacity for the TPS

LBR Plant is therefore 24.5 mgd. The USBPA also understands that the 22.0 mgd design capaoj.ty Qf *n4

City's SB Sprayfield haa been rerated (9/8/89) to 23.25 mgd and the capacity of the Clty,

Sprayfield has been rerated (9/8/89) to 1.25 mgd for a total deeign irrigation capacity of 24,s * 8*

Also, in addition to the rerating of the TPS Plant to 20.0 mgd, the City has more recently <=0^*

7.5 mgd expansion of the plant in January 199 3, so that the total design treatment capacity	*

TPS Plant ia 27.5 mgd. The total design treatment capacity of the expanded TPS Plant (27.5

the LBR Plant (4.5 mgd) ia therefore 32.0 mgd, while the total City sprayfield deaign irti ' *n
-------
^ EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGD)

GOLF
COURSE
SPRAY
IRRIGA* ON
( 3.0 MGD)

y

S ^EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGD)

GOLF
COURSE
SPRAY
IRRIGATION
( 3j0 MGD)

EXPANDED
T P SMITH
PLANT
(27.5 MGD)

EXPANDED
SE AGRICULTURAL
SPRAY IRRIGATION
(29.5 MGD)

ALTERNATIVE

EXPANDED
T P SMITH
PLANT
(27.5 MGD)

SE FOREST
SPRAY IRRIGATION
(7.5 MGD) NEXT
TO EXISTING 2 2 MGD
AGRICULTURAL
SPRAY SITE

ALTERNATIVE 2

^ EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGD)

EXPANDED
T P SMITH
PLANT
(27.5 MGD)

GOLF
COURSE
SPRAY
IRRIGATION
(3.0 MGD)

S EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGD)

SE WETLANDS
AND RIB'S (6.0 MGD)
NEXT TO EXISTING
22 MGD AGRICULTURAL
SPRAY SITE

EXPANDED
TP SMITH
PLANT
(27.5 MGD)

SE WETLANDS
AND RIB'S (9J0 MGD)
NEXT TO EXISTING
22 MGD AGRICULTURAL
SPRAY SITE

ALTERNATIVE 3

ALTERNATIVE 4

LEGEND

EXISTING WASTEWATER TREATMENT FACILITY
EXISTING EFFLUENT DISPOSAL FACILITY
PROPOSED EFFLUENT DISPOSAL FACILITY
. EXISTING CONVEYANCE
	 PROPOSED CONVEYANCE

CENTRALIZED WASTEWATER MANAGEMENT SYSTEM
ALTERNATIVES I THROUGH 4

FIGURE 2-6

-------
^ EXPANDED
CONVEYANCE

IMPROVED

LBR

PLANT

(4. 5 MGD)

NE AGRICULTURAL
SPRAY IRRIGATION
(5.2 MGD)

EXPANDED
T P SMITH
PLANT
(21.3 MGD)

EXPANDED
SE AGRICULTURAL
SPRAY IRRIGATION
(25.8 MGD)

EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGO)

NE
PLANT
(5.2 MGD)

A'f

>X	A SPI

... ! (5.

EXPANDED
TP SMITH
PLANT
(21.3 MGD)

FOREST
SPRAY IRRIGATION
2 MGD)

ALTERNATIVE 5

SE FOREST
SPRAY IRRIGATION
(3.8 MGD) NEXT
TO EXISTING 22 MGD
AGRICULTURAL
SPRAY SITE

ALTERNATIVE 6

NE wetlands

AND RIB'S
(5.2 MGD )

EXPANDED
T P SMITH
PLANT

(21.3 MGD)

SE WETLANDS
AND RIBS (3.8 MGD *
NEXT TO EXISTING
22 MGD AGRICULTURAL
SPRAY SITE

S EXPANDED
CONVEYANCE

IMPROVED
LBR
PLANT
(4.5 MGO) I

NE
PLANT
(5l2 MGO)i

4

»)i I I

EXISTING
1.25 MGO
SWSF

EXPANDEDI
TP SMITH
PLANT
(21.3 MGD)

t=Q

ALTERNATIVE 7

ALTERNATIVE 8

SE WETLANDS
AND RIB S (9.0 MGD)
NEXT TO EXISTING
22 MGD AGRICULTURAL
SPRAY SITE

LEGEND

EXISTING WASTEWATER TREATMENT FACILITY
EXISTING EFFLUENT DISPOSAL FACILITY
PROPOSED EFFLUENT DISPOSAL FACILITY
PROPOSED WASTEWATER TREATMENT FACILITY
EXISTING CONVEYANCE
	 PROPOSED CONVEYANCE

CENTRALIZED WASTEWATER MANAGEMENT SYSTEM
ALTERNATIVES 5 THROUGH 8

FIGJRE 2-7

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TABLE 2-20

SUMMARY OP SYSTEM ALTERNATIVES PROJECT COSTS
AND PRESENT WORTH VALUES11'

ID
1

Alt»rn«ttv»		Plow

Daacrlptlon	(mod)

Traatmant South

o Laka Bradford Road Plant	4.5

o T.P. Smith Plant	7.5

o SE Agricultural Spray	7.5

Irrigation

o Golf Couraa Irrigation	3.0

Traatmant South

o Laka Bradford Road Plant	4.5

o T.P. Saith Plant	7.5

o SE Poraat Spray Irrigation	7.5

o Golf Couraa Irrigation	3.0

Traatmant South

o Laka Bradford Road Plant	4.5

o T.P. Smith Plant	7.5

o SE Artificial Watland	6.0
with RIB*

o Golf Couraa Irrigation	3.0
Traatmant South

o Laka Bradford Road Plant	4.5

o T.P. Smith Plant	7.5

o SE Artificial Watland	9.0
with RIBa

Traatmant North and South

K«»<«i»tad Coata	

Capital Annual 0*M	Praaant Worth'2)

85,706 3,659	119,407

o

Laka Bradford Road Plant

4.5

o

T.P. Smith Plant

1.3

o

HE Plant

5.2

o

NE Agricultural Spray

5.2



Irrigation



o

SE Agricultural spray

3.8



Irrigation



1,410

1,475

670

1,004

2,235
712

92,238 2,998

98,429 3,460

101,436 3,728

99,728 2,483

119,851

130,297

135,773

122,598

2-52

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TABLE 2-20 (Cont'd.)

SUMMARY OP SYSTEM ALTERNATIVES PROJECT COSTS
AND PRESENT WORTH VALUES*1'

Alternative

ID	Deicription

Flow
cad)

Estimated Costs
Capital Annuel 0*M	Preeent Worths'

Treatment North and South

o Lake Bradford Road Plant	4.5

o T. P. Smith Plant	1.3

o NE Plant	5.2

o NE Poreat Spray Irrigation	5.2	2,725

o SE Poreat Spray Irrigation	3.8	747

Treatment North and South

o Lake Bradford Road Plant	4.5

o T. P. Smith Plant	1.3

o HE Plant	5.2

o HE Artificial Wetland	5.2	580

with RIBa

o SE Artificial Wetland	3.8	424

with RIBa

Treatment North and South

o Lake Bradford Road Plant	4.5

o T. P. Smith Plant	1.3

o NE Plant	5.2

o SE Artificial Wetland	9.0	1004

with RIBa

Decentralised

o Lake Bradford Road Plant	4.5

o Killearn Lake Plant	0.2S
Expansion

o On-lot	6.25

o SB Agricultural Spray	2.5	469

Irrigation

117,021 2,045

98,278 2,469

135,856

121,019

100,494 2,505

99,779 1,540

123,566

113,963

I1' Coat eatimatea are in third quarter 1989 dollara.

(2) Assumes an 8.875 percent compound interest rate for a 20 year period. Capital recovery
factor - 0.1085724 and present worth factor » 9.210445.

2-53

-------
and associated environmental protection measures for the four (4) system
alternatives selected for further study (1, 2, 7 and 9) are addressed in more
detail in chapter 3.

The centralized system alternatives require additional collection
conveyance pipelines to supplement the existing lines. The locations of these
pipelines have been designed to follow existing rights-of-way in order to
avoid environmental and cost problems. of the eight (8) centralized
alternatives, four (4) will require construction of the NE Plant. The NE
Plant would allow wastewater generated in northeast Tallahassee to be conveyed
a short distance to the NE Plant. without construction of the NE Plant,
wastewater generated in the northeast area would need to be conveyed via
existing pump stations to the TPS Plant on the southwest side of Tallahassee.
The environmental impacts of the conveyance pipelines necessary for the
selected system alternatives are discussed in greater detail in Chapter 3.
(Update: The USEPA understands from the city of Tallahassee that in the
absence of a NE Plant and under the proposed implementation of Alternative 1,
wastewater generated in northeastern Leon County would initially continue to
be conveyed via existing pump stations to the T.P. Smith Plant on the
southwestern side of Tallahassee. The USEPA understands from the City that
the City's 7.5 mgd expansion to the T.P. Smith Plant was completed in January
1993. Also at the time, a new force main from the northeast routed around the
eastern side of the city of Tallahassee via Capital Circle to the T.P. Smith
plant was completed by the City and was operational in February 1993, although
additional refinements were made thereafter. In the near future (1995-1997),
the City furthermore expects that new additional pump stations would be
required for conveyance.)

The major environmental concerns for all the alternatives are related to
the alternatives' effluent disposal components. Disposal for each of the
alternatives involves either two or three land application sites. Table 2-21
summarizes the sensitive environmental characteristics of each site that were
evaluated to determine the impacts associated with each disposal component.

Any areas found to have longleaf pine-wiregrass plant communities would
require special consideration because the FG&FWFC has identified these
communities to be in *need of protection. Ecological as well as archeological/
historical resources may be impacted. Therefore, an archeological survey
would need to precede any proposed construction so that proper assessment of
known sites and potential new, yet uncovered/unrecorded sites can be realized.
If additional sites not identified in the survey are found during actual
construction, construction should be stopped and the Florida State Historical
preservation Officer (SHPO) contacted. In addition to site avoidance and
proposed project design modification, the evaluation, excavation, and
relocation of certain identified sites may be possible through coordination
with the Florida SHPO.

The permitting guidance outlined for alternatives presented in this
section is very general and is not intended to be used to make final decisions
on the applicability of the NPDES or sludge regulations. site specific
conditions are always important factors in making these determinations.

2.4.3.1 system Alternative 1: Treatment South, SE Agricultural
and Golf Course spray Irrigation

Environmental concerns associated with the construction and
operation of Alternative 1 would mainly be due to the physical expansion of
the existing SE Agricultural Spray Irrigation area, specifically the
associated land conversion and habitat loss impacts. The expansion areas lie
within the cody Scarp sandhills, the Lutterloh Pond closed basin, and the
Woodville Karst Plain, and is adjacent to the St. Marks River Lowlands. These
areas are marked by outstanding-quality, mature cypress and gum swamps and

2-54

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TABLE 2-21

Summary of Environmental characteristics of Effluent Disposal Sites

1 Proposed affluent
I Diapoaal Sitae

Total
Approx.
Acreage

Physiographic
Region

Principla Cloaad
Basin

Quality of Watar
Bodies and
Vatlands

Upland Plant Ccaaunity

Laval of
Recharge for
Ploridan
Aquifer

Wildlife Habitat

1 8ite 1 - Weat of
1 and adjacent to
1 existing SB
1 Bprayfiald

400

Cody Scarp

Sandhills

Lutterloh Pond

Good to High

Fonwr longlaaf pine-
wiregrass sandhill
habitat converted to
aand pina and alaah
pina plantatiooa with
aoderate to low
aaounta of wiragrasa

High

Habitat for Indigo
Snaka, Florida Pina
Snake, Gopher
Tortoise, and Gophar
Prog aigration araa.
Also habitat for
Panhandlo Goldan

1 Bit* 2 - Ult of
I and tdjietnt to
1 exiating SB
1 Sprayfield

1(00

Cody Scarp
Sandhilla with
•eat southern
portion* in tha
Woodville Karat
Plain

Kagle Laka

Turf Pond
Boanett Pood
¦naaroua Onnaaad
Materbodiea

Outstanding
cypross and gum
sma|n and
aarshaa and good
to oatatanding
lakas and ponds

Poraer longlaaf pine-
wiragraaa sandhill
habitat converted to
Band pina and alaah
pina plantatiooa with
¦oderate to low
aaounta of wirvgrass

High

ponds and lakaa ara
habitat for
Panhandlo Meadow
Beauty. Woodstorks
have baan obaarvad
uaing Sita 2 for
rooating and
feeding.

I Bite 3 - m

1 Sprayfield

<500

Tallahaaaee Rod

Bills

Six watarshads

that drain into
Alford tea of
Laka Lafayotta

Poor to

outstanding, 1/3
to 1/2 of
watlanda ham
baan eliminated
and aoit ara
substantially
aaaller than '
indicated on tha
Laon County
k.S.A. napa

Poraar longlaaf pina-
wiregrasa clayhill
habitat convartad to a
aixture of cultivated
crop and pasture, old-
fiald auccaasional
loblolly pine-
ahortlaaf pina foraat
(-2000 acras), natural
oak-pine-hickory
forast (-300 acrea),
natural liva oak
forast, young
auccaaaiooal pinas and
hardwoods and pina
plantations

Low to Bona
with spots
of High

Woodstorks liva in
the lowar Lake
Lafayette'a pure
cypress atanda

Source i nrlmMBta
XaviroaaaDt*

l analysis
1 Special!

based on field visit
¦t for tha I«oa Count;

¦ to tha sitas by 7a
r Public Marks Oaparl

¦ Graana,

taent, Bin ¦¦t ar, 19B

».





-------
marshes; good or outstanding-quality lakes and ponds; flood-prone Karstic
depressions; and good to high-quality wetlands. A rich assortment of fauna
and flora, several species of which are of special concern or endangered, are
known to utilize the region as a cover and food source. Conversion to
intensive agriculture would likely create adverse effects to this sensitive
ecosystem by removing valuable habitat associated with the bottomland forest
systems. Existing functions such as surface water hydrology, sediment
transport and detention, water quality, and native biotic diversity would
likely be impacted by this alternative. It should be noted, however, that
this area is not pristine and is largely composed of managed pine plantations
in the area projected for use« Figures showing wildlife corridors and soils
are shown in Sections 4.4 and 4.5, respectively. • Archeological resources are
described in Sections 2.5.2 and 4.6.1.

The conveyance system necessary for implementation of this
alternative would consist of:

1)	a force main from the TPS Plant eastward along capital
Circle and Old Tram Road to the SB Sprayfield area, and

2)	a primary line along Lake Bradford Road and orange Avenue
with pipelines supplying effluent to fo*r golf courses.

Both lines would be constructed within existing rights-of-way,
hence causing little damage to environmentally-sensitive
be some impacts during construction such as noise.¦	_and

exhaust, but these would be temporary and would cease when construction would
be completed.

The irrigation of sprayfield and golf course areas could
potentially also cause environmentSl problems. on« conc.rn would be human
health concerns relative to the production and of:£-sLt#	jLjSItir

by the spray irrigation sprinkler	=£?£*Ljc.p£J-

contamination problems of the	of concern if effluent

ar "not	Th... tam.n bwlth concrn.

discussed below (Also refer to Section 4.6.2).

Tf aan«rallv documented (Crook, 1990; Asano et il*, 1992) that

It is generally	«tanificant numbers of pathogens and

wastewater treatment methods can remove signii	wastewater However,

non-pathogenic bacteria typically associated with sewage wastewater^ However,

not all may be killed by disinfection. In ^h® "Bh^|Us from a human
viruses, the surviving numbers could Potentially JJJ"JJJ"'b« S?f0ctious.

However f'severalVprecautions#,can betaken to r«duce the

ELri^^sTte containment^TlT^erosois^ and groundwater monitoring.

,h. USEPA -d.r.t.nd. fro. th.	."JuonW.

disinfected in accordance with State vt. Droccga#s a£* the activated
requirements. The City's wastewater	light (.unlight)

¦ludge process, chlorination, and	, ,_nt aDrav irrigation, the City

treatment in the holding ponds. Prior to	17 metals on a monthly

also monitors its effluJnt for 40 Par^te"ind(ToD) ?otal
basi.; monitors for 11 parameters (bi^h«^cal oxygesidJ2Tchloridis, PH,

¦usp«nded solids (TSS), total n^rogen, ti	k basis; and monitors

f«cal coliforme, and other parameters) on a twice a wees

fot the six (6) above parameters on a daily basis,
studi.. h«. .ho», 1

S t b..n di.int.ct.d. Th. di.p.r..l of

2-56

-------
aerosols is also directly related to wind velocities. Other factors which
prolong pathogen viability and increase the distance of aerosol travel are
increased relative humidity, lower temperature, and darkness. studies also
indicate that pathogens tend to survive longer in an aerosol than do the
traditional indicator organisms. However, in general, reasonable protection
of residents neighboring a sprayfield should be possible through the proper
design and implementation of appropriate effluent treatment methods, frequent
effluent monitoring of treated wastewater prior to irrigation, natural
ultraviolet light (sunlight) disinfection, prudent spraying operations, use of
evergreen forested buffer areas along external borders of sprayfields (which
act as a barrier to the off-site migration of spray effluent aerosols and also
reduce wind velocities), use of forested corridors within the general
sprayfield area (which further help to contain aerosols on site), and
groundwater monitoring.

The spray application of wastewater to golf courses and other
public access areas, which would provide greater public exposure than
agricultural or forest sprayfields, requires additional treatment for
suspended solids removal and high-level disinfection under state of Florida
regulations. Compliance with these regulations should greatly reduce the
health risks associated with aerosols at golf courses. irrigation of golf
courses using wastewater effluent is also not. an uncommon practice since 84
golf courses in Florida were being irrigated with wastewater by 1991. In
addition, golf course spray irrigation would require, per FDER stipulation
that an alternate disposal method (e.g., Rapid Infiltration Basin (RIB)
system; alternate sprayfield) be made available as a back-up. The system
alternative costs on Table 2-20 do not include the costs for a back-up system.

Potential public health effects from animal vectors at spray
irrigation sites would be minimized through effluent disinfection. Such
effects could be further minimized through prudent spraying operations that
allow acceptable effluent soil infiltration rates that avoid ponding.

Human health concerns also exist for potential groundwater
contamination of the Floridan Aquifer drinking water source. After
application of the wastewater effluent to land surfaces, the wastewater
infiltrates into the soil and interacts physically and chemically to remove
the potentially harmful constituents not removed during effluent treatment,
it is possible that some of these constituents could move quickly through the
soil (depending on soil characteristics and depth) and into the groundwater
used as a public drinking water source.

The city is conducting an on-site groundwater monitoring program
for its existing effluent sprayfields. Historically, over 60 monitoring wells
have been drilled and tested at the 8E Sprayfield site during interagency
cooperative studies. Although the City has been monitoring wells for some
time, the state of Florida required monitoring via a Groundwater Monitoring
Program by permit condition since November 1, 1984* The city now quarterly
monitors seven (7) compliance wells at the SE sprayfield for six (6)
parameters: NOa (nitrite) and MO, (nitrate) as nitrogen; nitrites; total
Kjeldahl nitrogen; chlorides; dissolved organic carbon (DOC); and fecal
coliforms. Pesticides and herbicides are also monitored annually.

Based on this monitoring program, the USEPA understands from the
city that the city discovered five (5) nitrate-nitrogen groundwater quality
violations in the seven compliance wells at the City's SE Soravfield.
Expected causes of these violations included a faulty well construction
application techniques for additional (non-effluent) fertilizer and oossibly
on-site cattle burial. Overall, four (4) other violatio'ns (aSS fS
nitrate-nitrogen) were monitored in one of the two comnliance well, at the
city's sw sprayfield. Expected* causes for" these violations included the fact
that a stockpile of dewatered sludge was placed near a compliance well" The

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USEPA further understands from the City that the exceedances in these two
wells were reported to the fder by the City as part of their quarterly reports
and that the FDER responded by writing a letter and by discussing some of the
violations with the City. The discussed exceedances involving the faulty
well, additional fertilizer, dewater sludge, and possibly on-site cattle
burial were resolved by constructing a new nearby well and adjusting farming
techniques at the SE Spray field, and by removing the sludge at the SW
Sprayfield, and that monitoring has shown no additional groundwater quality
violations since 1991 for the parameters monitored. As a rule, nutrient
groundwater quality problems can be minimized or prevented.

Aspects of Alternative 1 involving agricultural (animal feed
and/or processed human food only) and golf course spray irrigation methods
would be subject to NPDES permitting if point source storm water discharges to
waters of the United States exist during the construction of the Alternative 1
sites and from the treatment plants treating the spray irrigation effluent.
Pursuant to the existing NPDES permitting program (40 CFR Parts 122 and 124)
and to the "NPDES Permit Application Regulations for Storm Hater Discharges"
(55 PR 47990 dated November 16, 1990), an NPDES permit is required for point
source storm water discharges to waters of the United States from the facility
actually treating domestic wastewater. This provision applies to domestic
wastewater treatment facilities that have design flows or at l***t
The NPDES storm water regulations of November 1®» ' *
point source storm water discharges to waters of the united States from all
construction activities (including the initial clearing, until revegetated, of
spray irrigation sites) disturbing a total of five or_	Jj,J?*

permitted under the NPDES program. The permit application deadline for these

discharges is 90 days prior to commencement of

activities needing NPDES permit coverage can be made through a general permit
recently issued by EPA/Region IV.

fito™ w-f-r noint source discharges to waters of the United States

from the operation (spray irrigation) of	VlandscaDe

land application sites (such as golf courses,	~°^5Vtv	d b!

areas) receiving domestic wastewater treated to the mjUty rjqulwd by

chapter 17-610 P.A.c. for the land application of	. JJJcificallv

required to be covered by NPDES permit", unless the USEPA^specifically
requires a facility to submit an applicat^n on . ca..-by-ca« b«i..
Therefore, no NPDES permit is needed for th ??nr_ M,tar noint source
application sites for the city's proposed	* for HUCh sites) unless

di.ohargw .xi.t to v.t.r. of	"nit*^„r, d.dic«t.d discharge. of

^plicatio^of	on agricultwal^d

exempt from the NPDES permitting pr®9	u afor the city's proposed

CFR Part 122.3(e), so that the operation of such sites for the city s proposea

project would not require an NPDES permit if consistent with 40 CFR 122.3(e).

_ - , » ..	inrav irrigation of wastewater effluent

Included in the proposed p y	application of wastewater

in Alternative 1 is the	* Act requires that the disposal or

sludge, section 405(d) of the clean <£hi? regulatory activity is to be
reuse of sewage sludge be rd*	bated upon technical federal

accomplished through th*_^i^"^ioJ,tabShed federal sludge disposal/reuse
regulatory standards. The UMPA	n.ai.ter at 40 CFR 503 on

¦tandards which were promulgated intJ* ^gg^g^fTomplied with by all
February 19, 1993. in general, these stanaarasnu^ ^ ^ violation of
treatment works treating domestic sewage by # ^i#an Water Act. It is
these standards would be a	disposal/reuse activities would

anticipated that current and ProP°|i®d «^9* u P^i., or through issuance of

*SK5£2l?*2£l«. "th"	porltSn, activity would b. i..u.d by

a "

—-j- ——¦	

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the USEPA/Region IV until program authorization is given to the Stat® of
Florida. Therefore, the newly promulgated federal regulations ar® in addition
to the State of Florida sludge disposal/reuse regulations.

2.4.3.2 System Alternative 2: Treatment South, SE

Forest and Golf course spray irrigation

The environmental concerns associated with Alternative 2 need not
be significant if the existing tree species are utilized as the spray
irrigation forest crops.

The SE Forest Spray Irrigation system would cause an initial
disturbance associated with construction activities related to the buried
irrigation system and to th® r«placsment of existing longlaaf forast stands
with water-tolerant species. Existing forest stands on the SE disposal site
consist primarily of water-tolerant species, sand pine and slash pine (Refer
to Table 2-21). The sand pine, though water-tolerant, does not generate much
biomass. Therefore, replacement of existing trees with fast growing, water-
tolerant species would be beneficial in terms of nutrient uptake; however,
species replacement would be more environmentally disruptive.

After the irrigation system has been installed, effluent would be
applied at a rate compatible with the site's ability to accept water. This
rate would have to be monitored carefully so as not to interfere with the
site's natural ability to transport sediment and overland flow, absorb natural
precipitation, conserve surface soil, assimilate nutrients, and support
healthy, diverse, and native vegetative and animal life.

Th® forest site would be managed by maintaining, harvesting, and
reforesting of fast-growing, water-tolerant forest stands. During periods of
harvest, whether every 10 years in a selective harvest practice, or every 25
years on a clear-cut practice, there would be damage to the site and soil.

The impacts caused by the golf course irrigation disposal method
and the conveyance system would be identical to those described for
Alternative 1 in Section 2.4.3.1.

The need for npdes permitting for the effluent disposal proposed
in Alternative 2 through the forest and golf course spray irrigation method
would be as described in Section 2.4.3.1. The need for sludge permitting
would also be as described in section 2.4.3.1. other federal, state and local
permitting may also be involved for the Alternative 2 disposal methods.

2.4.3.4 system Alternative 3j Treatment South, SE Artificial

(Constructed) Wetlands/RiBs and Golf course Spray
irrigation

Environmental concerns associated with Alternative 3 would be
primarily due to the construction and operation of the SE Artificial
(Constructed) Wetlands with Rapid Infiltration Basins (RiBsi. The
construction and operation of artificial wetlands could be an attractive
alternative because of the relatively small land requirement. For a design
.o£ ,	' r, example, only 370 acres would be necessary. An

additional 300 acres is needed for th® rapid infiltration basins, but th®
total of 670 acres is still far less than the disposal alternatives with
agricultural or forest spray irrigation facilities.

The primary concerns associated with the rapid infiltration basins
are groundwater mounding and contamination, and possible sinkho Information.
The effluent going to these basins will already have been tre^«d hv h«?h th.
treatment plant and the wetlands and therefor/ have received a hiSh SJlll of
treatment, which is greater than secondary levels?	* high Uvel

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The environmental concerns caused by the golf course irrigation
disposal method and the conveyance system would be identical to those
described for Alternative 1 in Section 2.4.3.1.

Effluent disposal proposed in Alternative 3 through the artificial
(constructed) wetlands/RIBs method need not, by itself, be subject to NPDES
permitting if the ribs do not drain as a point source discharge into waters of
the united states. However, pursuant to the existing NPDES permitting program
(40 CFR Parts 122 and 124) and to the "NPDES Permit Application Regulations
for Storm Water Discharges" (55 FR 47990 dated November 16, 1990), an NPDES
permit is required for point source storm water discharges to waters of the
United States from the facility actually treating domestic wastewater as
discussed in Section 2.4.3.1. This provision applies to domestic wastewater
treatment facilities that have design flows of at least 1.0 mgd. storm water
permitting requirements would also apply to any point source storm water
discharges to waters of the United States from the rib site. Also, as
discussed in Section 2.4.3.1, the NPDES storm water regulations of November
16, 1990, also require that point source storm water discharges to waters of
the united States from all construction activities (including the initial
clearing, until revegetated, of spray irrigation sites) disturbing a total of
five or more acres must be permitted under the NPDES program. The permit
application deadline for these discharges is 90 days prior to commencement of
construction. Construction activities needing NPDES permit coverage can be
made through a general permit recently issued by EPA/Region IV.

storm water point source discharges to waters of the United States
from the operation (spray irrigation) of non-agricultural/non-silvicultural
land application sites (such as golf courses proposed for Alternative 3)
receiving domestic wastewater treated to the quality required by chapter
17-610 F.A.c. for the land application of reclaimed water are not required to
be covered by NPDES permits, unless the USEPA specifically requires a facility
to submit an application on a case-by-case basis. Therefore, no NPDES permit
is needed for the operation of such land application sites for the city's
proposed project (if storm water point source discharges exist to waters of
the United States for such sites) unless specifically requested by the USEPA.
However, dedicated discharges of reclaimed water, without land application,
are required to be covered by NPDES permits. It may also be noted that storm
water discharges from the land application of wastewater effluent on
agricultural and silvicultural sites are exempt from the NPDES permitting
program if the sites are consistent with 40 CFR Part 122.3(e), so that the
operation of such sites for the city's proposed project would not require an
NPDES permit if consistent with 40 CFR 122.3(e). Other federal, state and
local permitting may also be involved for the Alternative 3 disposal methods.

Related to the disposal of wastewater effluent through artificial
(constructed) wetlands/RlBs and golf course spray irrigation is the generation
of and land application of wastewater sludge. The need for sludge permitting
would be as described in Section 2.4.3.1.

2.4.3.4 system Alternative 4: Treatment South, SE Artificial
(Constructed) Wetlands/RlBs

Environmental concerns caused by Alternative 4 would be similar in
nature to those caused by Alternative 3, except there is no golf course
irrigation component in Alternative 4. Therefore, the artificial
(constructed) wetlands and ribs are larger to make up the difference and the
land area requirements are increased by approximately 50%. This is important,
considering the habitat of the protected Gopher Frog and Gopher Tortoise.

The treated effluent conveyance system used in this alternative
would require only a force main from the TPS Plant to the SE Disposal Site via
the Capital Circle Southwest and Old Tram Road right-of-way. Construction-
related impacts such as noise, dust, and exhaust would occur along this

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corridor, but no long-term impacts on environmentally sensitive areas are
foreseen.

The need for NPDES permitting for the effluent disposal proposed
in Alternative 4 through the artificial (constructed) wetlands/RIBs method
would be as described in Section 2.4.3.3 without the golf course spray
irrigation aspects. The need for sludge permitting would be as described in
Section 2.4.3.1. Other federal, state and local permitting may also be
involved for the Alternative 4 disposal methods.

2.4.3.5 System Alternative 5: Treatment North and South, NE and
se Agricultural spray irrigation

Environmental concerns associated with Alternative 5 would be due
mainly to the development of the NE and expansion of the se agricultural spray
irrigation facilities. The impacts from the expansion of the SE site have
been discussed in Section 2.4.3.1. The addition of the NE sprayfield area
would create additional problems. First, the clay soils could be expected to
induce spray effluent and any added fertilizers to reach surface waters and
hence affect wetlands, ponds, and streams.

A larger issue regarding the NE site is the extensive high-
quality successional and native forest, which constitutes about 50 percent of
the site's uplands. Any management scheme employed on this site would likely
destroy most or all of the existing plant and animal life. The conversion of
existing forest to agricultural fields would destroy valuable habitat.

Construction of the NE plant would take place in an area adjacent
to the spray site, and would cause impacts much like those noted above.

There would be considerable environmental impact due to the
construction and maintenance of pipelines into and out of the proposed NE
plant. The NE Disposal site for this alternative is located in the Lake
Lafayette Lowlands, which are characterized by wet pine flatwoods,
successional pine-hardwoods, and likely beech-magnolia hammocks. Unless the
proposed pipelines follow existing rights-of-way along Miccosukee Road, Route
90 or Route 10, there would be a substantial amount of vegetation, habitat,
and wetland loss and disturbance. The conveyance from the TPS Plant to the SE
Disposal Site would not present a significant environmental impact since the
pipeline would follow existing rights-of-way.

The need for NPDES permitting for the effluent disposal proposed
in Alternative 5 through the agricultural spray irrigation method would be as
described in section 2.4.3.1 without the golf course spray irrigation aspects.
The need for sludge permitting would also be as described in Section 2.4.3.1.
other federal, state and local permitting may also be involved for the
Alternative 5 disposal method.

2.4.3.6 System Alternative 6: Treatment North and South, NE
and SE Forest Spray irrigation

Implementation of Alternative 6 would create •nvimnmantai
concerns which are similar to Alternative 2, discussed in slctio? 2 4	in

that the disposal method is forest spray irrigation as noJ^H Hn Sili
the NE disposal site has large areas ofwater-tol«knt^r!ew
pine and shortleaf pine forist). Any armil of this .it^ JC? !T« (1°bl?lly
water-tolerant tree specie, wiild have" have the ex!.^™ J° n<* ha™
replaced. Any area found to have longleaf Din^ir.orI« «^L tr**
would require special consideration becauae the FOfcFWFC hae iXlU
habitats to be in need of protection. Jhi.h«. identified these

agricultural spray irrigation because once	, vanta9* over

r2l.tiv.ly llttl. diaturbaac. Vf t " Iot.S	th*r* U

to occur for a given plot at intervals of no' i	tina which ia

ia alao a consonant of Altarnativa 6 and vould cau"	thoM

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noted for the preparation of agricultural irrigation discussed in Section
2.4.3.5.

The environmental impacts due to construction of the treated
effluent conveyance system would be identical to those for Alternative 5
(Section 2.4.3.5).

The need for NPDES permitting for the effluent disposal proposed
in Alternative 6 through the forest spray irrigation method would be as
described in Section 2.4.3.2 without the golf course spray irrigation aspects.
The need for sludge permitting would be as described in Section 2.4.3.l!
Other federal, state and local permitting may also be involved for* the
Alternative 6 disposal method.

2.4.3.7	system Alternative 7: Treatment North and South, NE

and SE Artificial (Constructed) Wetlands/ribs

Alternative 7 would require artificial (constructed) wetlands and
rapid infiltration basins to be constructed in both the SE and the NE sites.
Construction in forested areas would require removal of trees and hence
habitat, but generally, the alternative is an environmentally sound one. The
land area that would be required for this alternative (580 acres in NE and 424
acres in SE) is relatively small.

The treated effluent conveyance .system necessary for
implementation of this alternative would be similar, if not identical, to that
used for Alternatives 5 and 6. The environmental impacts would therefore be
similar, if not identical.

The need for NPDES permitting for the effluent disposal proposed
in Alternative 7 through the artificial (constructed) wetlands/RXBs method
would be as described for in Section 2.4.3.3 without the golf course spray
irrigation aspects. The need for sludge permitting would be as described in
section 2.4.3.1. other federal, state and local permitting may also be
involved for the Alternative 7 disposal methods.

2.4.3.8	system Alternative 8: Treatment North and South,

SE Artificial (Constructed) Wetlands/RlBs

The environmental concerns associated with Alternative 8 would be
identical to Alternative 7, except there would be no wetland development at
the NE site.

The treated effluent conveyance of wastewater in this alternative
would consist of: 1) the force main along Capital Circle, as described in
Alternative 1 and 2) a force main, approximately 12 miles in length, from the
NE Plant to the SE Disposal site. The long-term environmental impacts created
by this construction would be limited to a 1-mile segment immediately south of
the NE Plant and north of Miccosukee Road. The area is characterized by
Loblolly-Shortleaf Pine forest, oak-Pine-Hickory forest, Live oak forest, and
cultivated crop, pasture land, and pine plantation. Construction of the
conveyance pipeline and right-of-way would impact one or more of these
community types by the removal of vegetation and habitat.

The need for NPDES permitting for the effluent disposal proposed
in Alternative 8 through the artificial (constructed) wetlands/RXBs method
would be as described in section 2.4.3.7. The need for sludge permitting
would be as described in section 2.4.3.1. Other federal, state and local
permitting may also be involved for the Alternative 8 disposal methods.

2.4.3.9	system Alternative 91 Decentralization

Environmental concerns caused by Alternative 9, or decentralized
treatment/disposal, would be due to the potential impacts of on-lot systems

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and the expansion of the SE agricultural spray irrigation facility (Refer to
Alternative 1 of Section 2.4.3.1 for impacts caused by theSE facility). It
should be noted, however, that with a decentralized system, the acreage
required for a SE Sprayfield expansion is reduced from 1410 to 469 acres.

Because of the hydraulic connection and proximity between surface
and groundwaters in the area, on-lot systems could cause significant problems
if they fail. Excessive nutrient loads and BOD could enter the aquifer
system. This condition is not easily remedied, and an alternative system
would need to be installed.

The on-lot systems have an advantage in that they at least
temporarily eliminate the need for alternatives which require large land areas
to operate.

The environmental consequences due to the construction of a
conveyance pipeline from the TPS Plant to the SE Disposal Site would be
expected to be minimal. The force main would utilize the existing right-of-
way corridor following Capital Circle Southwest and Old Tram Road. Long-term
impacts are not foreseen.

Effluent disposal proposed in Alternative 9 through the
decentralized (on-lot) system, would not, by itself, require an NPDES permit.
However, such on-lot systems would be supplemented by centralized systems
(expansion of the City's agricultural spray irrigation operation (SE
Sprayfield) and expansion of the Killearn Lakes Plant and the Lake Bradford
Plant). As such, the need for NPDES and sludge permitting for the centralized
aspects of Alternative 9 would be as described in section 2.4.3.1. other
federal, state and local permitting may also be involved for the Alternative 9
disposal methods.

2.4.4 Technical and institutional Feasibility

Technical feasibility of a system alternative includes evaluating the
alternative in terms of installation (or construction) and operation and
maintenance of the alternative facilities. Table 2-22 lists the major
potential installation and operation problems for the recommended components
of the alternative systems.

The feasibility of installing or constructing any of the alternatives
depends on ease of installation or construction, availability of materials,
and availability of manpower experienced in operating and maintaining the
structural facilities associated with each alternative. None of the
alternatives has any severe technical constraint* in terms of installation or
construction. Septic tanks, sewers, extended aeration treatment plants for
area systems, an activated sludge treatment plant, and spray irrigation and
sludge spreading systems are already being utilized within the study area.
The ribs recommended for possible use following artificial (constructed)
wetlands have only been used in the study area on an experimental basis.
However, because this disposal system is similar to a stabilization pond, in
terms of construction and installation, the fact that one has never been
constructed in the study area before cannot be considered a severe technical
constraint. As for artificial (constructed) wetlands, this effluent treatment
method (i.e., treatment subsequent to wastewater treatment plant treatment)
has been successfully used in Europe. Biologically, artificial wetlands
resemble horizontal trickling filters. Although it is a relatively new
wastewater disposal technology in the united States, it has shown increasing
reliability in areas such as nearby Orlando, Florida. The reliability of
constructed wetlands has probably increased even since the (1989) matrix
evaluation for the DEZSS. • The Orlando facility, for example, has been
functional for several years and the Tennessee Valley Authority (TVA) operates
facilities in Kentucky and Alabama, and possibly other areas. Constructed
wetlands also exist in other states such as Mississippi, California and
Maryland (Also refer to Section C-13 entitled "Artificial (Constructed)

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Type of Comment
Interceptor Sewera

Activated Sludge
Treatment of Wastewater

Waatavatar Diapoaal
by Rapid Infiltration

Sludga Treatment

a)	Anaerobic digestion

b)	Vacuum filtration

Sludga Diapoaal by
Landapraading

Haatawatar Diapoaal by
Slow Rata (Spray
Irrigation)

TABLE 2-22

POTHNTIAL INSTALLATION AND OPERATION PROBLSHS
OF SYSTBM COMPONENTS

Concarna with Inatallatlon and Parforaanca

Obtaining righta-of-way prior to inatallation

Anaarobio conditions if wastewater raaaina in a eewer for a long pariod of time

Poaaibla aurfaoa water degradation raaulting free construction-related aoil
aroaion

Disruption of microorganism activity dua to auddaa ahock

Lack of local familiarity with oparation proeaduraa

Hora attantion naadad for proper maintenance of inundation baaina

Parforaanca reliability highly dapandant on physical, chemical and biological
conatituanta found in aoil profile

Parforaanca ii auacaptibla to changaa in loadinga, flowa, and tamparatura

Parforaanca may vary with digeated aludga charactariatica

Uncertainty of predicting rainfall pattarne immediately following
an application of aludge

Parforaanca reliability highly dapandant on phyaical, chemical and
biological conatituanta found in aoil profile

Buried linea for apray irrigation of lands require* a aignificant amount of
excavation and land disturbance

Spraying of treated wastewater requiree apecial care to avoid clogging of
nossl««

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Wetlands" in Appendix C of this FEISS). However, success in the united states
(compared to Europe) is still fairly recent, this treatment method has not
been used in the study area, and City personnel are not familiar with the
technology — particularly when compared to the agricultural spray irrigation
technology. Reliability and acceptance in the United States would be expected
to continue to increase with time and implementation experience. As suggested
above, subsequent to artificial wetland treatment, the treated effluent
discharged from the artificial wetlands must be disposed via an acceptable
disposal method, (e.g., RIBs if feasible and if environmentally appropriate).

Operation and maintenance characteristics have been broken down into the
following criteria: reliability, flexibility, and ease of operation and
maintenance for both the homeowner and the managing entity for public systems.
The reliability of a wastewater management system is reflected in its ability
to consistently achieve and maintain water quality and other environmental
goals for which it is intended with a minimum of operational problems. The
flexibility of an alternative is measured in terms of its capability to adapt
to higher future wastewater flows and its ability to comply with future
changes in water quality goals. For example, an activated sludge system has
the ability to accept higher flows and still achieve the desired treatment
performance. The ease of operation and maintenance of an alternative must be
considered in terms of the amount of attention required to maintain the
desired reliability.

The comparison of the technical feasibility of centralized wastewater
management systems (Alternatives 1 through 8) versus a decentralized
wastewater management system (Alternative 9) is presented in Table 2-23. Area
systems, part of a decentralized system, are subject to many of the problems
associated with the components of a centralized system in addition to
potential management problems which come with being decentralized.

As mentioned before, there are no severe technical constraints
associated with installation or construction of a centralized plant and
collection system or a decentralized system. Care must be taken in the
selection of sites for wastewater disposal, sludge disposal, and on-lot
systems; site selection is of greater concern in a decentralized wastewater
management system.

A centralized system appears to present the least amount of O&M problems
because of the well-defined responsibility and the centralized nature of
collection and treatment systems. Alternative 9 is characterized by a
substantial number of on-lot and area systems dispersed over a large
geographical area, which leads to a decentralized and somewhat less defined
management responsibility.

As shown on Table 2-23, the majority of operation and maintenance
concerns with centralized wastewater management systems deal with the
reliability of the systems under uncertain conditions. For example, in the
activated sludge treatment of wastewater, the microorganism activity can be
disrupted by sudden, shock loadings of flows entering aeration basins. Also
in the landspreading of sludge or spray irrigation of treated effluent, an
unexpected heavy rain immediately following a land application effort may
cause excessive runoff. These problems can be managed, however, by providing
and maintaining a well-trained staff of operation and maintenance personnel.

Bana9«>»ent under Alternative 9, Decentralization, leaves the
responsibility for proper operation of disposal systems to individual home
ovna":^Jn Z i improve the reliability of a decentralized system, the
possibility of a Tallahassee-Leon County wastewater management agency, similar
to the jointly operated Tallahassee-Leon County Planning Department, should be

JiHII	r**Pon«i*>ility for the management of

these on-lot and area systems and could have a variety of functions:

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TABLE 2-23

SUMMARY OF THE TECHNICAL FEASIBILITY OF CENTRALIZED
VS. DECENTRALIZED SYSTEMS

Installation and
Construction

Operation and
Maintenance
(04M)

Centralised Plant
and Collection System

Expertise is available.

Terrain would not be a
problem.

No severe technical
constraints.

Reliability good if well
trained staff aaintained.

Flexibility, in a well-
designed systsm.

System may possibly be
complex and difficult
to operate if unfamiliar
with operation.

On-Let-. By t-»m» ( 2 )

o	Expertise ia available.

o	Attention to eite characteristics

necessary)

sites or systems may

require soae modification.

o	Reliability may be a

problem particularly
with individual respon-
sibility for each systsm.

o	Flexibility problems

possible in that the
syetems must be tailored
to local conditions.

Simple system to
operate and maintain.

System Alternatives 1 through S.
'^' System Alternative 9•

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•	Inventory and review of existing alternative systems.

•	Planning. including evaluation of alternative systems for
individual communities, and guidelines for site evaluation, design
and installation.

•	involvement with operation and maintenance such as homeowner
notification and approval of maintenance experts.

•	Financing clearinghouse.

•	Water quality monitoring.

•	Public education.

•	coordination with related programs.

•	stockpiling of replacement parts.

From a planning point of view, the decentralized system has less
flexibility due to limitations of soils within parts of the study area. In
addition, it is thoroughly documented that retrofitting of houses to a
centralized system often occurs as development density increases. Centralized
alternatives can be tailored to the needs of the community, whereas the
decentralized alternative is tailored around local conditions. The use of
area systems in the decentralized system will incre.ase its flexibility for
planning significantly.

in comparing the operating and maintenance characteristics of the
alternative systems, it may seem that wastewater treatment plants are more
difficult to operate and maintain than a less complex on-lot or area system.
However, the individual homeowner has more responsibility in the maintenance
of a septic tank, unless the system is taken over and maintained by a managing
agency. Thus, it would probably be easier to operate and maintain a
centralized sewer system and treatment plant, or plants, than the on-lot
systems of each customer.

2.4.5 imalamentabilitv and Environmental Protection Measures

The primary stages of a wastewater management project include:

•	Planning and design.

•	Construction.

•	Operation and maintenance.

•	Public acceptance.

Within each of these stages, measures can be incorporated which mitigate
adverse impacts or enhance beneficial impacts. Environmental protection
measures are often financially justifiable and are considered
more essential than enhancement measures in terms of implementing an
acceptable alternative. This section summarizes appropriate implementation
procedures and how environmental protection measures can be inserted into the
procedures. One measure that applies to all construction activities is to
minimize the disturbance at all sites to reduce soil erosion and destruction
of vegetation and animal habitats.

2.4.5.1 conveyance Facilities

.	planning, design and construction procedure for the

interceptors in conveyance systems should include the following to minimize
the adverse impacts of their construction!

• Transit surveys of corridor routes.

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•	Planning measures and restrictive construction techniques to
minimize impacts of interceptor construction particularly at
stream crossings.

•	Designing interceptors and environmental protection measures
including erosion and stormwater runoff control techniques.

•	Securing contractor services.

2.4.5.2	Wastewater Disposal Facilities

Table 2-24 summarizes the evaluation of land disposal techniques
for implementability. The components were analyzed to verify their viability
based on implementability and any potential environmental protection measures.
The following is a list of components that have been identified as non-viable
alternatives or "conditionally" viable alternatives along with the condition
that eliminates them from further evaluation or imposes a condition for
successful implementation and operation:

Implementation of any of the land application disposal components
requires a soil survey and site layout during the planning and design process.
This would be most extensive for disposal sites in the Northeast service area
since portions of the Southeast site have already been utilized for disposal.
The site layout procedure would need to include planning of buffer zones and
runoff controls such as diversions or storage basins. It is recommended that
soil surveys be periodically undertaken during the operations of any
implemented facility.

2.4.5.3	On-Lot Treatment and Disposal Facilities

Also considered as a part of the alternatives' implementability
analysis is the need to "correct" failing on-lot systems documented by the
LCPH. For system alternatives recommending centralized collection and
treatment, many on-lot and some area systems would be replaced with
connections to the central system. Any remaining failing systems would need
to undergo remedial action. In some cases, this remedial action would involve
replacing failing septic tanks/drainfields with connections to area systems.
Table 2-25 summarizes potential failure types and corrective actions for a
typical septic tank/soil absorption field system.

For all on-lot systems, environmental protection measures can
include the following:

•	Development of a management group or other type of
association to oversee all on-site system activities.

•	Field tests of soils, permeability and other parameters for
each lot that is to have an on-lot system.

•	standardization of practices for firms that install on-lot
systems.

•	Regular inspection and maintenance of on-lot systems by a
regulatory agency such as the LCPH.

According to the Leon County public Health Unit (LCPHU), the
successful operation of septic tank drainfields in the study area is a
function of available soil storage above a confining layer and the capacity of
the soil to move water. Accordingly, percolation tests and the measuring of
water table elevations before development may be misleading for determining
the suitability of areas to accommodate drainfields. The need exists to
develop a more accurate methodology.

2-68

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TABLE 2-24

WASTEWATER LAND DISPOSAL TBCBNIQUSS
IMPLEMENT ABILITY
ADVANTAGES AND DISADVANTAGES

ID	Daaeg^^t^oQ

D3, D4 Foreat Spray Irrigation

o Producaa a marketable product o
including construction luabar,
traa wood chip*, and pulp and
papar.

o laa good nitrogen-coneuaption
potential.

o

o Conaarvaa groundwater aourcaa.

o Laaa land grubbing/toil arosion/
global warning potential

Disadvantage
Requires ccoaitaent of larga land

o Raquiraa apaoial water-tolerant
traa apeoiea.

Buffer (onaa naadad for public
acceptance.

Dl, D2 Agricultural Spray
Irrigation

o Producaa a marketable foddar
crop.

o Baa good nitrogen-conauaption
potential.

o Conaarvaa groundwatar aourcaa.

o High oparational coata to prapara
land, plant, and harveat.

o Buffar aonaa naadad for public
haalth protaction.

o Raquiraa ccomitnent of larga land
azeaa.

•oil eroaion/global warming
paitantial dua to land
clearing and grubbing

M, D7,
DS

Oolf Courae Irrigation o

Nutriant value of wastewater
aay leaeen fertiliser
application.

o conaarvaa groundwater aourcaa.

Raquiraa high quality affluent to
prevent public health riaka.

May require Low preeeure
apray nosslee pointed downward to
¦iniaiae aeroaol drift (although
high-level effluent diainfeetion
ahould help alleviate aeroaol
concern).

DS	irrigation of Ornamental

Gardena

Nutriant value of waatawater
nay laaaen fertilizer
application.

o Conaarvaa groundwater aourcea.

Reatriction of (praying during
windy daya.

Raquiraa high quality affluent to

Pravent public health riaka.

Reclaimed water ia known to have
adveraa affeeta on aoma vegetation
(a.g., aaalaaa and aoaw tree
apaciea).

o Nay require apaoial low preaaure
spray noaalea pointed downward to
minimise aeroaol drift (although
high-level effluent diainfeetion
ahould help alleviate aeroaol
conoarn).

o Reatriction of apraying during
windy daya.

2-69

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TABLE 2-24 (Cont'd.)

WASTEWATER LAND DISPOSAL TECHNIQUES
IMPLEMENT ABILITY
ADVANTAGES AMD DISADVANTAGES

ID

D9

D10

Description

Advantage

Power Lin* Right-of-Way o Conserves groundwater aourcaa.
Irrigation

Sludge Diapoaal Fiald
Application

o Hinimal ait* preparation.

Disadvantage

° Hill raault in higher operational
coata due to increaaed frequency
of mowing irrigated areaa.

o Requirea mora diatribution pipe

o Buffer lone needed for public
health protection.

o Appropriate groundwater monitoring
required to determine extent of
contaminant leaching.

o Inundation baaina muat ba main-
tained to break-up aoil clogging
conditiona.

Oil,
D12

Rapid Infiltration
Basins

o Reduced area requirements

o Repleniahea groundwater
auppliea over time.

o Required nitrogen control may add
to treatment coat.

o Increaaed poaaibility of sinkhole
formation.

D13	Landscape Irrigation

and Percolation Ponda

o Raplacea exiating and future
withdrawal of groundwater.

o Extensive groundwater monitoring
required to determine extent of
contaainant leaching.

o Requirea high quality effluent to
prevent public health riaka.

o Poaaible public reaiatance to have
treated waatawater applied to
'your backyard."

D1S

Deep-Well Injection

o Reduced area requirementa.

o Extensive groundwater monitoring
required to determine extent of
contaminanta leaching.

o Requirea eatabliahment of a pilot
program to determine economic
feaaibility.

D16, Artificial (Constructed) o Reduced area requirements.
°17	Wetlanda	o Have been successfully used

in Europe.

o Require disposal of discharge which
would involve an NPDES permit if
diecharged into watera of the United
Statee.

2-70

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TABLE 2-24 (Cont'd.)

WASTEWATER LAND DISPOSAL TECHNIQUES
IMPLEMEMTABILIT*
ADVANTAGES AMD DISADVANTAGES

ID

Description

Advantage

Diaadvantaae

o A functional facility exiate
in naarby Orlando, rlorIda.

o Require laaa land araa than
spray irrigation fialds.

o May raquira eetabliahment of «.

pilot program to determine actua 1
treatment afficianciaa in a given
cliaata locals.

o Buffar ions naadad for public
haalth protection.

o Suceaaa in tha Unitsd Stataa
atill fairly recent.

T4

Soil Absorption Fialds
and Sand Mounds

Easy to construct.

o Can become clogged if not
periodically maintained.

o Requires commitment of large

Notei D5 and D14 do not include land disposal techniques.

Component

D14 - Surface Water Diacharge of
Plant Effluent

D15 - Deep Nell Injection

Dl, D2, D3, 04, D6, D7, DS, D»,
and D13

condition

FDER haa claaaified tha Ochloclconee
and St. Marke Rivera aa "Outstanding
Florida Water", thereby iapoaing a aaro
affluent limitation.

FDER requires information on the location

of a saline formation to receive the effluent

and tha availability of reaaonable tranamiaaivitia

Application ratea for theae alow rate
proceeaea must be carefully calculated
and maintained to avoid ponding and
groundwater contamination. Walls would
need to be inatalled for oontinuoue
monitoring.

2-71

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TABLE 2-25

FAILURES AND REMEDIAL ACTIONS
ON-LOT SYSTEMS I1)

Tvpa of Pailura	R—dial Action

Ovarloadad absorption timid;	o	Incraaaa absorption

¦aptic tank affluent braaks

through ground surfaca	°	Flow raduction aaaauras

o	Eliminate elaar watar discharge*

o Oxidiza clogging sat; pump out
and rapair or raplaca aaptic tank

o Mors frequent maintenance

o Dosing

o Modification of aita or ayetemi
ragrading/filling/alternate
ayetem

Insufficient renovation by
aoil absorption field

o Nodificatioii of aita or ayataai
filling/altarnata system

Intarcapt flew to groundwatar by
aubaurfaca drainaga

Remedial action for failing on-lot ayataaa alao includaa contacting
to a centralised or area ayataa.

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2.4.5.4 Public Acceptance

Public acceptance of wastewater management alternatives will be closely
related to the coats and inconvenience to homeowners and related to public
health implications.

The probable reaction of specific groups affected by each alternative
may be suggested by examining the particular interests of each group. For
example, commercial owners, including apartment and office building owners,
would be likely to favor alternatives which remove the responsibility for
wastewater disposal from them and place it with a public agency. Cost would
probably be a secondary consideration to relief from wastewater treatment
problems. Owners of existing package treatment plants would be likely to
favor alternatives that will leave their operations intact, while not favoring
those alternatives that would curtail their operation. Landowners with
interest in residential, commercial, or industrial development would favor the
alternatives which most greatly facilitate such development.

A dsepa public hearing for the Draft EIS supplement (DEISS) was held on
August 9, 1990 at the Tallahassee City commission chambers, Tallahassee,
Florida. The usepa hosted the public hearing and received comments from eight
different speakers. Public participation is further detailed in sections
5.3*1 and 5.3.2.

2.4.6 System Alternatives Selected for Detailed Evaluation

Due to the nature of this study, in that there exists a wide variety of
wastewater management components, four of the nine considered system
alternatives were selected for more detailed evaluation in the Exs Supplement.
The detailed evaluation includes an estimation of annual costs to the users.
Also included is a detailed environmental evaluation that addresses both
primary and secondary impacts of the specific system alternatives.

The system alternatives consist of eight <8) centralized alternatives
and one (1) decentralized alternative. Because the decentralized system,
Alternative 9, is similar to the 1983 EIS preferred alternative ("Ho-rederal-
Action") and because it has the lowest calculated present worth, it was
selected as one of the four (4) alternatives to undergo detailed evaluation in
the EIS supplement. The centralized alternatives of the EIS supplement would
also be No-rederal-Action alternatives provided local funds, i.e., no federal
funds, were used.

The selection of the three (3) centralized system alternatives for
further Eis consideration is based on the evaluation and screening process
presented in sections 2.4.2 through 2.4.5. Below is a brief description of
the screening as it applies to each centralized system alternative
(Alternatives 1-8). Those selected were system Alternatives 1, 2, and 7.

2.4.6.1 System Alternative It Treatment south, se Agricultural
and Golf course Spray Irrigation

*	This system alternative i. one of the alternatives selected for

further EIS Supplement consideration, it has the lowest capital costs of all

alternatives and the lowest present worth value of all centralized

alternatives. Environmental impacts, though significant are minimizedbecause

the spray irrigation expansion includes areas adjacent to e*i.tina

successful, city-operated sprayfields. oolf courses would be irriqated only at

specified times of the day when public exoosure e«n

Implementability is also very high because the ty^Tof spray irrigati^n^t the

SE sprayfield expansion site would be an extension	, *?!!!,

agricultural operation and the golf course irrigation would hi

the existing irrigation system.	irrigation would be integrated with

2-73

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2.4.6.2	System Alternative 2t Treatment South, SE Forest and
Golf course spray irrigation

This system, which is a variation of Alternative 1, is one of the
selected alternatives. It has the second lowest capital costs of all
alternatives and the second lowest present worth of all centralized
alternatives. The forest spray irrigation expansion includes forest areas
near the existing, successfully-operated, agricultural sprayfields. This
alternative also includes golf courses, which would be irrigated only at
specified times of the day when public exposure can be minimized,
implementability is lower than System Alternative 1 because operating a forest
spray irrigation system, including harvesting is new to the operators of the
existing, adjacent agricultural operation and the buried, spray irrigation
system requires special construction. As is the case for System Alternative
1, the golf course irrigation component would be integrated with the existing
irrigation system.

2.4.6.3	System Alternative 3s Treatment South, SE Artificial
wetlands/ribs and Golf course Spray Irrigation

This system is not an alternative selected for further study. It
has the third lowest capital costs, as does Alternative 7, but has a slightly
higher operation and maintenance cost, which increases its present worth
value. It is different from system Alternative 7 only in that it treats and
disposes the wastewater in the southeast areas and includes golf course
irrigation. Since selected Alternatives 1 and 2 already address siting all
wastewater management facilities in the south and using the golf courses, it
was determined that this alternative not be included.

2.4.6.4	System Alternative 4: Treatment South, SE Artificial
(Constructed) wetlands/RIBs

This alternative is not a selected alternative. It has the second
highest capital costs and present worth value for all alternatives. It is a
variation of Alternative 3 in that all treated effluent would be handled by
artificial wetlands and RIBs adjacent to the SE sprayfield.

2.4.6.5	System Alternative 5: Treatment North and South, NE
and SE Agricultural Spray Irrigation

This alternative is not a selected alternative. It has the fifth
lowest capital costs and present worth value for all alternatives. Implement-
ability is a problem because 1) the inconsistent soil characteristics in the
NE require special design of the irrigation system to avoid adverse
environmental impacts and 2) the prevalence of sensitive wetlands in the NE
makes the use of spray irrigation a potential adverse environmental impact.

2.4.6.6	System Alternative 6: Treatment North and South, NE and
SE Forest Spray irrigation

This alternative is not a selected alternative. it has the
highest capital cost and present worth value of all alternatives, implement-
ability is a problem because 1) the inconsistent soil characteristics in the
NE require special design of the irrigation system to avoid adverse environ-
mental impacts, 2) the prevalence of sensitive wetlands in the NE makes the
use of spray irrigation a potential adverse environmental impact, and 3) the
operation of the forest spray irrigation system is new to the operators of the
existing agricultural operation.

2.4.6.7	system Alternative 7: Treatment North and South, NE and
SE Artificial (Constructed) Wetlands/RlBs

This alternative is a selected alternative. It has the third
lowest capital costs of all alternatives, as does Alternative 3, but has a

2-74

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slightly lower operation and maintenance coat, which results in the third
lowest present worth value for a centralized system. It is also included as
one of the selected alternatives in order to include the detailed evaluation
of a system with North and South wastewater Management Sites which results in
having the wastewater managed near the source. The use of artificial
(constructed) wetlands as a wastewater treatment technology has been
successful in Europe but is still a relatively new technology in the United
States. The environmental impacts of constructed wetlands are low because of
the inclusion of liners to be used in the wetland design and because of the
relatively small land area requirements. Implementability can be expected to
involve some start-up problems; however, implementability was overall
considered to be the same as for the spray irrigation alternatives and can be
expected to improve with time and experience, constructed wetlands have shown
increasing reliability in the United States (e.g., Orlando, Florida facility)
and reliability has probably increased even since the FEISS preparation matrix
analyses (1989). However, success in the United states (compared to Europe)
is still fairly recent, the disposal method has not been used in the study
area, and city personnel are not familiar with the technology — particularlv
when compared to the agricultural spray irrigation technology. Reliabii^^
was therefore considered less than for spray irrigation'alternatives, but
be expected to increase with time and experience. The discharge from the
artificial wetlands would be disposed of through RlBs.

2.4.6.8	System Alternative 8: Treatment North and south, s&
Artificial (Construeted) Wetlands/RlBs

This alternative is not a selected alternative. It has the Coucth
highest capital costs and present worth value for all alternatives.	**

2.4.6.9	Selected System Alternatives with Flow Reduction

Table 2-26 summarizes the cost savings that could be realiz^^
the flow reduction measures described in Section 2.2.4 were instituted.
flow reductions do not affect all components of a system alternati*. *
Unaffected Components include the upgrading of the LBR Plant and the diip^ • •
components handling the LBR Plant's effluent (golf course irrigati0r.*^-
Generally, reducing the flow from 30.97 mgd to 29.75 mgd, which is a 1*
decrease, generates an average decrease of 14% in capital costs, 18% in antiu
OiM costs, and 15% in present worth costs.	U*1

2.5 AFFSCTBD ENVIRONMENT

Section 2.5 is a modification of the "Affected Environment" ¦*ct-1
presented in the USEPA 1983 EIS (USEPA, 1983), for which the present EI&
supplement. As such, considerable portions of the 1983 EIS were excerpt^^* a
edited and included in Section 2.5; some new material was also add °c
statistics primarily relate to the 1983 EIS.	.

2.5.1 Description of the study Area

Tallahassee, Leon County, is located in northwestern Florida. The 0.
serves as both the state capital and county seat. The majority oj
county's population is concentrated within Tallahassee and its inm*^ *
environs. Most urbanization has occurred north and east of the city.
remaining land area is comprised of natural and planted woodlands and
and contains scattered residential development.

The EIS supplement addresses direct and indirect impacts of wastes
management alternatives for the study area for a 20-year planning period
through 2010). it is necessary to document the existing natural and	9q

environments so that an assessment of the primary and secondary
alternative actions can be made, and environmental protection measures
recommended.

2-75

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TABLE 2-26

SUMMARY Or COSTS WITH AMD WITHOUT PLOW
REDUCTION MEASURES FOR THE POUR SYSTEM
ALTERNATIVES SELECTED rOR PURTUR CONSIDERATION
(ESTIMATED COSTS IN THOUSANDS %) 

WITHOUT PLOW REDUCTION

Annual	Praaant

Land Capital OfcH	Worth
l£S£SSX S8S£i Cojt*

1,410 85,706 3,659	119,407

1,475 92,238 2,998 119,851

1,004 98,278 2,469 121,019

469 98,771 1,531 112,872

WITH FLOW REDUCTION*3>

Annual Praaant
Land Capital OCM Worth

<»cr»a> £S£tl C9»MviV»*(al

996
<«%)

74,488 2,744
(13t) (25*)

99,761
(1«%)

1,042

(2»l)

79,158 2,280
(141) (24|)

100,158
(1<»)

870
(131)

8C,047 2,144
(12*) (13|)

105,794
(13*)

469
(0»)

82,184

<17»)

1,340
(121)

94,526
(1<«)

<1) Coat aatimataa ara In third quartar 1989 dollara.

<2' Aaaumaa an 8.875 parcant ccapound intaraat rata for a 20 year period.

Capital racovary factor ¦ 0.1085724 and praaant worth factor - 9.210445.

(3) Parcant reduction ia tha value in bracket!.

2-76

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2.5.2 Existing Natural Environment

Leon County is located 20 miles from the Gulf of Mexico and has a mild
and moist climate that is characteristic of the Gulf States. The average
year-round temperature in Tallahassee is 68° F (20° C) and has varied between
65° F (18.3° C) and 71° F (21.6° C). The average yearly rainfall is about 61
inches (154.9 cm) with variations from as low as 30.98 inches (78.7 cm) to
104.18 inches (264.6 cm). Prevailing winds average 7.7 miles per hour. They
are from a southerly direction in the spring and summer and shift toward a
more northerly direction near the end of the year.

No major odor producers are identified within the boundaries of the 1983
EIS study area. A few potential sources of odor, such as sewage treatment
plants and light industry exist. According to the fder, no major violations
of ambient air quality standards have been reported during the 1983 EIS time-
frame and air quality in the study area has been good. The primary noise
generators in the study area are the Tallahassee Municipal Airport, railroad
corridors, and Interstate 10, U.S. 319, U.S. 90, and U.S. 27.

Three major physiographic divisions are recognized in Leon County: 1)
the Northern Highlands, 2) the Gulf Coastal Lowlands, and 3) The River Valley
Lowlands (See Figure 2—8 which delineates the physiographic subdivisions
including Karstic characteristics). Development in the study area has taken
place mainly in the Northern Highlands, which is projected as the major future
growth area, and to a lesser degree in the Gulf coastal Lowlands, subsurface
geological formations in the study area include the Miccosukee and the
Hawthorn Formations in northern Leon County, the St. Marks Formation and
Sewanee Limestone in southeast Leon County, and the Jackson Bluff Formation in
southwest Leon County.

About 25 percent of the land in the study area has slopes between one
and four percent. The remainder of the County has slopes exceeding four
percent in areas characterized by gently rolling topography. slopfs may
exceed 10 to 15 percent in some areas along drainage ways.

Based on the -General Soil Map" for Leon County in the 1981 soil survey
Leon County is dominated by three soil associations: the Oranaib^Jl
Lucy-Norfolk association in the northern part of Leon Countv
Kershaw-ortega-Alpin and the Dorovan-Talquin- chipley associations in Ihl
southern part of Leon County. The Orangeburg-Lucy-Lrfolk Boila Jkd Si
Kershaw-ortega-Alpin soils are generally well-drained whn„	«

Talquin-Chipley soils are generally not well-drained. Specifically the°1981
soil survey classifies the Orangeburg-Lucy- Norfolk soila »a «„L'i ^ . i
soils- and the Kershaw-ortega-Alpin soils as -exSttlvelv
moderately well drained soils," while the Dorovan-Talauin-chinl=
considered "somewhat poorly drained to very poorly drained ao?
well-drained soil associations, the depths of theseaaJdv	H *5%*"°

significantly: the Orangeburg-Lucy-Norfolk soils	*ciationsdiffer

depths with loam below, compared to sandy 20-40 inches deetf with i°n .2J"inch
are loamy throughout (Note: "loam" is a soil tvn«	j loam below or

soil Survey as* a mix of clay (7-27%), 8ilt	in„th" c^81

particles.) By contrast, the Kershaw-ortega-Alpin soils Irf	I on

inch., or aore, with >« having icmy lay.r. (UbSum,belov^*54nchVp°th"

absorption field.fVSl'e'u^^the^m'soil"survey"001"1"?1* l°r 8*ptic tanlt
•oil feature.- of exi.tin9 .oil ty~. °	<** "".trictive

Norfolk soil types are classified as "mod	Orangeburg, Lucy and

"moderate: wetness," with "moderate" beina	^ percs slowly" and/or

properties for th^ given activity. The Jfr-w" ^Ving u°f^orable soil
-slight" which is defined as .oil prooertX* *! B°\}B	classified as

activity. oretega and Alpin soils are classified	avorable for the

with -severe" being defined as soil oroDertiit « severes P°°r filter,"
activity. The Dorovan, Tallin and chipley''.oil.	,'h*

2-77

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, X

LAKE U
!AHONlA

MICCOSUKEE

L Ah I 1/?
\BRADfOftU,

VLAKE ' ,
MUNSON•

WOODVILLE

I			 MinLttrv	GANNETT FLEMING ENVIRONMENTAL ENGINEERS , INC.

00 I	SOURCE* U.S. GEOLOGICAL SURVEY	harrisburg , Pennsylvania	February , 1991

LEGEND

GEORGIA

J

TALLAHASSEE HILLS
I	1 LAKE IAMONIA BASIN

U~- — 1 LAKE JACKSON BASIN

lake lafayette basin
LAKE MICCOSUKEE BASIN

D

APALACHICOLA COASTAL LOWLANDS
] OKEFENOKEE DUNES
WOODVILLE KARST PLAIN
Y///A LAKE MUNSON HILLS
f~ ""1 WAKULLA SAND HILLS



3

OCHLOCKONEE RIVER VALLEY LOWLANDS
ST MARKS RIVER VALLEY LOWLANDS

LIBERTY
COUNTY

GADSDEN
COUNTY



5^

WAKULLA

COUNTi

LAKE

MICCOSUKEE

JEFFERSON
COUNTY

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT

PHYSIOGRAPHIC SUBDIVISIONS

SCALE IN MILES

-------
wetness" or "severe: floods, wetness." These classifications indicate that
only the Kershaw soils have properties favorable for septic tank absorption
field infiltration while the others do not adequately drain or drain too well
and therefore do not provide proper filtration (i.e., adsorption of inorganics
(metals), microbes, etc.). Leon County therefore appears to be a mix of soil
types with "slight," "moderate" or "severe" classifications regarding the
suitability for septic tank activity. The preliminary 1988 Leon County MW&SSP
also addresses the issue of soil suitability for septic tanks within Leon
County.

Five bodies of water in the study area can be considered large lakes:
Iamonia, Jackson, Lafayette, Miccosukee and Talquin. Each lake occupies an
ancient stream valley in the Tallahassee Red Hills and has a direct flow
connection with the limestone aquifer via one or more sinkholes. This allows
the water level of the lakes to fluctuate greatly even to the point in varying
diversity and density of plants and animals in the area surrounding the lakes.

There are two major rivers associated with Leon County, the ochlocknee
which forms the western border of the county and the St. Harks found in the
southeastern portion of the County. Leon County has many relatively permanent
lakes and ponds that are smaller that the five large lakes. Some of these are
Moon Lake, silver Lake, Eagle Lake, Lake Munson, Orchard Pond, Lake Bradford,
the Cascades, Dog Pond, Dog Lake, Lake Hall, and Lake Ella. In the Woodville
Karat Plain there exist a number of open sink ponds, some examples being
Gopher sink and Dismal Sink. As a result of isolation from one another, these
ponds formed their own unique ecosystem. Many small bodies of water in Leon
County are called ephemeral ponds because they tend to dry up.

Leon County has only a few marshes confined to the edges of the larger
lakes. Branch or creek swamps in this region occur along fourth or fifth
order tributaries. River swamps occur along the St. Marks and Ochlokonee
Rivers in rich broadleaf woodlands that periodically become inundated by high
river waters.

The groundwater reservoir in Leon County consists of a sequence of
limestones and dolomites. The saturated portion of the overlying sands,
clays, and silts is also utilized in some localities. The limestone and
dolomite section is named for Floridan Aquifer and is the principle source of
groundwater in Leon county. The overlying sands, silts, and clays comprise
the Floridan Aquiclude and confine the water in the Floridan Aquifer under
artesian pressure. Some beds in the Floridan Aquiclude yield small supplies
of groundwater and are called water table aquifers.

The exploitation of mineral commodities in Leon County has not been
conducted on a large scale, except for groundwater. The only local mineral
commodity that serves a commercial market is quartz sand. Deposits of clay
are known to exist in the county, but their extent and quality are not of
commercial value. Sandy limestone is relatively near the surface in the
southeast portion of the County, but impurities prevent its use in the road
building industry (Florida Geological Survey, 1961).

The majority of the water obtained from wells in the Tallahassee area is
of good quality without color, odor, or objectionable taste and relatively low
in dissolved solids and hardness. The only parameter which shows a few high
readings is iron. chlorination is the only treatment process required prior
to distribution.

Aquatic systems in the Tallahassee area can be categorized as two types:
lentic (standing water systems) which include^ ponds, lakes and swamps, and
lotic (flowing water) systems are the predominant aquatic type within the
Tallahassee area.

In the Environmental Monitoring Program (EMP) in the 1983 Eis, aquatic
faunal and floral components were studied with the purpose of defining

2-79

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existing water quality conditions within the study area. These studies
indicate that the aquatic systems of the study area are currently suffering
from degraded water quality. While the problems are widespread, there are
indications that there is a direct relationship to non-point and point
pollution sources. The Lake Munson system seems to be in the worst condition.

The classification of the terrestrial vegetation was developed through a
series of studies to provide a detailed mapping effort. The 201 Study, 208
study (City of Tallahassee, 1977), 208 study (Tallahassee-Leon County Planning
Department, 1978), and the EIS EMP-Segment II (USEPA 1980) activities have all
addressed vegetation.

The definition and description of the wildlife in Leon County have been
much less sophisticated than that of the vegetation. The level of effort
involved has generally been restricted to species lists. This effort has been
extended to habitat/wildlife associations only for protected or sensitive
species, and Florida species of special concern. Table 2-27 provides the
status of protected plants and animals which may occur in the study area.

EIS supplement field investigations (January 23, 1991) showed that
several protected animals are likely to occur within some of the potential
sprayfield areas. Active and abandoned Gopher Tortoise burrows were observed
at the Eastern Expansion area (Alternative 1) of the existing SE sprayfield.
Abandoned burrows can be used by Gopher Frogs and the Florida Pine Snake. In
the southern sprayfield sites, proper habitat conditions are present for the
occurrence of the Gophef Frog, Indigo Snake, Gopher Tortoise and Florida Pine
snake. Wiregrass, while not legally protected, was also found on site.

Wiregrass acts to carry fire which iB vital in Longleaf pine
habitat. The area is also habitat for the Panhandle Golden Aster and the
Panhandle Meadow Beauty. (See Table 2-27 for protected status listings for
local flora and fauna.)

A number of ecosystems have been identified as being vulnerable to
impacts of wastewater management systems or development, or as providing
habitat for threatened and endangered species. The ecosystems may be grouped
in the following categories: lakes, wetlands, aquatic-subterranean
ecosystems, habitats for protected species, steepheads and other ravines, and
floodplains.

Nonpoint source pollution refers to nondiscrete and diffuse inputs or
loadings which are usually associated with rainfall events and are associated
with both natural processes and human activities. Non-point sources which
affect the study area include atmosphere, vegetation, urban areas,
construction activities, agriculture-silviculture activities and solid waste
disposal sites.

There are 9 known and previously-documented (listed) archeological sites
in the SE and SW Sprayfield study areas. Figure 2-9 shows the locations of
these resources. These sites are known to contain relics of various early
cultures.

During November 1990, the city contracted with the University of West
Florida, institute of West Florida Archeology, for a phase I Cultural resource
inventory and assessment of the proposed expansion areas of the TPS Plant and
the Eastern Expansion area of the SE Sprayfield. A final report waB submitted
to the city in February 1991 with the following conclusions:

•	The only site of cultural remains located in the TPS Plant parent
tract was the previously recorded 8LE546.

•	No culturally significant remains were found to exist in the TPS
Plant expansion tract.

2-80

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TABLE 2-27

PROTECTED FLORA ANO FAUNA THAT RANGE IN THE STUDY AREA



Florida Species of
Special Concern

Federal-Level
Category 2

Threatened
in Florida

Endangered
(n Florida

Threatened in

United StfltM

Endangered in H
United States I

Eastern Indigo Snake
Drymarchon Corait

X



X



X



Florida Pine Snake

Pituophis Melanoleucus melanoleucus

X

X









Gopher Tortoise
Gopheru polyphemut

X

X









Gopher Frog
Rana aerolaia atsop us

X

X









Panhandle Golden Aster
Pityopiit flexuosa







X



C

Panhandle Meadow Beauty
Rhexia salicifolia



X









Notes:

Species of Special Concern • a species which is known to be vulnerable, but no protection measures
have been enacted at the State level.

Federal Level Category 2 • species which are candidates for federal listing as threatened or
endangered. These species show evidence of vulnerability, but not enough is known to support a
listing.

C ¦ Candidate • any species proposed for listing as federally threatened or endangered.

Source: Dave Martin, USFUS, Jacksonville, Florida.

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PAGE NOT
AVAILABLE
DIGITALLY

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•	cultural remains were located in 26 new sites in the Eastern
Expansion area of the SE Sprayfield (See Figures 2-9 and 4-2).

•	of the 26 areas of cultural material recorded in the Eastern
Expansion area, five appear to be significant enough to warrant
further consideration.

Recommendations presented in this final report (February, 1991) for
protecting the cultural resources at these sites are incorporated into the
environmental protection measures of Sections 3.3.5 and 4.6.1.

2.5.3 Existing Han-Made Environment

The populations of Tallahassee and Leon County have experienced steady
growth over the past 50 years. The primary factor in population growth has
been in-migration. The sunbelt states, and Florida in particular, have
experienced significant population increases over the last two decades. in
addition, Tallahassee is the state's capitol and the site of Florida state
University and Florida A&M University. Increased opportunities in government
employment and increased enrollments have both contributed to in-migration.

Residential land use is the predominant land use in the study area.
Other land uses in Leon County include commercial, industrial, institutional,
open space, agriculture, transportation/utilities, and the Apalachicola
National Forest. The TLCPD 1987 population projections were employed in the
Eis Supplement. Section 2.2.2 documents the projections by service area for
the study area that were used to estimate sewage flows (Sections 2.2.3 and
2.2.4) .

Population information more recent than the 1983 usepa eis presently
exists. According to the Tallahassee-Leon County Planning Department (1992)
statistics dated February 14, 1992, the 1990 census population of Leon County
including the city of Tallahassee and university students is 192,493 and a
population projection for the year 2010 of 261,600 (35% increase since 1990).
According to the Tallahassee Chamber of Commerce, the 1990 population of the
City of Tallahassee is 124,733 (presumably also for 1990 and including
university students).

Leon county is primarily a government, trade and service center, over
fifty percent (>50%) of non-agricultural employment is in government,
reflecting Tallahassee's Btatus as the state capitol. Approximately twenty
percent (20%) of the nonagricultural employment is in wholesale and retail
trade.	The third largest employment sector is services, which records

approximately thirteen percent (13%) of total nonfarm employment, and is
attributable to the presence of Florida A&M University, Florida State
University, and Tallahassee community College in the study area.

A wide variety of recreational opportunities are available in Leon
County. Apalachicola National Forest is the largest recreational resource in
this area covering 103,471 acres. silver lake, located within the Forest
offers a complete range of outdoor activities. Numerous state, County, city,
and privately-owned parks and recreational facilities are available for public
use.

Of the major components of the transportation system (highway, air,
rail, and water), only highway and air systems have significant importance to
the study area. Four major Federal highways, U.S. 90, U.S. 27, U.S. 319, and
1-10, intersect the Tallahassee area. The Tallahassee Municipal Airport is
owned and operated by the City of Tallahassee and is served by several
commercial airlines. There are no important navigable waters or significant
rail centers in the study area, although there is rail freight service to Leon
County.

2-83

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Various natural resources are found and utilized within the Tallahassee-
Leon County study area. The major natural resources are minerals, timber,
agriculture, freshwater fish and wildlife.

One Class I sanitary landfill is found in the study area, located on
U.S. 27 south. it is owned and operated by Leon County. The existing site
comprises 620 acres and has a life of 30 years. The sanitary landfill
operates the trench method and uses the lined cell concept for compacting the
refuse. The landfill currently disposes about 400 tons of waste daily.

Land development controls are an important aspect of water quality
management planning. Land use regulations can be used to direct development
away from sensitive environmental areas, including water-quality-sensitive
areas. Land use controls can also Berve to mitigate any short- or long-term
negative impacts that may result from the provision of wastewater treatment
and disposal facilities. Leon County and the City of Tallahassee at present
administer many environmentally-oriented regulatory measures. However, most
ordinances now in effect are only for the purpose of regulating development.

2-84

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CHAPTER 3

ALTERNATIVES
EVALUATION

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CHAPTER 3 ALTERNATIVES EVALUATION

This chapter addresses the evaluation and rating of the four system
alternatives selected for further evaluation (Alternatives 1, 2, 7 and 9) in the
EIS Supplement. The characteristics of the categories of the cost-effectiveness,
implementability, reliability, and environmental impacts were considered by
alternative in a matrix rating format. The evaluation was developed during the
deiss preparation stage (1989). The rating information was subsequently utilized
to rank the overall acceptability of the four alternatives relative to the four
categories considered. Ranking was not statistically treated (Refer to Chapter
4 of this FEISS).

3.1 COST AND IMPLEMENT ABILITY EVALUATION

3.1.1 Cost Effectiveness

The USEPA requires that the alternative evaluation process include a cost-
effectiveness analysis. The objective of a cost-effectiveness analysis,
according to USEPA regulations for the construction grants program (Code of
Federal Regulations Title 40, Part 35, Appendix A), is to determine which
wastewater management system alternative will meet federal, state, or local
requirements in the minimum total resource cost over time. Furthermore, the most
cost-effective alternative is defined as the system with the lowest present.worth
value (1989) unless non-monetary costs are overriding. The non-monetary factors
include primary and secondary environmental effects, implementation capability,
operability, and performance reliability and flexibility. Even though use of
federal funds is not anticipated for the considered alternatives, it is still
important to the users and potential users, and therefore to USEPA, that the
wastewater management system costs be reasonable for the users.

Tables 2-11 through 2-19 presented the estimated project costs for each of
the system alternatives. These costs are used as a basis for the project cost
analysis presented in Section 3.1.1.1 for the four (4) selected system
alternatives. A discussion of financing options is included to determine sources
of revenue for construction of an alternative, particularly the centralized
alternatives. User charges for the four (4) alternatives were estimated to
determine the financial impact of the proposed wastewater treatment and disposal
services on the Tallahassee-Leon County area user households.

Although the system alternatives have been planned in some detail and every
effort has been made to ensure that the costs, of each alternative are reasonable,
it should be recognized that uncertainty is inherent in any attempt to plan for
the future. Indeed, with the level of detail used in a study like this one,
error limits of 30 percent can be expected. The objective of the cost-
effectiveness evaluation was not to define what the actual charge to the users
of each system would be, but rather to develop costs that would be internally
consistent and allow a valid comparison of alternatives.

3.1.1.1 Project Costs

Cost estimates in this section were based on 1989 dollars.

3.1.1.1.1 system Alternative 1» Treatment south, SE Agricultural and
Golf course spray irrigation

The treatment components of Alternative 1 consist of
Plant and improving and expanding the TPS Plant for a total
$15,665,000. The expanded conveyance system which isto transport collected
sewage from new development to these plants is estimated to cost $52,586,000.

The effluent disposal system, which includes expanding the existing SE

Agricultural Spray irrigation operations by	,e«nitaleoatof

irrigation at four (4) golf courses, is estimated to have a capital cost of

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$17,455,000. These costs include the $8,733,000 for conveying treated effluent
to the disposal sites.

The total capital and annual Operations and Maintenance (O&M) costs for
Alternative 1 are estimated to be $85,706,000 and $3,659,000, respectively.
These costs were summarized in Table 2-11.

3.1.1.1.2	System Alternative 2: Treatment South, SE Forest
and Golf course Spray Irrigation

The project costs for Alternative 2 are similar to those of Alternative
1 except for the effluent disposal system which includes expanding the existing
SE disposal site by 1,475 acres, but using forest spray irrigation on these acres
instead of agricultural spray irrigation. The total capital costs for the
disposal components are $23,987,000 which include $8,733,000 for conveying
treated effluent to the disposal sites.

The total capital and annual OSM costs for Alternative 2 are estimated
to be $92,238,000 and $2,998,000, respectively. These costs were summarized in
Table 2-12.

3.1.1.1.3	System Alternative 7: Treatment North and South, SE
and NE Artificial Wetlands

The treatment components of Alternative 7 consist of improving and
expanding the TPS Plant, and constructing a new NE Plant for a total capital cost
of $26,309,000. The expanded conveyance system which is to transport collected
sewage from new development to these plants is estimated to cost $36,207,000.

The effluent disposal system includes expanding the existing SE disposal
site by 424 acres and developing a 580 acre NE disposal site. Disposal
facilities at these sites include artificial (constructed) wetlands and rapid
infiltration basins. These facilities are estimated to have a capital cost of
$35,805,000 which includes $4,226,000 for conveying treated effluent to the
disposal sites.

The total capital and annual 04M costs for Alternative 7 are estimated
to be $98,321,000 and $2,469,000, respectively. These costs were summarized in
Table 2-17.

3.1.1.1.4	System Alternative 9: Decentralized

The project costs for Alternative 9 were summarized in Table 2-19 and
includes costs for improving the LBR Plant, expanding the Killearn Lakes Plant,
constructing on-lot systems using septic tanks and soil absorption fields or sand
mounds, expanding effluent conveyance capacity from the TPS Plant to the SE
disposal site, and expanding the existing SE Agricultural spray Irrigation
operations by 469 acres. Total capital costs are estimated to be $99,779,000 and
the total annual O&M costs are estimated to be $1,540,000.

3.1.1.2 Financing Options

The annual household costs presented in the following section assumes, for
the sake of comparison, that the City finances the centralized system
alternatives using the sale of revenue bonds. In addition to this financing
mechanism, there are cost-sharing techniques including federal grants. The
current status of the federal grant program is described below followed by a
summary of municipal revenue bonds and privatization.

3-2

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3.1.1.2.1	Federal Grants

Current USEPA construction grant regulations provide for federal funding
of 55 percent of the allowable costs of wastewater treatment projects started
after September 30, 1984. However, such projects must appear on the state^B
priority list. Projects with the highest priority receive grants and then, if
funds are available, the other projects are funded in descending order of
priority. The priority list is assembled each year. No construction Grant funds
are currently available. To replace this lost funding source, the USEPA has
assisted the states in establishing revolving loan fund programs. In any case,
the costs in thiB study are presented assuming no grant participation.

3.1.1.2.2	Municipal Revenue Bonds

Revenue bonds are tax exempt debt instruments which are used to
construct capital projects and are retired by payments from user charges
collected by the City.

The tax exempt status of municipal revenue bonds will not be affected
by new tax laws. However, the traditional purchasers of municipal "venue bonds
(large banks, insurance companies and retirement funds) will be restricted as to
the amount of tax exempt securities that they purchase. Therefore, the cost of
selling municipal revenue bonds and the interest rates paid may increase.

Another issue affecting the use of municipal revenue bonds by the City
t JT	. " .	la debt service coverage. Debt service

for construction projects in Leon County is deDt .	rmvBI?U9. In order for

coverage is expressed as a multiplier or percentage	.	.

the city to sell revenue bonds, it will have to demonstrate that it generates a

net revenue approximately 1.1 times its annual aeot.

3.1.1.2.3	privatization

privatizationifl • =°»="P*	d.flcit' and al!J

grant-in-aidprogram«?Undar this approach,	oou" "*

to design, finance, construct, own and operate

Privatization is not intended to be
approach. Privatization applies to	in the solution to its problems,

may utilize in order to engage private comPaniei no tax benefits arising from
It can apply to: municipal leasing, ™ "eative sale of future user rights
ownership are intended to be reall"d'h ^B. the development and application of
as a basis of security for future	of revolving, repayable grants,

the infrastructure bank concept; and a system oirevoiy,*

It can also apply to other creative concepts not yet formulated.

3.1.1.3 Annual Household Costs

_	are defined as the average total

For evaluation purposes, user cna g'	t syfltem. This average annual

annual household costs for the wa®te**^erh"!*"xfBting sewered, existing unsewered
cost is a weighted average of costs for the existing sewet

to be served, and future households to be

3.1.1.3.1 Household characteristics

Table 3-1 presents the household^proh^uMho^d4statisticS?

Tallahassee-Leon County study area.	/oersons per household) were

the service areas' average household	o£ th# city t0nd
determined. Generally, the areas on the development is occurring at these

to have larger households. Since most °f * J*	the city, the overall
locations, particularly in areas north.of.the
study area's household size increases slig y

3-3

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TABLE 3-1

HOUSEHOLD PROJECTIONS BY SERVICE AREA

CENTRALIZED SEWERED HOUSEHOLDS	PNSBWERBD HOUSEHOLDS < 1> ' <2 >	TOTAL HOUSEHOLDS

Sarvica Atm

Bouaahold
Bisa


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As stated previously the objective b£ calculating annual household
costs is not to define what the actual user charges of each system will be, but
rather to develop costs that would be used to provide a valid comparison of
alternatives. In addition, the calculation of the average annual payment is
necessary to determine whether a project is too expensive by USEPA guidelines.

The USEPA considers wastewater management projects to be expensive
when the average annual household cost exceeds the following percentages of
median annual household income (values were adjusted using the U.S. Department
of Labor Consumer Price Index to reflect 1989 dollars):

1.0 percent when the service area's median income is less than
$15,000,

1.5 percent when the service area's median income is between
515,000 and $26,000; and

1.75 percent when the service area's median income is greater
than $26,000.

Table 3-2 lists the estimated 1989 median household income for the
service areas along with the calculated maximum annual household cost as
recommended by the USEPA.

The total annual household costs calculated for the EIS Supplement
consist of three components: annual debt payment, annual assessment payments,
and annual operating, maintenance, and replacement cos s. ®	below The

and the assinptions used to calculate their values are described below. The
costs estimates assume no federal grant funding.

3.1.1.3.2	Annual Debt Payment

.,	-	-«o4--effectiveness evaluation, it is assumed

that the city' w^d^at o°ne ^ue bond to

£°ata faci.1.ity pLannii9l/Vvern'aa2o4e« period at an interest rate of 9
The bond would be amortized over: a 20 year per	ital recovery factor,

percent. Therefore, the annual debt Payment	project cost. Table 3-3

0.10955, times the bond amount which is	three (3) selected centralized

displays the debt payment calculation for tn

alternatives plus Alternative 9.

Generally, it is assumed that the "®^nf°fvea"tiTbrpaidaUfor by
those proposed in Alternative 9 (decentralized	Qf the selling price of

th. d.v.lop.r. who, in tarn,	co»t for on-lotP.y.t.M

the house or other types of structures. Ther 'Qr a structure not connected
will be a part of the selling price of ane	System. To account for these

to either an area system or a large centra	i	wag assumed that the

"hidden" costs in the cost-	Mortized over a 30-year

capital costs for area and on-lot sYst®ma	typical 1989 market rate for

period at a 9.5 percent interest rate, Dasd (the assumed life of the
is the yearly investment over a 20-yaarpa rate of return, required to pay
"perishable" parts of the facility)	:* period. in actuality, the service

the replacement cost at the end of the zw ye F	h tjjne of purchase

provider may choose to finance equipment replacement at «• m

3-5

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TABLE 3-2

ESTIMATED MEDIAN ANNUAL HOUSEHOLD INCOMES
AND USBPA RECOMMENDED MAXIMUM COSTS

(19B9 DOLLARS)

Median	Maximum Annual

Service	AnnualHoysehold	Household

Are*	Income *	' Cost '*>

Lake Bradford Road	$11,200	$ 112

P.S. No. 12	24,600	369

Riggins Road	32,400	567

Northeaet	43,000	753

Springhill Road	IS,900	239

T.P. Smith	20,700	311

Southeast	24,700	371

Buck Lake	36,800	644

Service Area-wide	24,000	360

City-wide	17,900	269

County-wide	21,900	329

' ) Baaed on data from the 1980 Cenaua of Population and Housing of the U.S.
Department of Commerce and the Consumer Price Index (all urban
consumers, U.S. City average, all items) of the U.S. Department of Labor.

Calculated insylimim allowable costs for wastewater management systems.

3-6

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CABLE 3-3

CALCULATION Or DEBT PAYMENT FOR SEWERED POPULATION
(Thousands of 1989 Dollar*)

Alternative* Selected For Further Consideration
	In the Alternative* Analysis	

Project Coat	B5,706

Annual Debt Payment	9,389

Average Household Annual	130 I1'

Household Debt
Payment (Dollars)

2	7	9 <3>

82,238	98,278	4,343

10,105	10,766	476

140	(1> 149 (1>«	9 <2>

<*> Assumes a service ares of 72,355 houssholds in the year 2010,
Assumes a service area of 54,256 houssholds in the year 2010.
Excludes the on-lot systems proposed to serve future populations•

3-7

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rather than establish a replacement fund as illustrated here. The replacement
costs are included in the annual cost for this analysis to maximize the household
cost and provide a "worst-case" comparison against usepa's expansiveness
criteria. The interest rate used for the fixed rate of return is 8-7/8 percent,
which was the current interest rate used by the USEPA for present worth analysis
at the time of the evaluation (1989).

Estimates for replacement costs assumed equipment (perishable parts)
consisted of the following:

•	One hundred percent of the treatment plant electrical; heating,
ventilation and air conditioning (HVAC), instrumentation, and
piping components;

•	Ten percent of the treatment plant major structures (appurtenances
and process equipment); and

•	Ten percent of both the sewer line components (both collectors and
interceptors) and the major components of the conveyance pumps.

Table 3-4 lists the estimated average annual household costs for
operation, maintenance, and replacement (OM&R) and the breakdown of these costs
of facility components. Replacement costs are not included in the annual o&M
costs for on-lot and area systems because all "parts" are assumed to last the
service life of the system provided proper maintenance procedures are followed.
The annual O&M costs for area systems and on-lot systems for Alternative 9 are
included in Table 3-5.

3.1.1.3.4	Assessment

For this analysis it is assumed that the City would finance the
construction of collection systems for the existing unsewered expansion areas by
assessment of costs against benefitted properties. The estimated average per-
household cost of collection systems, including house connection, is $8,180 in
1989 dollars. Assuming a 9.5 percent interest rate, baaed on a typical 1989
market rate for first mortgages, a 30-year loan for $8,180 would have annual
payments of $831. For the purpose of this evaluation, the annual household cost
for households in expansion areas includes the $831 yearly assessment cost. The
cost of collectors for these households is likely to be a part of the price of
the house and would be included in the mortgage amount. Unsewered households in
"infill" areas do not incur significant costs for collection and therefore do not
have costs included here.

3.1.1.3.5	Total Annual Cost

The total annual household costs for system customers are shown in Table
3-5. The average total annual payment is a weighted average of the existing
sewered, future infilling, future expansion, and future on-lot households. The
range of average annual payment is from $149 (for Alternative 9 ) to $274 (for
Alternative 7), excluding hook-up costs I Note t Hook-up costs are addressed in the
"Project Updates Summary" Chapter of this fexss. Xn general, the total City
connection fee (FY 94 dollars) for residents inside the City limits is $2,970 and
$4,305.60 outside the city limits, plus actual on-lot connection costs for
individual residences (plumber's fee) of approximately $1,000 (1994 dollars) can
also be expected; the City also charges a monthly user fee (FY 94 dollars) of
$2.60 per 1,000 gallons of sewage for City residents and $3.90 per 1,000 gallons
of sewage for residents outside the City). Table 3-2 listed the median annual
household income for the Leon County Area which resulted in a recommended nnnHmnm
household cost for wastewater management of $360. All alternative systems are
within this level, xt should be noted that any large centralized system would
be done in phases and should lessen the burden on existing, sewered households.

3-8

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TABLE 3-4

ESTIMATED ANNUAL OPERATION, MAINTENANCE AND REPLACEMENT COSTS
(Thousand* of 1989 Dollar*)

Conveyance 0*M
R

Alternative* Selectad Por Further Consideration
..-in_the_A_ltarnativea Analyei*

404

439

404

439

333
302

(1)

Treatment OtM
R

2,010
399

2,010
399

1,098
540

94
6

Diepoeal Conveyance
OtM
R

122
73

122
73

72
35

22
14

Disposal OtM
R

1,123
72

462
125

966
205

349

15

Total

Average Annual
Boueehold Coat
(Dollar*)

4,642
64

4,034

56<2)

3,551
49<2>

500
$(3)

Exclude* the on-lot eyetem* proposed to eerve future population*.
A**use* a aervice area of 72,355 household* in the year 2010.
''' Assumes a service area of 54,256 households in the year 2010.

3-9

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TABLE 3-5

ESTIMATED ANNUAL HOUSEHOLD COSTS

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TABLE 3-6

COST-IFFECTIVBNESS ANALYSIS RATING
(in Third-Quartar 1989 dollars)

Coat-Bffactivanaaa'
Charactariatlci

Capital Coats
Annual 04M Coata
Praaant Wortti Valuaa
Annual Houaahold Coata
Total

Avaraga
Ranking'2>

Altarnativaa Salactad For Furthar Consideration
	In tha Altarnativaa Analvala

2.75

3
2
2
2

1

2 .25

1.75

1
4
4
4

~T3

3.25

(1)

(2)

Rating ac.la for char.ctari.tic. goa. from high coat/low vain. (-1) to low coat/high valua (-4)

__ i.j - ,.	¦		 1-..^ nrafarrad f«l) to Boat prafarrad (»4). When a tia axiata for

* catSgo^,abo"nflt«na?°i". ara aaaigi&d tha	mmarioal ranking. Ranking ia not .t.tiatically

traatad.

3-11

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3.1.1.4 Alternative Cost-Effectiveness Summary

Table 3-6 presents a simple rating of the four alternatives selected for
further consideration for cost-effectiveness. This matrix was developed at the
DEISS preparation stage (1989). Based on this analysis, Alternative 9 is
considered the most cost-effective followed by Alternative 1 and Alternative 2,
respectively. Alternative 7 is considered the least cost-effective alternative.

3.1.2. Implementability

The engineering and technical expertise necessary to implement the selected
alternatives is generally well established and available for agricultural and
forest spray irrigation, treatment plant upgrades and effluent conveyance, and
on-lot (septic tank) systems. The technology for artificial (constructed)
wetlands is also established and available, although it is still a somewhat
recent technology in terms of implementation in the United states,
implementability of alternatives is also related to public acceptance, public
agency approval, and City and County selection.

The following conclusions summarize some inputs from public participation
programs undertaken by the 1983 USEPA EIS and inputs at the DEISS preparation
stage of the EIS Supplement:

1.	Low annual costs to households are preferred and it is generally
assumed that the project will not receive federal grant funds. The
Leon County Board of commissioners has established as their Goal Number
4, for development of services in the unincorporated area of the County
- provide water and sewer services at lowest possible costs.

2.	Distribution of costs is a major concern to many citizens and should be
based on use. Generally, centralized wastewater management system
costs are spread over all utility customers beginning when facilities
are added. consequently, the capital cost of carrying significant
amounts of over-capacity would have to be borne by existing customers
until new customers connected to the system and the facility reached
user capacity. On the other hand, most of the costs of on-site
facilities (a decentralized system) would be incurred by the user
leaving a small balance to be passed on to the public, i.e., equitable
cost allocation. Also, on-site facility costs would be incurred
simultaneously with the need for the facilities resulting in a more
efficient use of invested capital.

3.	compatibility of the management system with existing land use is a
major concern to many citizens. The Leon County Board of Commissioners
has established as their Goal Number 1 for development of services in
the unincorporated area of the County - Manage the impact of growth.

4.	A management system that is flexible to meet the changing needs of a
developing area and that increases the availability of sewer management
systems is preferred. The Leon County Board of Commissioners has
established as their Goal Number 2 for development of services in the
unincorporated area of the county - increase ability to respond to
citizens needs.

5.	A management system that simplifies the procedures needed to monitor
the operations and maintenance of a system is desirable to ensure that
the system functions properly. The Leon County Board of commissioners
has established as their Goal Number 3 for development of services in
the unincorporated area of the County - Develop tools for managing
services.	' *

3-12

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6.	The City prefers expansion of the T. P. Smith Facility to 27.5 mgd and
expansion of the southeast Agricultural spray irrigation operations to
handle the additional effluent. f 1:hi	preference for wastewater

¦imilar to those items provided above (e.g., it*" * v

3-13

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Implementation *1'
Characteristics

TABLE 3-7

IMPLEMENT ABILITY ANALYSIS RATING

Alternative* Selected ror Further Consideration
	in the Alternatives Analysis

1.	Low annual
household costs

2.	Equitable
distribution of costs

3.	Compatible with
existing land use

4.	Able to respond
to the needs of
development

5.	Provides easy
management of
facilities

6.	City's approval

7.	Treatment and
disposal of waste-
water near gener-
ation site

8.	Reduce potential
environmental impact
due to spray irriga-
tion of affluent

9.	Reduce potential
operation failure of
artificial wetlands

10.	Reduce on-lot	3
system failures

11.	Minimize non-point-
source pollution

Total	25

Average

Ranking «*»

25
2.27
4

25 22
2.27
4 3

2.27

111 Ratxng scale for characteristics is as followsi

1	- Low implementation potential.

2	- Medium/conditional implementation potential.

3	- High implementation potential.

<2) Ranking of alternatives goes from least implementable (-1) to most implemantable (»4).
Whan a tie exists, both alternatives are assigned the seme numerical ranking. Ranking
is not statistically treated.

3-14

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treatment in northern Tallahassee as opposed to southern Tallahassee). m
addition, the USEPA understands from the City that Leon County held a public
hearing in Tallahassee on July 23, 1991. Some 20 speakers voiced concerns
regarding aerosol spray drift, odor, and decreased property value. These
speakers were primarily citizens with residences east (and north) of the Eastern
Expansion area of Alternative 1 proposed by the city for near-future
construction. As a result of the July 23 public hearing comments, the County
Commissioners of Leon County have unanimously denied the City issuance of Leon
county sewer "franchise" which the county maintains is needed for the expansion
of the existing SE Sprayfield. As a consequence, the city's proposed expansion
to the Eastern Expansion area is presently denied by Leon county. The county has
furthermore requested that the City revise/update the 1988 City Master Sewer Plan
and that the city present various wastewater alternatives with cost estimates to
the County for consideration.

3.1.3 Reliability

The reliability evaluation estimated the degree to which each wastewater
management system could consistently achieve and maintain effluent limits for
which the system was designed, which included the City staff's experience in
using the technologies. The general consensus is that larger centralized
treatment facilities are more reliable than smaller area facilities. Experience
suggests that the duration of malfunctions resulting in violations would be
greater at small treatment plants because of limited operational flexibility and
less frequent inspection and maintenance. The frequency of malfunctions at large
plants may not be less than at small plants, but the ability to identify,
isolate, and correct a malfunctioning unit at a large plant would reduce the
probability of unacceptable discharges.

To provide a method for evaluating the reliability of Alternatives 1, 2, 7
and 9 in this cost-effectiveness analysis, the characteristics that affect a
system's reliability have been defined as follows?

1.	On-site personnel - provides timely response to problems that may occur
at treatment and disposal facilities including equipment failure and
wet-weather wash-outs.

2.	Largs operating budget - allows '""ity to attract and p,Y higher-
caliber supervisory personnel and store competent operators.

3.	Maintenance program - * structured program provide. a systematic
approach to performing. don".' corr.ctly lnd in t ti^^
f™hi"Cto "Jtaize downtime and both operation and maintenance costs.

4 • fS&U,f^w".Cryi.Son.'P.!nd

treatment units, and flow equalization basins.

c T	, fKa lonaer the sewer collection/interceptor system

5'	su's'^tibU ''it'iT* inflow and infiltration problems.

e	,	. - --ins in sewer system - the more pumps and

' SET mains^in a ..»« collection/interceptor system the more
susceptible it is to have mechanical problems.

7.	complexity of facility's technologyandhardwarette^

ESSjf^&SS*	reason for failure.

8.	Experience in using	f^Uit^with "this1 technology
particular technology the less liKeiy a j

3-15

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will experience operation problems and failure and the more rapidly a
breakdown can be corrected. Likewise a new and innovative technology
with little test cases may experience more operation problems.

These characteristics are summarized and rated in Table 3-7. The reliability
analysis was developed at the DEISS preparation stage (1989). It should also be
noted that this reliability analysis does not account for a "weighting" of the
reliability characteristics, in that all the characteristics are considered of
equal importance. The ratings listed in the table are based on the following
assumptions:

1.	The city will operate any centralized facilities. Therefore, they will
supply supervisory personnel and operators for these components.

2.	The Talguin Electric Cooperative, Inc. (TECO) will operate any area
facilities. Therefore, they will supply supervisory personnel and
operators for these components.

3.	Treated effluent for all alternatives will be disposed via some type of
land application.

From Table 3-8, Alternative I with its proposed expansion of the T.P. Smith
Facility and adjacent expansion of the SE Agricultural Spray irrigation
operations was considered to have an advantage over the other alternatives in
terms of reliability (and was considered the same in terms of implementability
compared to the other centralized system alternatives). The city of Tallahassee
is familiar with and has used the agricultural spray irrigation technology at the
existing SE Sprayfield facility.

It should be noted that use of artificial (constructed) wetlands, a
relatively new wastewater disposal technology in the United States, has shown
increasing reliability in the united States in areas such as neaurby Orlando,
Florida. The reliability of constructed wetlands has probably increased even
since the 1989 matrix evaluation for the DEISS. The Orlando facility, for
example, has been functional for several years and the Tennessee Valley Authority
(TVA) operates facilities in Kentucky and Alabama, and possibly other areas,
constructed wetlands also exist in other states such as Mississippi, California
and Maryland (Also refer to Section C-13 entitled "Artificial (Constructed)
wetlands" in Appendix C of this FEISS). However, success in the United states
(compared to Europe) is still fairly recent, the effluent treatment method (i.e.,
treatment subsequent to wastewater treatment plant treatment) has not been used
in the study area, and City personnel are not familiar with the technology —
particularly when compared to the agricultural spray irrigation technology.
Reliability and acceptance in the united states would be expected to continue to
increase with time and implementation experience. Subsequent to artificial
wetland treatment, it should be noted that the treated effluent discharged from
the artificial wetlands must be disposed via an environmentally appropriate and
feasible disposal method.

3.2 ENVIRONMENTAL EVALUATION

The environmental impacts caused by the four (4) further-considered
alternatives (1, 2, 7 and 9) were categorized as primary and secondary. Primary
impacts are characterized as being directly affected by the implementation of the
wastewater management system, secondly impacts occur as indirect results of
system implementation.

3.2.1 Primary Impacts

3.2.1.1 surface Water Resources

Surface water degradation may occur as a direct result of construction
activities or during the effluent disposal process. Each of the four alternatives

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TABLE 3-8
RELIABILITY ANALYSES RATIHQ

Reliability
Characteristics (*)

1.	On-sita Personnel

2.	Large Operating Budget

3.	Structured Maintenance
Program

4.	Equipment Redundancy

5.	Length of Sewer

6.	Number of Pump* in Sewer
System

7.	Complexity of Technology
and Hardware

8.	Experience in Uaing
Technology

Total

Alternatives Selected For Further Consideration
In the Alternatlvee Analysis

3	3	3

3
3

3

1

1

2

3

Average
Ranking I *'

19
2.39

.13

2
2

1

1

1C
2.00

2.00

*¦

Rating scale for charcteriatics is aa follow*s

1	- Poor reliability

2	- Average or conditional reliability

3	- Good reliability

(2»	Ranking of alternatives goes from least relieve <^>*°^*ranking^" [Unking"*1**" not Statistically

exiata, both alternative® are aeaigned the aaae nujaerx
treated.

3-17

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involve the construction of conveyance pipelines, but little impact on surface
waters is anticipated due to the use of existing rights of way. There may be
areas when an existing right of way cannot be used, but adequate erosion and
sedimentation control measures should protect adjacent surface waters.

The application of effluent on golf courses, as proposed in Alternatives
1 and 2, will not likely impact surface water resources. The position,
trajectory, and area coverage of sprinkler systems should be designed to avoid
direct application to surface waters.

Agricultural and forest spray application could cause degradation if
systems are constructed in areas having low infiltration/percolation rates, or
where the application rate exceeds the intake capability of the soil. The
alternative SE agricultural and forest spray sites are located adjacent to the
existing SE agricultural irrigation facility. Portions of these sites are
wetlands and lakes and drain into numerous Karstic depressions, as well as
shepherd Branch and chicken Branch. clearly, there is an opportunity for
degradation of surface waters by spray irrigation systems used in Alternatives
1 and 2. Careful design and orientation must be used if these sites are to be
adapted to land application facilities to avoid water quality problems such as
waterbody eutrophication.

When Rapid infiltration Basins (RIBs) are used in conjunction with
constructed wetlands, they should not be allowed to cause significant surface
water impacts. Therefore, effluent disposed via RIBs should be adequately
treated and RIBs designed to avoid surface water runoff. As a precaution,
however, such facilities should probably also not be located near surface waters
within the alternatives sites.

There would be an increase in surface water flow due to the operation of
any of the alternatives. The increase would likely occur due to groundwater
mounding and the subsequent movement into the adjacent surface waterbodies. No
significant impacts due to increased surface water flows would be anticipated.

3.2.1.2 Groundwater Resources

Groundwater quantity and quality would most likely be affected by any of
the land application or infiltration systems. Wastewater constituents not used
by plants, degraded by microorganisms, or fixed in the soil may leach to the
groundwater. Constituents of concern are bacteria, viruses, nitrate-nitrogen,
heavy metals, phosphorous, and organics.

Sites using slow-rate land application techniques pose a minimal bacterial
contamination threat to the groundwater. The combination of high bacterial
densities and a high water table should be avoided even when using a slow-rate
technique to prevent undesirable surface seepage. High-rate land application
techniques, such as rapid infiltration, may experience penetration of bacteria
about 10 meters vertically and at variable distances laterally.

Based on the "General soil Hap" for Leon County in the 1981 soil Survey,
Leon county is dominated by three soil associations: the Orangeburg-Lucy-Norfolk
association in the northern part of Leon County and the Kershaw-Ortega-Alpin and
the Dorovan-Talquin-Chipley associations in the southern part of Leon County.
The orangeburg-Lucy-Norfolk soils and the Kershaw-Ortega-Alpin soils are
generally well-drained while the Dorovan-Talquin-Chipley soils are generally not
well-drained. Specifically, the 1981 Soil survey classifies the Orangeburg-Lucy-
Norfolk soils as "well drained soils" and the Kershaw-Ortega-Alpin soils as
"excessively drained and moderately well drained soils," while the Dorovan-
Talquin-Chipley soils are considered "somewhat poorly drained to very poorly
drained soils." Of the two well-drained soil associations, the depths of these
Bandy associations differ significantly: the Orangeburg-Lucy-Norfolk soils are
sandy to only 20-inch depths with loam below, compared to sandy 20-40 inches deep

3-18

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with loam below or are loamy throughout (Notes "loam" i« a soil type that is
defined in the 1981 Soil Survey as a mix of clay (7-27%), silt (28-50%), and sand
(<52%) particles.) By contrast, the Kershaw-Ortega-Alpin soils are sandy to 80
inches or more, with some having loamy layers (lamellae) below 45-inch depths.

Regarding the suitabilities of these soil associations for septic tank
absorption fields, Table 11 of the 1981 Soil Survey presents the -restrictive
soil features- of existing soil types. All listed

soil types are classified as -moderate! percs slowly «»d/or "JodiHriitet weti
with -moderate- being defined as having unfavorable soil P"P®rtiesf orthegiven
activity. The Kershaw soils are classified as "which is defined as soil
propartias genar.lly

classified as -severe:	Dorov Talquin and chipley

properties very unfavorable for	oV - severe« floods, wetness.- These

only th. K.r.h.« .oil. h«v.jrop«ti.. javorjbl.

for septic tank absorption field infiltration	nroDer filtration (i e

drain or drain too well= and:P	/ Leon County therefor4

adsorption of inorganics (metals), micro ^	, -moderate" or -severe"

appears to be a mix of soil types^wi for9s	tio tank activity. The

classifications regarding ¦uitaDixi^	e ^ q£ 8uitabilit
preliminary 1988 Leon county MW4SSP also aaaroB«D
for septic tanks within Leon county.

_ j	vha Leon county Public Works Department

The USEPA UjiderBtands that the L ^	sites in 1989 and

apparently conducted a site assessment Northaa8t sites, with their lower
determined that the clayey 8oi^a	, d to dispose the same quantity of

permeability, would require much mor .. L oparation in the Southeast sites
effluent than what would be needed tor a	trend also generally agrees with

with their more permeable sandy soils.	oredicted to be required for

T&bla 2-9 of thi. FEISS. WMn,	si (cMiiponaiit M> *• comparad to

agricultural spray irrigation .in " (component D2), the average acreage
agricultural spray irrigation in the < r in the m <430 acres/mgd) than m
needed per effluent flow (mgd) is ®uf*V,9 , exists for the NE forest irrigation
the SE (188 acres/mgd). The same trena_	th# SE forest irrigation site

site (component d4j 524 acres/mgd) co p	however, is not true in every

(component D3: 197 acres/mgd). (Tnis j.* 'diap08ai in the SE (components
instance since the artificial wetlands aaine amount of acreage as in the NE
Dll and D16) are predicted to	J;"®-/mad\. For Table 2-9, the maximum

(components D12 and D17), i.e., l*1 _aaa, and was based on the soils in the
application rate was used to estimate act* 9	However, the USEPA recommends

1981 Leon County Soil Survey at the gi . t anv 8j.te proposed for irrigation
that soil percolation testing * owdnotjd a^any^^ ^atefl>
be implementation to determine actual	e

* -™4torinq wells near the City's existing

Data collected from	and nitrate-nitrogen concentrations,

sprayfields indicate an increase in chiori	^ ayfield increased from a

Chloride (Cl) levels at the city' •	man and nitrate-nitrogen (No3-No2)

background concentration of 3 ®9(*¦ Jf' ,5 mq/l. City monitoring has shown
concentrations increased from 0.5	-d (FDER) water quality standard for

nine (9) exceedances of the	0^/ita c0fflpli^e wellB for *£• ®E a?d S*

nitrate-nitrogen (10 mg/1) in two . the j-der standard. Chapter 4 and
Sprayfields. The current level i« J®*,. an expanded explanation of these
section 3.3.7 of this chapter provid undwater8 (pUblic drinking water
exceedances. The standard for c^"/1 £or chlorides and 10 mg/1 for nitrate-
8uPPly) as established by FDER i« 250 mg/x

nitrogen.

*	wetlands and RIBS in the alternative

The use of artificial (con#t"ct„lh^ degradation of groundwater unless
N* and se sites will not likely	treated in terms of microbes, metals, and

*he effluent disposed is not adequately trea^e

3-19

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nutrients in the treatment plan and/or the constructed wetlands, such systems
should not be located near Karstic features.

Groundwater levels would likely be affected to a greater extent than
quality. Application by any of these methods, whether by agricultural or forest
spray, golf course spray, RlBs, or on-lot systems, would cause local groundwater
mounding. The additional wastewater would cause greater recharge to the Floridan
Aquifer as well as increased baseflow to the lakes, streams, wetlands and Karstic
depressions. This increase in flow would not likely cause significant distortion
of the regional pattern of groundwater movement or surface waters.

3.2.1.3 Ecological Resources

Any site development would significantly alter existing terrestrial
ecosystems. The County supports several ecologically-sensitive and threatened
or endangered species (or their suitable habitat) which would likely be affected
by any of the system alternatives. For example, there are 26 species or groups
of plants in the County which are protected by Florida law as threatened or
endangered. Nine amphibians and reptiles, eleven bird species, 29 mammals, one
species of fish, and two invertebrate types in the County are also protected by
Florida law. In addition, there are a multitude of species of special concern
in the county and protected by Florida law.

Protected federal and state-of-Florida faunal and floral that range in the
general alternative sites project area are the Eastern indigo Snake, Florida Pine
Snake, Gopher Tortoise, Gopher Frog, Panhandle Golden Aster, and Panhandle Meadow
Beauty. These species are classified as Florida-listed faunal species of special
concern (Eastern Indigo Snake, Florida Pine Snake, Gopher Tortoise, and Gopher
Frog); Florida-listed and federally-listed threatened faunal species (Eastern
Indigo snake); federal category 2 candidate faunal species for federal listing
as threatened or endangered (Florida Pine snake, Gopher Tortoise, and Gopher
Frog); federal Category 2 candidate floral species for federal listing as
threatened or endangered (Panhandle Meadow Beauty); and/or Florida-listed
endangered floral species and federal candidate floral species for federal
listing as threatened or endangered (Panhandle Golden Aster) (Also refer to Table
2-27 and Section 4.4.1).

Even if no species of special concern or threatened and endangered
individuals would be lost during construction of these facilities, the permanent
alteration of a habitat would cause population reductions. This is particularly
true for the Gopher Frog tRana areolata aesopus) because this amphibian is known
to migrate over long distances to breed in waterbodies, and is dependent on the
Gopher Tortoise burrow for protection. There is documented evidence of Gopher
Frogs migrating 1.2 miles (Herpetological Review, 1988) in order to reach shallow
breeding ponds. consequently, if migratory paths are disturbed, the Gopher
Frog's breeding may be circumvented. in addition, the loss of the Gopher
Tortoise habitat, is to be considered. If the Gopher Tortoise is driven out of
its current range, the threatened Gopher Frog is certain to be lost as well.

In addition to threatened or endangered plant and animal species, the
existing ecosystems at the alternative SE and NE Sprayfields would experience
impacts in some or all of the following categories: species diversity, breeding
grounds, food chain integrity, degree of naturalness, degree of the
replaceability of community, ecosystem uniqueness and fragility, interaction with
other ecosystems, and wetlands. The Leon County Public Works Department (1989)
conducted a site assessment of the Southeastern and Northeastern alternate sites.
The environmental analyses of the sites concluded that the Northeastern site
contains large portions of high quality upland areas whereas the Southeastern
sites are primarily covered with lower quality slash pine and sand pine forests.

It is important to consider the size of the land areas which would be
potentially impacted by proposed construction and operation. Based on the

3-20

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assessment performed by the County Public Works, the alternative SE Sprayfield
sites were determined to be less environmentally sensitive than the alternative
NE sprayfield site, but the land areas required at these sites are vastly
different, and merit careful review. The SE agricultural and forest spray sites
of Alternative 1 and 2, respectively, require approximately 1,450 acres, but the
artificial (constructed) wetlands and RIBs of Alternative 7 need' °»ly
approximately 1,000 acres. These 1,000 acres would be divided between the
alternative NE site (580 acres) and the alternative SE site (424 acres) (Refer
to Table 2-9). The larger land area specified for the alternative NE site
would be required because the flow to be treated at the alternative NE Pin
(5.2 mgd) is greater than the flow to be disposed at the SE site, (3.8 mgd).
(Note: Estimated acreage requirements in Table 2-9 were calculated based on the
maximum application rate for given sites, which was based on site soils in the
1981 Leon County Soil survey (1981); however, actual on-site

studies would be needed to determine more specific acreage requirements before
I5ril?«SiivrwS5d be implemented. While the acreage'

(mgd) ratios are the same for NE and SE sites (111 ®c"®/"g_cL)ie^ll^?
artificial wetland with RIBs alternatives, the ratios for *gr\c8li1^"
irrigation in th. m <430

suggesting the sprayfield soils at the NE^Blte	p ^ ^ ^ foregt

more acreage is needed per mgd. Tne Bafe "B"u	
-------
existing facility sites. A nearby fourth known site (8LE1681) was determined to
be outside these areas. The City has retained a professional archeologist and
has completed a survey of these three known sites. The survey also included a
search for potential, as yet uncovered/ unrecorded sites within the Eastern
Expansion of the existing SE Sprayfield and the TPS Plant facility site, where
collectively most of the near-future construction proposed by the city of
Tallahassee related to the preferred alternative is planned. Preliminary
findings from this survey identify 26 newly recorded archeological sites in the
Eastern Expansion area. Of these sites, five (SF1, SF2, SF3, SF7, and SF9) have
been determined to be significant enough to warrant further consideration.
Archeological impacts of the preferred alternative are more thoroughly discussed
in Section 4.6.1. (Also see Figures ES-5, 2-9, and 4-2).

Recreation resources are plentiful in and around the numerous ponds and
small lakes in the alternative SE site. Fishing and boating are common in this
area, but these would probably not be affected by spray facilities. The
recreational use of forested lands of the alternative disposal sites would be
diminished not only if it was developed for agricultural spray irrigation, but
also if a forest spray facility was established. Hiking, hunting, and similar
outdoor activities would be restricted from the irrigated forest sites in order
to avoid direct contact with potentially harmful bacteria and viruses in the
spray effluent. (Also refer to Section 3.2.1.7 below for a human health effects
summary.)

3.2.1.6 Noise, Odor, and Air Quality

Construction of the conveyance lines would produce a temporary increase in
noise and odors, as well as some local reduction in air quality. The use of
diesel-powered and gasoline-fueled equipment would be the major contributors to
the noise, odor, and air quality short-term impacts.

A greater short-term impact would occur at the alternative HE plant
construction site. Excavation and materials transport would cause some annoyance
and disturbance to local residents and wildlife. Documented noise levels from
common construction equipment (USEPA, 1971) are: front loader - 79 dB; truck -
91 dB; bulldozers - 80 dB; graders - 85 dB; and pile drivers - 101 dB (all values
are reported at 50 feet from the source). A general EPA guideline for an
acceptable noise level at a property line is 55 dB. Average noise levels of up
to 62 dB (Leq - 62 dB) are perceived by people as "normally acceptable" (USEPA,
1971). These potential impacts may be reduced by the appropriate use of
environmental protection measures (Refer to Section 3.3).

Noise, odors, and air quality would not be anticipated to be problems at
the agricultural or forest spray irrigation sites. Proper pretreatment of
wastewater effluent would eliminate odor nuisances. There would be some low-
level noise associated with the continuous operation of the HE plant. The local
impacts, however, may be significantly reduced by the use of buffer zones,
planted in evergreen tree species.

Golf course spray irrigation has a potential for causing a localized
increase in airborne pathogens carried via aerosols. Proper treatment of the
wastewaters prior to spray irrigation and selective operation times should
minimize this impact. Viral pathogens may not be killed by conventional
pretreatment methods.

On-lot systems would not cause significant odor problems unless there are
malfunctions resulting from poor planning or design. This includes undersizing
the system and constructing the system on improper soil types or over a hiah
water table.	'

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3.2.1.7 Human Health Effects

It is generally documented (Crook, 1990; Aaano et al., 1992) that
wastewater treatment methods can remove significant numbers of pathogens and
non-pathogenic bacteria typically associated with sewage wastewater. However,
not all may be killed by disinfection. In the case of pathogens such as viruses,
the surviving numbers could potentially be hazardous from a human health
perspective since even a small number of viruses can be infectious.

Spray irrigation of wastewater effluent has the potential to produce
aerosols, and proper treatment relies on microbial contact in the soil to remove
constituents such as metals, salts, nitrogen, phosphorus, non-pathogenic bacteria
and pathogens (pathogenic bacteria, viruses, protozoans and other infectious
microbes). The aerosols have the potential to reach and potentially infect

humans via the atmosphere.

Humans may also be affected via potable groundwater wells near irrigation
sprayfields. After application of the effluent to the land surface, the
wastewater infiltrates into the soil and interacts physically and chemically to
remove the potentially harmful constituents not removed by effluent treatment.
It is possible that some of these constituents could move quickly through the
soil (depending on the soil characteristics and depth) and into the groundwater.
Once this occurs, groundwater flows can carry the untreated metals, pathogens,
nitrogen, etc. to wells which are used by humans as a drinking water source.

3.2.2 Secondary Impacts

3.2.2.1	Land Use

Existing land use would be most altered at	wou!d*n^

of the use of existing rights-of-way, conveyance pipeline construction wouldnot

create changes in land use. The installation	_V^ndtha m* nlant

artificial (constructed) wetlands, rapid	nrinoi.d^iiSoa^l SiXl

would create significant land use changes. Much of the ]Pi®PS*!d oine ind slash

svt* f"rr,"(iy u,*d

Pine. The alternative NE site nas upi«nu» 7".	mature live o*le

fSriit"*" cr°e *nd, P'fu"'„T\aardvo*^r.e, oid-£l»" pin. 'for.-t, «„d pin.

Would constitute significant land use alterations unless located in areas which
are currently similar to the proposed use.

_	. . . .j «itarnative SB disposal site area, intensive

In the general existing andI	expected to continue, but several

lL*!i ^nten*ivA8ilJvi.,CUl i!5f 4	Already exist near the east parcel and

r*8identic1 ¦ubdivis^i	weat parcei. The proximity of lakes and

Pproximately one-half mile south o	disDOsal site area a prime target for

the st. Marks River system make the SE disposal	t<

future residential development.

. ^ ,t. «_j «-ha artificial wetlands and rapid
in... The alternative NE plant site "d raa that includes the Welaunee
infiltration basins would be located in a	u#r parcei8 j.n this area have

lantation and other developable parce *	Current plans at welaunee

recently become active residential subdivisions. curr. £

Plantation are for a mixed commercial/residential d	p»

-	i-ank/drainfield systems under the on-lot

The predominant use of septic tank/or	cleared areas in order to

alternative would require largerlot ^il d lead to more acres being converted to
accommodate drainage fields. This could leaa to mot-

r«sidential land use.

3.2.2.2	Economics and Employment

3-23

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The location of industrial, commercial, and residential development is
often influenced by the availability and extent of public services. The
availability of public wastewater facilities in the NE region would make the area
more attractive for future development, possibly resulting in more numerous and
diverse employment opportunities. The construction of any of the alternatives
would be expected to also create at least a short-term economic and employment
boost, especially if local contractors are selected.

3.2.2.3	Transportation

Transportation resources would not likely be affected to any great extent.
In the short-term, additional construction vehicles may create traffic
bottlenecks, and a certain amount of temporary fugitive dust would likely annoy
some drivers. Long-term transportation could be affected if the increased
wastewater facilities create large increases in local populations and hence
greater traffic congestion.

3.2.2.4	Community services and Facilities

Growth and development served by expanded sewer service has the potential
to cause a need for increased public facilities such as fire and police, health,
recreation, education, library facilities and utilities. The HE site could have
a particularly strong effect on local expansion and associated community
services. The alternative NE site is one of the few remaining undeveloped areas
to the northeast of Tallahassee. (The USEPA understands from the City of
Tallahassee that at least 100 square miles of undeveloped land exits in Leon
County northeast of the NE alternative sites). Construction of the alternative
NE Plant would have a significant effect on local development because it would
encourage further expansion of residential and commercial property. However,
expansion of the southeast treatment facilities to include conveyance of effluent
from the northeast would similarly encourage such development in the northeast.
Also, the land application disposal sites themselves, whether in the southeast
or northeast, would require relatively large land areas which would decrease the
land area available for residential or commercial development.

3.2.2.5	Water Quality

Water quality at any of the sites should not be adversely affected, given
the proper maintenance and operation of the treatment and disposal systems. On-
lot systems, however, present a scenario where surface and groundwater quality
could be degraded. On-lot system failures have been documented in the Killearn
Lakes Subdivision area in the northeast area of Leon County (See Section 2.1.4).
The inventory of failures currently being compiled by the county only includes
"new" failures. Neither the City nor the County has statistics on the percentage
or number of failures or information to identify problem areas. The 1981 soil
survey for Leon County (See Section 2.3.5.1) does indicate that large portions
of the County have soils limiting the operation of septic tank drainfields.

Expansion of wastewater facilities has the potential to increase the level
and density of local population and residential development. The associated
increase in traffic could cause a rise in petroleum oils and various other
chemical materials washed from roadways. These chemicals could	their way

via overland routes into surface waters, or move directly into the groundwater.
In addition, increased residential development generally produces increases in
the use of lawn fertilizer and pesticides. This in turn usually leads to
pollution of storm water runoff flowing to surface waters or to the direct
pollution of groundwater via Karstic depressions (sinkholes).

3.2.2.6	Ecological Resources

Secondary impacts to ecological resources are often difficult to quantify.
Adverse impacts would result primarily from the direct effect of wastewater

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application, and the indirect impact of habitat removal caused by growth and
development, other secondary concerns are: 1) the production of new sinkholes,
or deepening of existing ones due to additional water entering the groundwater
from land application and rapid infiltration basinj 2) the creation of a nutrient
imbalance within ecosystems receiving spray effluent; and 3) the alteration of
forested or agricultural systems because of the varied abilities of different
plant species to adapt to the introduced conditions.

3.2.2.7	Environmentally-Significant Agricultural Lands

There would be some conversion of agricultura1 andailviculturailandto
spray irrigation facilities, wetlands, MBs, and the NE p.1.a"t* _Jh® f?i ®
substantial amounts of open agricultural land. The *SB ¦***"*** m®h-r_y ia JiL
company-owned lands currently in silviculture for pulp P	du_ tQ

a relatively new concern over the impacts of global climate	to

deforestation. The forest	the

rate	the greenhous*™ e^fect^ffects^the	EQ^1^eAlternatives

be made to avoid forest destruction in conjunction vaaetation (agricultural
studied here. Alternatives involving irrigation ®/K^e9«tation(agricultural
and/or forest sprayfields) would somewhat reduce global climate change effects

generated by land clearing.

3.2.2.8	Archeological, Historical, and Recreational Resources

Archeological resources ahould^°^ )?^

activities, if: 1) appropriate	fSHPO) to determine the presence of

Florida state Historic Preservation OfficeJr ( ?ta_ cific pre-construction
any known listed archeological	£ tion of the Florida SHPOj and

archeological survey is conducted to theJ(f^**eved 8ite ia discovered during
3) construction is stopped if	» determination. Major archeological

construction and the SHPO is contacted for a d® ®	nt water sources. Well-

sites are most likely to exist near large	areas,

developed floodplains and terraces would be the most sensitive areas.

*	in*tad to receive direct damage or

Historical resources are not an'ticipate	aUse encroachment on these

natural ..tting di.ruption.	that n..d

resources, and proper protection should be eniorcea wo

j *	sewer service would affect the
An increase in population due to *"cr citv and county parks would receive

way local recreational resources are used, c	y rt fishing and boating,

greater visitor pressure, as would areas t	Di-n appropriately for future

Presumably, the City and the Cou"^	important cultural resources, and

anticipated growth. Parks and open spaces ar	P. . t

should be planned with the use of adequate f	9

3.2.3 Alternatives Impact" summary

and wherever man-made development
Environmental damage occurs whenever di8D08al are agricultural spray
occurs. The alternative methods of effluent disposal i a*ion> artificial

irrigation, forest 8Pra*	infiltration basins (RIBS), and/or on-lot

(constructed) wetlands with rapid-infiltration

systems.

-j-wwub.	archeological, historical and

Damage to floodplains and wetlands, an idable if proper planning is
recreational sources could be minima ,	reasonably addressed through

implemented. Human health concerns could also ftfflu#nt treatment methods,
Proper design and implementation of *pPf°Awater prior to irrigation, natural
frequent effluent monitoring of tr,a**^ prudent spraying operations, use of
ultraviolet light (sunlight) disinfect:^Sternal borders of sprayfields, use of
evergreen forested buffer areas alo"g, sorayfield area, and groundwater
forested corridors within the general P

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monitoring. (However, although it is generally documented (Crook, 1990; Asano
et al., 1992) that wastewater treatment methods can remove significant numbers
of pathogens and non-pathogenic bacteria typically associated with sewage
wastewater, not all may be killed by disinfection. In the case of pathogens such
as viruses, the surviving numbers could potentially be hazardous from a human
health perspective since even a small number of viruses can be infectious.)

The primary environmental concern would be impact on ecological resources.
Han-induced changes, due to implementation of any of the alternatives, would
surely affect the ability of the ecosystem to perforin normally. The following
points should be key in choosing an alternative:

1)	Agricultural and forest spray irrigation are proven disposal methods,
but require a relatively large land area.

2)	Artificial (constructed) wetlands for effluent treatment (i.e.,
treatment subsequent to wastewater treatment plant treatment) have been
successfully used in Europe and are showing increasing reliability in
the United States (e.g., Orlando, Florida) and require less land area
than spray irrigation methods. RIBs have been successfully used for
effluent disposal (from constructed wetland discharges) and also
require less area.

3)	No wastewater discharges are permitted to flow into Lake Lafayette;
therefore, no alternatives should include such a discharge.

4)	In general, centralized disposal methods would be subject to NPDES
permitting for point source storm water discharges to waters of the
United states for construction sites (five acres or more), for
regulated treatment facilities actually treating domestic wastewater
(at least 1 mgd), and for other regulated sites. Construction
activities needing NPDES permit coverage can be made through a
general permit recently issued by EPA/Region IV. The operation of
certain disposal methods involving point source discharges to waters
of the United States would also require NPDES permit coverage. The
operation (spray irrigation) of agricultural and silvicultural spray
irrigation sites is exempt from NPDES permitting if sites are
consistent with 40 CFR 122.3(e). storm water point source discharges
to waters of the united states from the operation (spray irrigation)
of non-agricultural/non-silvicultural land application sites (such
as golf courses, rights-of-way, and landscape areas) receiving
domestic wastewater treated to the quality required by chapter
17-610 F.A.C. for the land application of reclaimed water are not
required to be covered by NPDES permits, unless the USEPA
specifically requires a facility to submit an application on
case-by-case basis. Bowever, dedicated discharges of reclaimed
water, without land application, are required to be covered by
NPDES permits, included in the spray irrigation of wastewater
effluent is the land application of wastewater sludge, section
405(d) of the Clean Water Act requires that the disposal or reuse

of sewage sludge be regulated. This regulatory activity is to be
accomplished through the utilization of permits based upon technical
federal regulatory standards. The USEPA established federal sludge
disposal/reuse standards which were promulgated in the Federal
Register at 40 CFR 503 on February 19,1993. in general, these
standards must be complied with by all treatment works treating
domestic sewage by February 19, 1994. Violation of these standards
would be a violation of the clean Water Act. it is anticipated that
current and proposed sludge disposal/reuse activities would be
regulated through an NPDES permit, where applicable, or through
issuance of a "Sludge-Only" permit. This federal permitting
activity would be issued by the USEPA/Region IV until program

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authorization is given to the State of Florida. Therefore, the
newly promulgated federal regulations are in addition to the State
of Florida sludge disposal/reuse regulations. (Note: Also see
Section 2.2.1.2 on permitting and Sections 2.4.3.1 to 2.4.3.9
(Chapter 2) and sections C-l to C-13 (Appendix C) on permitting
for alternatives.)

The centralized disposal method (on-lot systems) would not, by itself,
require an npdes permit. However, any associated centralized methods
supplementing such on-lot systems would in general be subject to NPDES
permitting as described above.

5)	The construction and operation of the alternative NE Plant would
produce a relatively large impact because of the permanent loss of that
land area. By comparison, the disposal options, such as artificial
wetlands, may be used by wildlife after construction is completed.

6)	Golf course spray irrigation acts to protect sensitive ecosystems
because it reduces the land area required to dispose of the projected
effluent volume.

7)	On-lot systems initially act to avoid environmental damage because they
eliminate the need for construction of large collection, treatment and
disposal facilities. On-lot systems, however, are known to fail,
creating serious environmental impacts, corrections of these failures
and their detrimental impacts can be expensive.

To summarize the environmental impacts of **ch system alterative for
•valuation purposes, a simple rating of the alternatives selected for further
consideration for environmental impacts was developed at the DEiss preparation
stage (1989). This alternative rating is presented in Table 3-9. It should be
noted that this environmental impact analyses does not account for a weighting
of the environmental impact characteristics, in that all the characteristics are
considered of equal importance. From the table, Alternative 2 with its expansion
of the T.p. smith Facility and the SE Forest Spray	SUm£hi.Wia

considered to have an advantage over the other	f «	av ij-riottion

primarily due to the use of privately-owned forest	£of « pray irrigation

disposal site. The use of the P^ivately-o^ed forest la^s maintains the
existing land use type and allows continued use of the	J®*wildlife

habitats. Alternative 9 was considered to have the n?xt highest ranking
•ftAterna"VB ' w®	, + f-cilities of a decentralized system

el^n Jy b.6"USeAhe U"	of l«oe wastewater management facilities

eliminates the need for construction of large	.

which immediately impact the construction area. As loted "jm 7 listed
fbove, this positive impact may be only an initial,	f J^VinfiildJ

installation of on-lot facilities proliferate, so do f**1""8 £hev accSulate'
These failures are often difficult to locate and	^

°an create serious negative environmental impac .	. . averaae ratines

considered to have eqJal ranking which results; frem. "giving	ratings.

Alternative 1 would eliminate the need fox^constJongigtfl primarily of expanding

exiS^?ent*pl*inJt ,and dAlP°Ba that can be reasonably minimized or mitigated,
•xisting facilities with impacts th®* _„of a new separate regional treatment

Dl»^natlwe 7 would r®quire th# COin^n« from this component may be off-set by the

»'™oi	»ith li',#r¦

followed by ribs.

3-3 ENVIRONMENTAL PROTECTION MEASURES

t ?he construction and continued	ro°nmental i^acts^* Environmental

treatment, and disposal system would """^v^o^entax^p	^ The

Protection measures can often be implemented to lessen

3-27

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TABLE 3-9

ENVIRONMENTAL IMPACT ANALYSES RATING

Alternatives Selected for Further Consideration





in Alternativea Analysis



Impact
Characteristicsv '

1



9

1. Surface Mater Quality

1



2

2. Groundwater Quality

1

1 1

1

3. Protected Species/Habitat

1

1 1

1

4. Floodplains and Wetlands

2

2 2

2

5. Poreeted Lands

1

3 1

2

t. Parka and Open Space

2

2 2

2

7. Archeological and
Biatorical Reaourcea

2

2 2

2

8. Noise, Odor, and
Air Quality

2

2 1

2

9. Land Uee

1

3 1

2

10. Socio-econonics

3

3 3

2

11. Aesthetics

2

2 2

2

12. Public. Health

2

2 2

2

Total
Average
Ranking ' '

20
1.(7
2

24 20
2.00 1.67
4 2

22
21.83
3

I1' Rating scale for charactariatics la aa followsi

1	- "Negative" impact

2	- "Neutral" impact

3	- "Positive" impact

These three ratings are Bade from the perspective of the reaource
use/management of the altarnativa area involved, e.g./

Alternative 2 may have a "positive" or "neutral" impact on
forested lands (item #5) since forest irrigation is proposed for
Alternative 2, but could alao have a "negative" secondary iapact
if, aa a result of such effluent disposal, local development is
encouraged and results in land clearing and loss of forested
areas. These three ratings could in sons cases perhaps also be
tensed aa •negative* (1), 'moderate* (2), and 'minimal/neutral"

(3) impacts.

<2> Ranking of altemativee goes from most negative impact (-1) to most positive

iapact (»4). When a tie axiats, both alternativea are aasigned the same numerical
ranking. Ranking is not statiatically treated.

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environmental protection measures discussed beLow are not intended as the only
available possibilities.

3.3.1 Surface Water

The integrity of surface water resources is of prime concern during

wastewater disposal process, but degradation can also °°cur ^£9 (Sd
of the wastewater collection and treatment facilities. ^ ^equate aroaion_and
sedimentation control measures should be implemented whenever appropriate. This
is particularly relevant at the alternative NE Plant site, and for the pipeline
from the TPS Plant to the alternative SE disposal site.

Th. locating of spr.yfi.ld area. within the

5S"5,11.r*?SrdKtf«100,1 t0JT,rr^; vacatative cover i. recommended, and .hould

J °; £&££ around US .'"KhTSS nin, o.planted «£,J-"-**

reduce or eliminate an,..urfac., water^

in the field areas. The use of appropriate waste	yy direct surface water

agricultural and forest aprayfieldsvould

contact along with the prudent timing 01 appxi^ „„v_

spraying immediately prior to and during storm events.

3.3.2 Groundwater

The groundwater quality at. any of	etm^S^ SThi!

could be degraded if normal aoil-wastewater i	lav#lg of bacterial,

is of special concern if the appUedeff luen	^ 9^ t0ntlal im best made

viral, and nutrient concentrations.	on acceptable soil types and

with the use of appropriate application rates on accept

effective secondary wastewater treatment.

3.3.3 Ecological Resources.

J I *1 I ^	aWVAWMAWW-1- 		¦¦	•

• mm! i a be at least two key impacts to
As discussed in section 3.2.1..3,	lo8B ef habitat and human contact,

existing terrestrial and aquatic aC ®X__ which alternative is chosen. For
Both of these can be reduced, depending ° f ^ ft form of environmental
example, golf course irrigation w°^l_	additional disposal ar®as! ^

protection because it eliminates th9 t, _jg and rapid infiltration k**in »
the use of artificial (constructedRequirement "duced but valuable
in Alternative 7, not only is the total uaiiy be created. Environmental
terrestrial and aquatic ecosystems caii conjunction with the SB a9r^°u^"£?®*
protection measures would be most oee	existing forest cover a

spray irrigation facilities. ww«j « 'additional impacts can be reduced
vegetation would create wildlife 108888' buffer zones, and the *b8®"c®
by the use of wildlife movement corrif0";ip of essentially undeveloped land
fences. A corridor would consist of a "trip cypreas swamps. Buffer zones
connecting areas of high ecological value 'areas, and would be
would serve as wildlife food andcove;c f\6ld areas, if P°"lblVo	akout

around all sides of the agricultural fie ^ relatively free

eliminating the use of fences, wildlif® woul	naCessary. **VA^Ld in

their home range or migrate to breeding groun^	area8 would also aid in

°r diminished use of human contact

reducing the impact to wildlife.	ahould involve

Environmental protection ^9 the	^ ^h.r wiWH^^v.rJy

avoiding the unnecessary destruction , a limited number of des g . .

keeping heavy construction equipmen during periods which wo"^-	Tortoises,

construction should also be carried wtd^ing|	rrogs, Gopher Tortoises,

reproductive behavior or migratory

*hd other native wildlife.

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3.3.4 Floodplains and Wetlands

The use of construction equipment in floodplains and wetlands should be
avoided, and ideally, a buffer zone should be maintained between construction
areas and these sensitive areas. Surface water resources within wetlands can be
protected by the appropriate use of erosion and sedimentation control measures.
If any alteration of wetlands is to take place during construction, the
appropriate wetland permits must be obtained from the FDER and the U.S. Army
Corps of Engineers (COE), Jacksonville District. Compliance with the State of
Florida and any Leon county regulations regarding wetland dredge-and-fill
activities would also be necessary.

3.3.5	Archeoloqical. Historical, and Recreational Resources

Avoidance and minimization of impacts on archeological and historical sites
should be achieved by preceding any construction with a professional
archeological survey so that proper assessments of known sites and potential new,
yet uncovered/unrecorded sites can be realized. If additional sites not
identified in the survey are found during actual construction, construction
should be stopped and the Florida SHPO contacted. In addition to site avoidance
and proposed project design modification, measures such as evaluation,
excavation, and relocation of certain identified sites may be possible through
coordination with the Florida SHPO.

Recreational resources are abundant in the areas surrounding Tallahassee.
Numerous lakes and ponds serve as fishing, boating, and swimming resources, and
attempts should be made to avoid impacts to them. The buffer zones could be
established for these areas when considering pipeline corridors and disposal
sites so that current recreational activities could continue.

3.3.6	Noise. Odor, and Air Quality

Construction of wastewater conveyance, treatment, and disposal systems would
create unavoidable but temporary noise and air quality degradation.
Environmental protection measures should meet the rules established by the FDER
and the Florida Division of Forestry. These measures include the following:

•	The use of heavy equipment to be limited to daytime hours during
the construction period.

•	All earth moving and construction equipment to use factory
specification noise suppression equipment (mufflers, engine
enclosures, etc.)

•	Fugitive dust production from grading and clearing operations and
on dirt roads to be controlled using asphalt or water.

•	Open burning of debris to be performed at locations at least 50 yards from
the nearest occupied building or public highway. Moisture content and
composition to be favorable for good burning. All open burning must be
consistent with federal, state and county particulate matter (PM)
guidelines and any other appropriate regulations. The 24-hour National
Ambient Air Quality standards (NAAQS) pm standard (PM10) is 150 |ig/m3,
while the annual standard is 50 |ig/m3.

Operation of the disposal systems is not likely to cause significant noise,
odor, or air quality impacts. Odor should be minimized since the effluent would
be treated prior to spray irrigation. Buffer zones of dense forest vegetation
would aid in minimizing noise effects and further minimize odor effects.

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3.3.7 Human Health Effects

Public health issues are primarily a concern to residents living adjacent to
or dorogcadi^rtvt/dwtMtreaiii/downwind of	^"..nd"^

utUU.d9 for .pr.y irri9«i°».<£f.r ""USon^M!

>•«*"* ££ b0»dorl*°.°ndCS..i3

T.U.h..... on July 23, 1991, °onc.rning wro.ol .pr.y	«« „r*I".

property values. Potantiha,ctfria and pathQgens (e.g., pathogenic bacteria,
containing non-pathogenic k^eriaandpat microbes) traveling away from a
viruses, protozoans, and other inrtctwuii contamination of the Floridan
sprayfield area and the pctential groundw	undwater concerns were voiced

Aquifer, a drinking water source. For examp '.^1H in Tallahassee on August 9.
by the public during the USEPAPublic H®a* g also be of concern if effluent
1990. Post-irrigation use of the golf courses may axso «
pathogens are not completely disinfected.

,, J	4. ^ ,-rnnk 1990' Asano et al., 1992) that wastewater

It is generally documented ("ook, ^ Qf"pathogens and non-pathogenic

treatment methods can remove	" wastewater. However, not all may be

bacteria typically f8BOciTat®^aw^3_ ®f 5athogens such as viruses, the surviving
killed by disinfection, in the case of pa g ^ heaith perspective since even

numbers could potentially be ha£arf°*®However, several precautions can

a small number of viruses can be	* t BDray irrigation sites. These

be taken to reduce the hu»*ri he«lth r	on-site containment of aerosols,

include effluent treatment, effluent monitoring,

and groundwater monitoring.

. _j i.,, <-hat. citv effluent is disinfected in
The USEPA understands from the City tn	raquirements. The City's

accordance with state of Florida "tand
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The USEPA understands from the city of Tallahassee that fecal coliform levels
are monitored by the City before effluent is spray irrigated on sprayfields and
after irrigation via groundwater monitoring. The USEPA also understands from the
city that the water quality limits for fecal coliform levels used by the City for
effluent prior to sprayfield irrigation is the state of Florida standards
defining "secondary treatment" of wastewater, i.e., <200 organisms per 100 ml of
effluent. Although there are no USEPA or federal standards for fecal coliforms
for spray irrigated effluent, this criterion is consistent with USEPA guidance
from the Requirements Memorandum #79-3 dated November IS, 1978 of the former
Construction Grants Program (USEPA, 1978). The concepts of this memorandum were
incorporated in a USEPA Technology Transfer manual entitled "Land Treatment of
Municipal Wastewater" (USEPA No. 625-1-81-013) (USEPA, 1981). The 200 counts/100
ml of effluent criterion is USEPA's fecal coliform criterion for bathing
(swimming) waters, it is presumed that water considered safe enough for swimming
(which could include incidental drinking) would be adequate for irrigation of
sprayfields, particularly with vegetated buffers. In the absence of federal
standards regarding acceptable remaining levels of fecal coliforms in sprayed
effluent, the USEPA recommends that the State of Florida the use, at a minimum,
the above federal guidance (USEPA, 1981) to help protect public health and the
environment during their permitting decision for effluent sprayfields in addition
to any appropriate state of Florida regulations (Chapter 17-640 F.A.C.) for
public access areas.

The spray application of wastewater to golf courses and other public access
areas, which would provide greater public exposure than agricultural or forest
sprayfields, requires additional treatment for suspended solids removal and high-
level disinfection under State of Florida regulations. Compliance with these
regulations should greatly reduce the health risks associated with aerosols at
golf courses. Irrigation of golf courses using wastewater effluent is also not
an uncommon practice since 84 golf courses in Florida were being irrigated with
wastewater as of 1991. Zn addition, golf course spray irrigation would require,
per FDER stipulation that an alternate disposal method be made available as a
back-up.

Potential public health effects from animal vectors at spray irrigation sites
would be minimized through effluent disinfection, such effects could be further
minimized through prudent spraying operations that allow acceptable effluent soil
infiltration rates that avoid ponding.

Human health concerns also exist for potential groundwater contamination
of the Floridan Aquifer drinking water source. After application of the
wastewater effluent to land surfaces, the wastewater infiltrates into the soil
and interacts physically and chemically to remove the potentially harmful
constituents not removed during effluent treatment. It is possible that some of
these constituents could move quickly through the soil (depending on soil
characteristics and depth). Once this occurs, groundwater flows can carry the
untreated metals, pathogens, nitrogen, etc. to wells which are used by humans as
a drinking water source.

The City is conducting an on-site groundwater monitoring program for its
existing effluent sprayfields. Historically, over 60 monitoring wells have been
drilled and tested at the SE sprayfield site during interagency cooperative
studies. Although the City has been monitoring wells for some time, the State
of Florida required monitoring via a Groundwater Monitoring Program by permit
condition since November 1, 1984. The city now quarterly monitors seven (7)
compliance wells at the SE sprayfield for six (6) parameters: NO, (nitrite) and
NOj (nitrate) as nitrogen; nitrites; total Kjeldahl nitrogen; chlorides;
dissolved organic carbon (DOC); and fecal coliforms. Pesticides and herbicides
are also monitored annually.

Based on this monitoring program, the USEPA understands from the City that
the city discovered five (5) nitrate-nitrogen groundwater quality violations in
the seven compliance wells at the City's SE Sprayfield. Expected causes of these

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violations included a faulty well construction, application techniques for
additional (non-effluent) fertilizer, and possibly jon-site cattle burial.

overall, four (4) other violations (also for nitrat0",ij:t^°genJlv"®"J2i	~

one of the two compliance wells at the City's SW Sprayfield. J*Pecte
-------
disposal methods such as agricultural irrigation, forest irrigation, and
artificial (constructed) wetlands.

Another key to reducing potential impacts is to use proper caution when
locating the disposal facilities. For example, agricultural and forest spray
irrigation facilities should be placed 1) as far as possible from wetlands or
other surface waterbodies, 2) in upland areas, where infiltration and percolation
rates are more favorable, and 3) in areas where large buffer zones possessing
dense vegetation can be maintained as sheet-flow reduction areas and as wildlife
corridors. Specific environmental protection measures for the preferred
alternative (Alternative 1) are provided in chapter 4.

In summary, the best environmental protection measures are those that create
the most environmental protection while allowing the designed facilities to
operate properly.

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CHAPTER 4

PREFERRED
ALTERNATIVE

-------
CHAPTER 4 PREFERRED ALTERNATIVE

4.1 SELECTION OF THE PREFERRED ALTERNATIVE

Given the nine alternatives considered and the four alternatives (1, 2, 7 and
9) selected for further study in the EIS supplement, the USEPA finds Alternative
1 to be an acceptable alternative. Alternative 1 is a practical alternative that
represents a continuation of the City's successful agricultural spray Irrigation
approach to the disposal of treated effluent through an expansion of the city's
SE Sprayfield, as well as the irrigation of existing golf courses. As such, the
USEPA considers Alternative 1 as the preferred alternative for the EIS
Supplement. However, the USEPA is not requiring the implementation of
Alternative 1 since this EIS supplement is discretionary and there are no federal
funds and no major federal action proposed for Alternative 1 (or for Alternatives
2, 7 or 9) at this time. Unless the proposed project becomes a major federal
action, the selection of an appropriate alternative for the City of Tallahassee
wastewater management would be a local decision.

The USEPA selection of Alternative 1 as the preferred alternative was based
on the ratings for the cost-effectiveness, reliability, implementability, and
environmental impact categories presented in Chapter 3. Table 4-1 is a matrix
summary of the rankings for these categories for each of the four system
alternatives (1, 2, 7 and 9) selected for further consideration in the EIS
Supplement. This matrix evaluation was developed at the DEISS preparation stage
(1989) . Although a somewhat subjective analysis, it should be noted that all of
the characteristics addressed during the category rating process and all of the
categories addressed during the ranking process were considered of equal
importance. Weighting of the items would have been difficult to justify because,
although certain items could be considered more "important" than others, the
determination of a specific weighting value is highly subjective and dependent
on the wants and needs of an individual or organization.

TAALK 4-1

SUMMARY OF 8KUCTBD SYSTEM ALTSRHAIIVX RANKINGS <*>

SYSTEM ALTERNATIVE

2	7	9

2	14

3	2	2

4	4	3

4	2 3

13	»	12

4	2	3

(1) Ranking of alternatives goes team least preferred (-1) to Boat preferred (-4). Whan a tia
uciiti for a category, both alternatives ara assigned the ease numerical ranking. Ranking
was not statistically treated.

Table 4-1 indicates that Alternatives 1 and 2 were equally ranked highest
among the four alternatives and Alternatives 7 and 9 were ranked as less
desirable. In general, the USEPA selected Alternative 1 as the preferred
alternative for the EIS Supplement due to: 1) projected relatively low capital

Category		1

Cost-effectivsnsss	3

Reliability	4

Xaplementability	4

Environmental Impacts	2

Total	13

Overall Ranking	4

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costs, 2) the city's successful experience in operating agricultural spray
irrigation facilities for effluent disposal, and 3) negative environmental
impacts could be expected to be reasonably minimized. Alternative 1 is also a
practical approach since it would not only utilize the City's successful
experience in agricultural spray irrigation, it also proposes to expand the
city's existing SE Sprayfield as opposed to developing a new, separate spray field
facility or a new disposal approach, of the final four alternatives considered,
Alternative 1 was rated the most cost-effective of the three centralized
alternatives considered; was rated the most reliable given the City's success in
agricultural spray irrigation at the existing SB Sprayfield; was rated as one of
the three most implementable given that the proposed project would expand the
City's existing SE Sprayfield as opposed to developing a new, separate sprayfield
facility; and negative environmental impacts could be expected to be reasonably
minimized despite the fact that the proposed project was rated as one of the two
least environmentally preferable. Despite the equal, most favorable ranking of
Alternative 1 and 2, Alternative 1 is considered the preferred alternative for
the eis supplement since the city has had successful experience in agricultural
spray irrigation proposed in Alternative 1 as opposed to forest spray irrigation
proposed in Alternative 2. However, as indicated above, forest irrigation is to
be tried as a demonstration project by the city for Alternative 1 on a proposed
small portion of the Eastern Expansion spray area of the agricultural sprayfield
expansion.

Although the USEPA considers Alternative 1 the preferred alternative from a
practical perspective, the other three system alternatives further considered in
the EIS supplement (Alternatives 2, 7 and 9) also have attributes that the local
decision-makers may or may not wish to further consider in their selection of a
preferred alternative. Of these alternatives, Alternative 2 is noteworthy from
an environmental perspective. Alternative 2, as indicated above, is similar to
Alternative 1 except that it proposes forest irrigation rather than agricultural
irrigation. Overall, it was ranked equal to Alternative 1 in the 1989 matrix
evaluation, but was ranked higher environmentally. Global climate change
impacts, for example, due to land clearing of vegetation at the Eastern
sprayfield Area, would be offset to a greater degree through the irrigation of
a forest crop than an agricultural crop due to the greater biomass of the tree
crop. If the existing young pines on site could be irrigated (i.e., the site is
not cleared and replanted with a new crop of pines), global climate change
impacts would be further minimized and the existing silvicultural land use of the
Eastern Expansion Area would essentially be unaltered. In addition, the
potential for soil erosion would be significantly reduced if the existing trees
would be irrigated or if the existing trees are harvested and replanted with a
new crop of trees without the clearing and grubbing (stump removal) required for
an agricultural crop. The City and the pulp and paper company that owns the land
may reach a mutually beneficial agreement involving effluent utilization for
silviculture, on the other hand, disadvantages for Alternative 2 would appear
to be the city's inexperience in forest irrigation (although forest irrigation
is being successfully used at 66 sites in the southeast, including 31 in Florida)
and operational considerations such as understory maintenance of the tree crop
and use of "drip" irrigation as opposed to "spray" irrigation (which may reduce
the per-acre effluent disposal capacity of the operation and therefore require
a larger sprayfield land area). The small forest irrigation demonstration
project that the City is to try as part of Alternative 1 (if implemented), should
provide an excellent opportunity for local decision-makers to compare the merits
of agricultural irrigation versus forest irrigation. Operational, environmental
and nutrient uptake (crop nitrogen demand) aspects of each technique would need
to be considered.

4.2 SUCCESS OF CITY'S SB AND SW SPRAYFIELD OPERATIONS

The city's experience with agricultural spray irrigation disposal operations
has been successful at the existing SE Sprayfield, and the production of animal
feed crops and/or processed foods for humans has reduced operational costs. The

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USEPA understands from the City that the City has been continuously spraying its
SE sprayfield since January 1981 (experimental spraying was initiated in fall of
1980). Continuous spraying at the sw sprayfield for effluent disposal was begun
in 1978, with experimental spraying starting in 1972. As such, the SE sprayfield
has been successfully used for continuous spraying for some 13 years and the SW
sprayfield for some 15 years. In regard to environmental impacts of the
operation, the city disinfects its wastewater at the expanded T.P. Smith
Treatment Plant and the LBR Treatment Plant, further treats the treated effluent
before it is spray irrigated, and also conducts a groundwater monitoring program.

The USEPA understands from the City that City effluent is disinfected in
accordance with State of Florida standards and permit requirements. The City's
wastewater treatment processes are the activated sludge process, chlorination,
and natural ultraviolet light (sunlight) treatment in the holding ponds. Prior
to effluent spray irrigation, the City also monitors its effluent for 40
parameters including 17 metals on a monthly basis; monitors for 11 parameters
(biochemical oxygen demand (BOD), total suspended solids (TSS), total nitrogen,
residual chlorides, pH, fecal coliforms, and other parameters) on a twice a week
basis; and monitors for the six (6) above parameters on a daily basis.

The City is also conducting an on-site groundwater monitoring program for its
existing effluent sprayfields. Historically, over 60 monitoring wells have been
drilled and tested at the SE Sprayfield site during interagency cooperative
studies. Although the city has been monitoring wells for some time, the state
of Florida required monitoring via a Groundwater Monitoring Program by permit
condition since November 1, 1984. The City now quarterly monitors seven (7)
compliance wells at the SE Sprayfield for six (6) parameters: N02 (nitrite) and
N03 (nitrate) as nitrogen; nitrites; total Kjeldahl nitrogen; chlorides;
dissolved organic carbon (DOC); and fecal coliforms. Pesticides and herbicides
are also monitored annually.

Based on this monitoring program, the USEPA understands from the city that
the city discovered five (5) nitrate-nitrogen groundwater quality violations
(1989, 1990 and 1991) in one of the seven compliance wells at the city's SE
sprayfield, and four (4) nitrate-nitrogen groundwater quality violations (1986,
1987 and 1988) in one of the two compliance wells at the city's sw Sprayfield.
These exceedances have been resolved by the City through corrective actions and
monitoring has shown no additional groundwater quality violations since 1991 for
parameters monitored. As a rule, nutrient groundwater quality problems can be
minimized or prevented. (Additional discussion on the city's groundwater
monitoring program is presented below in Section 4.6.)

4.3 STATUS OF LOCAL DECISION-MAKERS SELECTION PROCESS

As indicated previously, the USEPA is not requiring implementation of
Alternative 1 as the preferred alternative since this Eis Supplement is
discretionary and there are no federal funds and no major federal action proposed
for Alternative 1 (or for Alternatives 2, 7 or 9) at this time. Unless the
proposed project becomes a major federal action, the selection of an appropriate
alternative for the City of Tallahassee wastewater management would be a local
decision.

At the time of issuance of this FEISS, a proposed Tallahassee wastewater
management alternative had not been finalized. Local decision-makers including
the city of Tallahassee, city Commission, Leon County Board of County
Commissioners (County commission), citizens Advisory Committee (for a NE
treatment plant), Citizens Advisory Committee (for effluent disposal) and the
general public were continuing to locally review the project in terms of
acceptability, design, prioritization, and implementation. As such, the contents
of this FEISS may not include any or all aspects of the ultimate approach locally
selected. The FEISS will serve, however, to provide technical guidance to local
decision-makers and the public.

The USEPA understands from the city of Tallahassee that the Leon County Board
of County commissioners has denied (July 23, 1991) two Leon County sewer
"franchise" applications for right-of-way placement permits for the proposed

4-3

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City's expansion of the SE Sprayfield and the associated expansion of an effluent
force main from the T.P. Smith Treatment Plant to the SE Sprayfield. The USEPA
understands from the city that the County's actions are made in response to
citizen concerns regarding aerosol spray drift, odor, and decreased property
value were voiced by some 20 speakers in a public hearing held by Leon County in
Tallahassee on July 23, 1991. As a consequence, the City's proposed Eastern
Expansion area (part of Alternative 1) is presently denied by Leon County. The
County has requested that the City revise/update the 1988 City Master Sewer Plan
(MSP) and that the City present various wastewater alternatives with cost
estimates to the County for consideration.

Additional project updates related to the preferred alternative and
Tallahassee wastewater management in general are provided in the "Project Updates
summary" Chapter following the Executive Summary of this FEISS. Updated topics
include: treatment plant and sprayfield capacity reratings and/or expansion,
Leon County action on NE treatment plant, Leon County action of SE sprayfield
expansion, City of Tallahassee Action on T.P. Smith Plant expansion, Citizens
Advisory committee action on disposal site priorities. City Commission action of
SE sprayfield expansion, artificial wetlands alternatives, USEPA action on storm
water regulations, and USEPA action on sludge permitting.

4.4 DESCRIPTION OF THE PREFERRED ALTERNATIVE

Alternative 1 is referred to as a centralized "treatment south"
alternative. This means that all untreated sewage effluent flows would be
conveyed to southwest Leon County to receive secondary treatment at either the
improved LBR Wastewater Treatment Plant or the expanded TPS Wastewater Treatment
Plant. The preferred alternative proposes disposal of the treated water from the
LBR Plant via a spray irrigation operation at four (4) local existing golf
courses: Florida state University, Jake Gaither, Capital city Country Club, and
Hilaman Municipal. Alternative 1 further proposes that the treated wastewater
from the TPS Plant would be transported to the proposed expanded SE Sprayfield
for final disposal. The sprayfield expansion proposed in Alternative 1 consists
of Eastern and Western Expansion Areas.

The Eastern Expansion Area is being leased by the City from a forest-products
company (St. Joseph Land and Development Company) and consists of approximately
1,830 total acres. The preferred alternative proposes that approximately 9 09
acres are to be utilized for spray irrigation (Update: The USEPA understands from
the city of Tallahassee that the 909 acreage figure and/or the configuration of
the spray areas may be changed by local decision-makers if Alternative 1 is
implemented). Although forest spray irrigation is to be tried for an
undetermined number of acres by the City for Alternative 1 on a small
demonstration project basis, the majority of the 909 acres are to be utilized for
agricultural spray irrigation. The agricultural crop rotation is expected to
include corn, soy beans, canola, and rye/rye grass for hay. All agricultural
crops produced from effluent sprayfields are not for direct human consumption and
must be utilized consistent with the State of Florida regulations. Accordingly,
irrigated crops produced by the City from the proposed Alternative 1 may only be
utilized as animal feed (e.g., cattle feed) and/or as processed food for humans
(e.g., canola oil: soy bean oil) to the extent consistent with chapter 17-610
F.A.C. The remaining acreage of the 1,830 total acres would either be actively
managed by the St. Joseph Land and Development Company or set aside as wildlife
corridors.

As previously indicated, an undetermined number of acres proposed for spray
irrigation at the Eastern Expansion area are to be used by the city for forest
spray irrigation as a small demonstration project. The forest spray irrigation
acreage is planned for cultivation in the northwest portion of the Eastern
Expansion Area. The tree species in this small demonstration project would
utilize the typical existing St. Joseph Land and Development company's pine
plantation species (primarily young slash and sand pine), so that land conversion
in this area would not be needed for the forest spray irrigation. The City plans
to operate the demonstration project site initially and is investigating existing
forest spray irrigation operations in Clayton County, Georgia for guidance (the
Clayton county site is currently one of 66 forest application sites in the

4-4

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southeast including 31 in the state of Florida). It is anticipated that'in the
future, the city would involve a private entity for harvesting trees. Specifics
on crop management practices have not yet been finalized.

The Western Expansion area proposed in the preferred alternative consists of
approximately 1,280 total acres. Although part of the Alternative 1 proposal to
expand the City's SE Spray fie Id, the USEPA understands form the City that the
land for the Western Expansion area has not been acquired, no near-future
construction plans have been made for the site, and no future activity is planned
there.

Figure 4-1 presents the soil associations of the Eastern Expansion Area based
on the 1981 Leon County Soil survey (USDA [SCS] and USFS, 1981). Figure 4-2
illustrates the "proposed" wildlife corridors as well as sensitive resources such
as surface waterbodies and archaeological sites in the Eastern Expansion Area of
Alternative 1. Because the Western Expansion Area is not proposed for
development by the city at this time, it was also considered in Figure 4-3,
although to a lesser degree. As a part of Alternative 1 and in the event of any
potential future land acquisition, wildlife corridors and a pivot irrigation area
for the Western Expansion area have been "suggested" and are depicted in Figure
4-3 along with associated selected sensitive resource areas. No site-specific
cultural resource inventory was conducted for the Western Expansion area.

4.5 SOIL ASSOCIATIONS OF THE PREFERRED ALTERNATIVE

Based on the 1981 soil Survey (USDS [SCS], USFS) the soils of the Eastern
Expansion Area sprayfield site proposed by the City are dominated by Ortega Sand,
Kershaw sand with a 0-5% slope, Talquin Fine Sand, Chipley Fine Sand and Kershaw
Sand with a 5-8% slope, respectively (Fig. 4-1). Of these, only the Kershaw
sands are classified in the Soils Survey as favorable for septic tank absorption
fields (classified as "slight," i.e., having favorable soil properties for the
activity).

Of the portions of the proposed Eastern Expansion Area sprayfield proposed
for irrigation (i.e., center pivot irrigation Areas A-E and adjacent fixed head
irrigation areas: Fig. 4-2), irrigation areas associated with and adjacent to
Areas A, B, and D primarily contain Kershaw sands while irrigation areas
associated with and adjacent to Areas C and E primarily contain Ortega Sand.
As indicated, Kershaw Sands are considered suitable soil types for septic tank
absorption fields while Ortega Sand would not be favorable due to poor filtration
capabilities (too well-drained sands). However, it should be noted that the
City's proposed project is not septic tank disposal of raw sewage, but rather
spray irrigation of monitored, secondarily-treated sewage effluent. As such,
spray irrigation would disperse effluent over a greater area than septic tank
disposal and also would dispose wastewater of a considerably higher water quality
than untreated raw sewage wastewater of septic tanks. (Specifically, all of the
vertical soil horizons are utilized for filtration during spray irrigation
whereas several inches of soil filtration are not utilized in septic tank
drainage fields, since drainage lines are buried several inches below the
surface; spray irrigation utilizes the entire horizontal soil surface area
whereas septic tank fields only utilize soil areas associated with the drainage
lines; and secondarily-treated spray effluent requires considerably less soil
filtration for purification than untreated septic tank raw sewage wastewater.)

Because of the filtration limitations of the Ortega Sand in the proposed
irrigation areas associated with and adjacent to Areas C and E as well as some
unfavorable soils interspersed in irrigation areas associated with and adjacent
to Areas A, B and D, the USEPA recommends reduced irrigation application
(inches/week) in these areas. If monitoring exhibits compliance with state of
Florida groundwater quality standards and monitoring is conducted to the
satisfaction of the state of Florida, additional application can be tried if
commensurate with groundwater quality compliance. Groundwater monitoring is also
essential since the entire Eastern Expansion Area lies in the Woodville Karst
Plain, i.e., Karstic geology that is subject to water dissolution and collapse
(sinkholes). In any areas of collapse, irrigation should be stopped immediately

4-5

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o
c

70

rn

SOURCE : TAKEN FROM USDA SCS,
•	LEON COUNTY SOIL SURVEY,I9SI

LEGEND

8

CHIPLEY FINE SANO

0-2% SLOPES

18

KERSHAW SANO

0-5% SLOPES

19

KERSHAW SANO

5-8% SLOPES

37

ORTEGA SAND

0-5% SLOPES

43

RUTLEGE LOAMY FINE SANO

39

PELHAM FINE SANO



47

TALOUIN FINE SANO



5

BLANTON FINE SANO

0-5% SLOPES

1

ALBANY LOAMY SAND 0-2% SLOPES

48

TROUP FINE SAND

0-5% SLOPES

24

LUCY FINE SANO

0-5% SLOPES

23

LEON SAND



42

PUJMMER MUCKY FINE SAND DEPRESSIONAL

45

SAPEL0 FINE SANO



A

SINK OR DEPRESSIONAL AREA

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT
EASTERN EXPANSION SPRAYFIELD

SOILS MAP
PREFERRED ALTERNATIVE

l«00	0	1600	3200

scale in feet

GANNETT FLEMING ENVIRONMENTAL ENGINEERS, INC.
HARRISBURG , PENNSYLVANIA	FEBRUARY , l»»l

-------
N

LEGEND

\//X CENTER PIVOT IRRIGATION
p&Ml FIXED HEAD IRRIGATION AREA

SF3

8L&36
~

ST JOSEPH S ALTERNATE
ROW LOGGING AREA

WILDLIFE CORRIDOR-PROPOSED
WATERBODY

NEWLY RECORDED (SURVEYED)
ARCHEOLOGICAL SITE (PENTON,
1991 )

LISTED ARCHEOLOGICAL SITE
SINK OR DEPRESSIONAL AREA

FI6

SOURCE. CITY OF TALLAHASSEE

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT
EASTERN EXPANSION SPRAYFIELD

WILDLIFE CORRIDORS (PROPOSED)
AND SENSITIVE RESOURCES
PREFERRED ALTERNATIVE

SCALE IN FEET

GANNETT FLEMING ENVIRONMENTAL ENGINEERS ,INC.
HARRlSByftG .PENNSYLVANIA	MARCH , 1992

FIGURE 4-2

-------
N

LEGEND

Y//\ CENTER PIVOT IRRIGATION AREA
I I WILDLIFE CORRIDOR - SUGGESTED

WATERBODY

81*48 LISTED ARCHEOLOGICAL SITE

( NOTE : WESTERN EXPANSION AREA
WAS NOT SURVEYED FOR NEW
ARCHEOLOGICAL SITES; NO NEAR
FUTURE CONSTRUCTION IS PLANNED
IN THIS AREA )

8Le 548

SOURCE. CITY OF TALLAHASSEE

TALLAHASSEE - LEON COUNTY
ENVIRONMENTAL IMPACT
STATEMENT SUPPLEMENT
WESTERN EXPANSION SPRAYFIELD

WILDLIFE CORRIDORS (SUGGESTED)
AND SENSITIVE RESOURCES
PREFERRED ALTERNATIVE

SCALE IN FEET

GANNETT FLEMING ENVIRONMENTAL ENGINEERS , INC .
HARRIS BURG .PENNSYLVANIA	FEBRUARY, (991

FIGURE 4-3

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in those areas and the state of Florida notified. The usepa recommends that no
effluent be sprayed in a reasonable surrounding area of the existing sinkhole
depressional area located within the proposed fixed head irrigation area adjacent
to Area D, as well as any other potentially discovered sinkhole areas (See Fig.
4-1). The USEPA further recommends that the state of Florida consider the
existing soil characteristics and Karstic conditions of the proposed Eastern
Expansion Area in their permitting decision for the city's proposed sprayfield
expansion.

Although the western Expansion area of preferred Alternative 1 is not, as
indicated above, proposed by the City for near-future construction, it may be
noted that this area is characterized by Kershaw Sands based on the Leon County
soil survey (USDA [SCS] and usfs, 1981). As indicated above, the Kershaw Sands
have excellent drainage and filtration characteristics.

4.6 ENVIRONMENTAL IMPACTS OF THE PREFERRED ALTERNATIVE

Environmental impacts of the preferred alternative include water quality
(groundwater, surface water, and wetlands), habitat loss, protected species,
archeological, public health, and land-use concerns. Primary/secondary
environmental impacts and environmental protection measures for Alternative 1 are
described below in Subsections 4.6.1/4.6.2 and Section 4.7, respectively.

4.6.1 Primary Environmental Impacts

The most critical primary impacts of the preferred alternative would be
potential groundwater and surface water contamination; the removal of trees in
the sprayfield area; loss of habitat for protected faunal species in the area
(Gopher Frog, Gopher Tortoise, Eastern Indigo snake, and Florida Pine Snake); the
possible disruption of the Gopher Frog migration paths for breeding in
waterbodies; the possible disruption of habitat suitable for the Panhandle Golden
Aster, a protected floral species in the area; and the Panhandle Meadow Beauty,
a candidate protected floral species in the area; impacts to known and possibly
to potential, uncovered/unrecorded archeological sites; and possible human health
effects.

Groundwater and surface water contamination could result from the spray
irrigation of effluent at the expanded SE Sprayfield (and the four golf courses).
Factors that could lead to this include the following:

•	Inadequately treated wastewater coming from the TPS Plant or LBR Plant.

•	Inadequate farm operations which include incomplete harvesting to
remove all vegetation from the fields and improper cultivation
resulting in low crop yields and therefore low nutrient uptake.

•	Excessively high effluent application rates.

•	Application of effluent immediately prior to, after, or during storm
events.

•	Location of sprayfield areas over -live" Karstic sinkholes (depressions
with standing water) and other unfilled Karstic depressions (potential
groundwater contamination).

•	Location of field areas on soils with high clay content (potential
surface water contamination) (Refer to Figure 4—1 for soils map of
Eastern Expansion Area of SE Sprayfield).

•	Inadequate storm water management facilities (potential surface water
contamination).

A. indicated above, the city is conducting an on-site groundwater
®°nitoring program for its existing effluent sprayfields. Historically, oyer60
®®nitoring wells have been drilled and tsittd at tht SE sprayfield sits during
^tarag^ncy cooperative studies • Although the City has been monitoring wells for

4-9

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some time, the State of Florida required monitoring via a Groundwater Monitoring
Program by permit condition since November 1, 1984. The City now quarterly
monitors seven (7) compliance wells at the SE sprayfield for six (6) parameters:
NO, (nitrite) and N03 (nitrate) as nitrogen; nitrites; total Kjeldahl nitrogen;
chlorides; dissolved organic carbon (DOC); and fecal coliforms. Pesticides and
herbicides are also monitored annually.

Based on this monitoring program, the USEPA understands from the City
that the City discovered five (5) nitrate-nitrogen groundwater quality violations
in one of the seven compliance wells at the City's SE Sprayfield. The USEPA
further understands from the City that these violations occurred at Compliance
Well No. SE-22 during 1989, 1990 and 1991 and that expected causes included a
faulty well construction, application techniques for additional (non-effluent)
fertilizer, and possibly on-site cattle burial. The nitrate concentrations in
Compliance Well No. SE-22 during those sampling periods were 10.7 mg/1 and 10.1
mg/1 (1989), 10.3 mg/1 and 10.8 mg/1 (1990) and 10.2 mg/1 (1991), compared to the
10.0 mg/1 State of Florida limit for groundwater nitrate-nitrogen. Overall, four
(4) other violations were monitored (also for nitrate-nitrogen) at one of the two
compliance wells at the City's SW Sprayfield during 1986, 1987 and 1988. The
USEPA understands from the City that expected causes included the fact that a
stockpile of dewatered sludge was placed near Compliance Well No. LS-25. The
nitrate concentrations in Compliance Well LS-25 were 11.8 mg/1 (1986), 10.3 mg/1
and 11.0 mg/1 (1987) and 11.2 mg/1 (1988). The USEPA understands from the City
that the exceedances in these two wells were reported to the FDER by the City as
part of their quarterly reports and that the FDER responded by writing a letter
and by discussing some of the violations with the City. The USEPA also
understands from the city that the above exceedances involving the faulty well,
additional fertilizer, dewatered sludge, and possibly on-site cattle burial were
resolved by the corrective actions of constructing a new nearby well and
adjusting farming techniques at the SE Sprayfield, and by removing the sludge at
the SW Sprayfield, and that monitoring has shown no additional groundwater
quality violations since 1991 for the parameters monitored. As a rule, nutrient
groundwater quality problems can be minimized or prevented.

As exemplified above by compliance Well No. LS-25, the disposal fields for
sludge generated during the treatment of the wastewater would also have the
potential for groundwater contamination. Generated sludge would be disposed by
land application near the TPS Facility, the SW Sprayfield for dewatered sludge
disposal, and an expanded airport site for liquid sludge disposal. The city has
a groundwater monitoring program in effect for the airport sludge fields. The
wells are tested quarterly, with results reported to the FDER. Data from
groundwater monitoring wells have shown some nitrogen exceedances, which have
been addressed and corrected for areas outside the sludge field property line.
The FDER apparently believes that the sludge field is in compliance outside of
the property line in terms of the nitrogen parameter. According to the City, the
compliance wells located down-gradient of the sludge field and in the Floridan
Aquifer, a drinking water source, have shown no violations of drinking water
standards. The sludge field site, however, is apparently at capacity based on
FDER nitrogen level determinations.

The environmental concerns associated with potential contamination of
surface water from spray irrigation include the generation of nutrient-rich
surface water runoff. Such runoff could potentially cause eutrophication of
surface waterbodies and wetlands in the sprayfield (e.g., Eagle Lake, Turf Pond,
Bonnett Pond in the Eastern Expansion area), of the St. Harks River system
adjacent to and south of the Eastern Expansion Sprayfield (the St. Marks River
is classified as an Outstanding Florida Water), and of the groundwater via
Karstic sinkhole direct access areas. Agricultural practices should therefore
include creation of 6- to 8-inch earthen berms along the sprayfield area/wildlife
corridor boundaries (See Figure 4-2 for proposed boundaries within the Eastern
Expansion area) as part of the leasing farmer's initial field plowing
preparations. For stability, the berms should be vegetated (herbaceous ground
cover) as soon as practical. Such berms would help contain surface water runoff
and allow percolation and soil filtration of the applied effluent in designated
sprayfield areas, slightly higher berms (10-12 inches) should also be created
around identified sinkholes (See Figure 4-1 and 4-2 for Eastern Expansion area),

4-10

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to divert flows away from such direct groundwater access areas. City spray
application rates must be in compliance with state of Florida permit conditions
and should be adjusted according to weather conditions, which would help prevent
effluent over-application and reduce surface water runoff if these conditions
would be expected to cause detrimental environmental or human health effects or
be considered to be ineffective from an effluent disposal perspective (Also refer
to Section 4.6.2 for human health effects under "Secondary Environmental
Impacts").

The loss and disruption of contiguous wildlife habitat would result from
conversion of the land area of the proposed Eastern Expansion to a sprayfield
area. The loss of suitable habitat for wildlife such as the protected Gopher
Tortoise, Indigo Snake, and Florida Pine snake, as well as the disruption of
Gopher Frog reproductive migration routes, would be of concern. The acreage to
be converted to spray irrigation area would consist of approximately 909 acres,
which presently supports young slash pine (254 of area) and sand pine (75% of
area). The majority of the 909 acres would be cleared in preparation for the
agricultural sprayfield. The remaining acres would not need to be cleared for
conversion since this acreage (around Center Pivot Area A m the northwest
portion of the Eastern Expansion area: See Figure 4-2) is to be used for the
small forest irrigation demonstration project to be tried by the City, which
would utilize the existing young pines for forest irrigation.

As a consequence of the land-clearing activities proposed for the Eastern
Expansion area, approximately 85% of the existing on-site Gopher Tortoise habitat
(sandy, upland areas) would be converted to a spray irr^ation field. However
the remaining 15% of the suitable habitat areas is to be protected by inclusion
in the proposed wildlife corridors, i.e., the n«tur»i

to spray irrigation areas within the Eastern Expansionarea d*pictedin Figure
4-2. Protection of the remaining 15% of citable *^tat was	by the

Florida Game and Fresh Water Fish commission (FGiFWFC). to ®"ur« 1J*
on-site existence" of the protected Gopher Tortoise, Gopher Frog, Eastern Indigo
and Florida Pine Snake. (See FG&FWFC letter dated February 6, 1991 in chapter
5 included as part of usEPA's response to DEISS Letter 90'o acreaoe fioure and/or

sas esseiss.nsssr

coordination with the FGSFWFC, as appropriate.)

in addition to the land clearing for the Eastern E^an.ion spray ^rriga^on

area, the St. Joseph Land and	the Eastern Expansion area

southern half of the proposed wildlife corrido	jurisdictional wetlands

leased to the city. This timbering i« to	/COE) and/or the FDER. As

designated by the U.S. Army Corps	be( united to the thinning of

specified by the FG4FWFC, timbering shth DroDOsed wildlife corridors, with
alternate rows of planted pines in the PrJP being moderately maintained

vegetation in exposed areas between re"""^di oontrol burns or perhaps mowing
in coordination with the FGSFWFC through periodic control ourna v v

to benefit Gopher Tortoise habitat (See Figure - )•

Habitat loss and disruption	but" w"^"ali'o 1
-------
The previously-mentioned wildlife corridors would help minimize the effects
of the habitat losses projected from converting the land of the Eastern Expansion
area to a sprayfield. The corridors are designed to maintain a portion of the
natural vegetation of upland and wetland habitats in the sprayfield expansion
area. The corridor areas would be contiguous to the spray irrigation areas
proposed for the Eastern Expansion area (Areas A-E; See Figure 4-2), which is
intended to allow undisturbed movement of wildlife around these irrigation areas.
The Eastern Expansion wildlife corridors are to include an isthmus area (maximum
of 300-500 feet wide) west of center pivot Area C to maintain corridor
interconnection for north-south wildlife movement. The wildlife corridors are
to essentially be continuous, although occasionally would be crossed by dirt,
gravel or paved access roads. I Note: If the configuration of the areas to be
irrigated are changed from those shown in Figure 4-2 by local decision-makers if
Alternative 1 is implemented, the USEPA recommends that an appropriate north-
south wildlife corridor should still be maintained.)

Protected federal and State-of-Florida faunal and floral species that range
in the preferred alternative area are the Eastern Indigo Snake, Florida Pine
snake, Gopher Tortoise, Gopher Frog, Panhandle Golden Aster, and Panhandle Meadow
Beauty. These species are classified as Florida-listed faunal species of special
concern (Eastern Indigo Snake, Florida Pine Snake, Gopher Tortoise, and Gopher
Frog); Florida-listed and federally-listed threatened faunal species (Eastern
Indigo snake); federal category 2 candidate faunal species for federal listing
as threatened or endangered (Florida Pine snake, Gopher Tortoise, and Gopher
Frog); federal Category 2 candidate floral species for federal listing as
threatened or endangered (Panhandle Meadow Beauty); and/or Florida-listed
endangered floral species and federal candidate floral species for federal
listing as threatened or endangered (Panhandle Golden Aster) (Also refer to Table
2-27).

The U.S. Fish and wildlife Service (USFWS) was contacted to fulfill the
interagency cooperation requirements of Section 7 of the Endangered Species Act
(Refer to Appendix F for record of contacts for federally-protected flora and
fauna in the project area: Mr. Dave Martin [USFWS; Jacksonville, FL] and Mr. Jay
Troxel [USFWS; Panama City, FL]). Section 7 requires federal agencies to ensure
that their proposed actions are not likely to jeopardize the continued existence
of endangered or threatened species or result in the destruction or adverse
modification of such species. In addition to the USFWS, the state of Florida,
notably the FG&FWFC, was also contacted. Cooperation included a field inspection
of the Eastern Expansion area on January 23, 1991, to review suitable, on-site
habitat for State-of-Florida-listed fauna ranging in the areas (Refer to Chapter
5 of this FEISS in the USEPA response section for the DEZSS Comment Letter #9
from the U.S. Department of the Interior for a copy of the FG&FWFC letter dated
February 6, 1991, regarding the field survey; also refer to Appendix F for a
record of contact for Florida-listed flora of the areai Mr. Dennis Hardin
[Florida Department of Agriculture; Tallahassee, FL]).

Based on coordination with the Florida state Historic Preservation officer
(SHPO), three (3) known listed archeological sites were determined to exist in
the preferred alternative project site and the existing SE Sprayfield. These
sites are: site 8LE1436 which is located within the proposed Eastern Expansion
of the existing SE Sprayfield; Site 8LE546 which is located within the TPS Plant
site, and Site 8LE548 which is located in the existing SE sprayfield. An
additional archeological site (Site 8LE1681) was determined to be located nearby
but outside the proposed Eastern Expansion of the SE sprayfield. The shpo has
indicated that sites 8LE546 and 8LE1436 should be relocated and evaluated, site
8LE548 should not be affected if project construction (drilling of a groundwater
monitoring well) avoids the site, and that Site 8LE1681 lies outside the proposed
Eastern Expansion area (See Figure 2-9). The City recently retained a
professional archeologist to conduct a cultural resource inventory and assessment
of the TPs Plant area and the Eastern Expansion area of the SE Sprayfield (See
Penton, 1991). The Phase I archeological study identified 26 newly recorded

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sites of which five (SKI, SF2, SF3, SF7, and SF9) have been determined to be
significant enough to warrant further consideration (See Figure 4-2). Additional
City coordination with the Florida SHPO should be provided, as appropriate.

In addition to the Eastern Expansion area, preferred Alternative 1 also
includes the Western Expansion area of the City's existing SE Sprayfield (1,280
total acres). As indicated previously, it is USEPA's understanding from the City
that the city has not acquired the land in this area and acquisition of and
construction at the Western Expansion area appears unlikely at this time.
Nevertheless, as a part of Alternative 1 and in the event of any potential future
land acquisition, wildlife corridors and a pivot irrigation area for the Western
Expansion area have been "suggested" and are depicted in Figure 4-3 along with
associated selected sensitive resource areas. No site-specific cultural resource
inventory was conducted for the western Expansion area.

4.6.2 Secondary Environmental impacts

The secondary environmental impacts of the preferred alternative which
generate the most concern are the impacts on public health and land-use changes.

Public health issues are primarily a concern to residents living adjacent
to or downgradient/downstream/downwind of the SE Sprayfield and the adjacent
proposed Eastern Expansion area as well as golf courses, should they be utilized
for spray irrigation. Residents living east (and north) of the proposed Eastern
Expansion area have voiced complaints during the public hearing held by Leon
county in Tallahassee on July 23, 1991, concerning aerosol spray drift, odor, and
decreased property values. Potential public health risks are related to aerosols
containing non-pathogenic bacteria and pathogens (e.g., pathogenic bacteria,
viruses, protozoans and other infectious microbes) traveling _away	the

sprayfield area and the potential groundwater contamination of the Floridan
Aquifer, a drinking water source. Groundwater concerns were voiced by the public
during the USEPA Public Hearing held in Tallahassee on August 9, 1990. Post-
irrigation use of the golf courses may also be of concern if effluent pathogens
are not completely disinfected.

It is generally documented (Crook, 1990; Asano et	"92) that

wastewater treatment methods can remove significant numbers of pathogens and

non-pathogenic bacteria typically associated with	lTT.ll'

not all may be killed by disinfection. In the case of pathogens such as viruses,

the surviving numbers could potentially be hazardous ....	However

perspective since even a small number of viruses can be	risk at anrav

several precautions can be taken to reduce the	on!£f£e

irrigation sites. These include effluent treatment, effluent monitoring, on site

containment of aerosols, and groundwater monitoring.

As indicated previously, the USEPA underatands from the City that City
effluent is disinfected in accordance with State of	. activated fiudae

requirements. The city's	^"^^^t^ight (sunlight) treatment in the

effluent for 40 parameters including 17 metals on a no:a ^ d d ' 0ijH8 /
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shift toward a more northerly direction near the end of the year. Other factors
which prolong pathogen viability and increase the distance of aerosol travel are
increased relative humidity, lower temperature, and darkness. Studies also
indicate that pathogens tend to survive longer in an aerosol than do the
traditional indicator organisms. The use of dense evergreen forested buffer
areas, which is proposed by the City along the external borders of the Eastern
Expansion area for Alternative 1, should greatly reduce the spread of aerosols
off site by acting as a barrier and by reducing wind velocities. Wildlife
corridors within site boundaries of the proposed Eastern Expansion area
consisting of natural vegetation, should further reduce the off-site migration
of spray effluent aerosols. However, in general, reasonable protection of
residents neighboring a sprayfield should be possible through the proper design
and implementation of appropriate effluent treatment methods, frequent effluent
monitoring of treated wastewater prior to irrigation, natural ultraviolet light
(sunlight) disinfection, prudent spraying operations, use of evergreen forested
buffer areas along external borders of sprayfields, use of forested corridors
within the general sprayfield area, and groundwater monitoring. Direct
application of effluent to forested areas, which is to be tried by the city as
a small demonstration project (forest irrigation) for the preferred Alternative
1, should further reduce the human health risk associated with aerosols, since
aerosols should be further contained on site (in the demonstration project area).

The USEPA understands from the city of Tallahassee that fecal coliform
levels are monitored by the city before effluent is spray irrigated on
sprayfields and after irrigation via groundwater monitoring. The usepa also
understands from the city that the water quality limits for fecal coliform levels
used by the City for effluent prior to sprayfield irrigation is the State of
Florida standards defining "secondary treatment" of wastewater, i.e., <200
organisms per 100 ml of effluent. Although there are no USEPA or federal
standards for fecal coliforms for spray irrigated effluent, this criterion is
consistent with USEPA guidance from the Requirements Memorandum #79-3 dated
November 15, 1978 of the former construction Grants Program (USEPA, 1978). The
concepts of this memorandum were incorporated in a USEPA Technology Transfer
manual entitled "Land Treatment of Municipal Wastewater" (USEPA No. 625-1-81-013)
(USEPA, 1981). The 200 counts/100 ml of effluent criterion is usEPA's fecal
coliform criterion for bathing (swimming) waters. It is presumed that water
considered safe enough for swimming (which could include incidental drinking)
would be adequate for irrigation of sprayfields, particularly with vegetated
buffers. In the absence of federal standards regarding acceptable remaining
levels of fecal coliforms in sprayed effluent, the USEPA recommends that the
state of Florida the use, at a minimum, the above federal guidance (USEPA, 1981)
to help protect public health and the environment during their permitting
decision for effluent sprayfields in addition to any appropriate State of Florida
regulations (Chapter 17-640 F.A.C.) for public access areas.

The spray application of wastewater to golf courses and other public access
areas, which would provide greater public exposure than agricultural or forest
sprayfields, requires additional treatment for suspended solids removal and high-
level disinfection under state of Florida regulations. Compliance with these
regulations should greatly reduce the health risks associated with aerosols at
golf courses, irrigation of golf courses using wastewater effluent is also not
em uncommon practice since 84 golf courses in Florida were being irrigated with
wastewater by 1991. In addition, golf course spray irrigation would require, per
FDER stipulation, that an alternate disposal method be made available as a back-
up. it is the USEPA's understanding from the City that such a contingency does
not presently exist.

Potential public health effects from animal vectors at spray irrigation
sites would be minimized through effluent disinfection. Such effects could be
further minimized through prudent spraying operations that allow acceptable
effluent soil infiltration rates that avoid ponding.

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Human health concerns also exist for potential groundwater contamination
of the Floridan Aquifer drinking water source. After application of the
wastewater effluent to land surfaces/ the wastewater infiltrates into the soil
and interacts physically and chemically to remove the potentially harmful
constituents not removed during effluent treatment. It is possible that some of
these constituents could move quickly through the soil (depending on soil
characteristics and depth) and into the groundwater used for as a public drinking
water source. As previously indicated, the City also monitors the groundwater
in compliance wells at the existing SE sprayfield.

The impact of land-use changes at the Eastern Expansion area is related to
the change of silvicultural operations to agricultural operations. The concern
ia not so much for aesthetics or restriction of future land use potential, but
rather for global climate change impacts. Deforestation reduces the capacity of
an area of the earth to absorb carbon dioxide from the atmosphere. Carbon
dioxide is the major contributor to the greenhouse effect. However, retaining
or creating vegetated areas in the sprayfield area is expected to help minimize
the impact of deforestation due to converting forested land to sprayfields (e.g.,
use of agricultural sprayfields (i.e., vegetation) to replace cleared forested
areas, implementation of the small forest irrigation demonstration_project which
would retain some existing forested area, retention of additional forested areas
within the project area as wildlife corridors, and use of ivergreen buffer strips
along external sprayfield borders which would retain or create forested areas).

4.6.3 Permitting Requirements

Pursuant to the existing NPDES permitting program (40 CFR Parts,122 «d 124)
and to the "NPDES Permit Application Regulations for{ftorm Wate:r Dii
FR m,0 dttjd Nove^r 19.0,

storm water discharges to waters of the unitea	domestic wastewater

treating domestic wastewater. This	t L0 mgd. The NPDES storm

treatment facilitiesithat.have designJJ°w»lgQ requira that point .ource storm

water regulations of No^riberl , d statea from all construction activities
water discharges to waters of the unitea	irrioation

(including the initial c/ie"i"r9' icliriust be permitted under the NPDES
disturbing a total of five	these discharges is 90 days prior

program. The permit application d«adliM r	tivitie8 needing NPDES permit

to commencement	recently issued by EPA/Region IV.

coverage can be made through a general permit

.. . . „ fnr tha nreferred Alternative 1, application
Relevant to NPDES permitting . made by the City for point source storm
for an NPDES permit would need to be mad *statea ftQm regulated treatment
water discharges to waters of	"n* ter under the above-noted criteria,

facilities actually treating domestic	-ennit would also be needed by the

Application by the City for a separate NPDES	d™ucharges to water8 the

above-noted deadline for point	associated with and actually involving

United states for all construction sites. luding the initial clearing, until
the effluent land application	' sion area of the SE Sprayfield and the

revegetated, of the proposed Eastern	ted) of the preferred Alternative 1)

proposed Western Expansion area (ii	. These permit requirements

disturbing a total of five or	ernative l as well as any existing

would be relevant for the preferred A1

unpermitted city sites.

. • Umv.„ae to waters of the United states from the
Storm water point source discharges	. lturai/non-silvicultural land

operation (spray irrigation) ofn rights-of-way, and landscape areas)
application sites (such as golf	'he Quality required by Chapter 17-610

receiving domestic wastewater treated	,tar are not required to be covered

F.a.c. fir the land application of reclamed water	f£uity tQ aubmlt an

by npdes permits, unless the US®PA.sp iu«refore no NPDES permit is needed for
application on a case-by-case basis. Tn	City's proposed project (if

the operation of such land application sites ror »

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storm water point source discharges exist to waters of the United States for such
sites) unless specifically requested by the USEPA. However, dedicated discharges
of reclaimed water, without land application, are required to be covered by NPDES
permits. it may also be noted that storm water discharges from the land
application of wastewater effluent on agricultural and silvicultural sites are
exempt from the NPDES permitting program if the sites are consistent with 40 CFR
Part 122.3(e), so that the operation of such sites for the City's proposed
project would not require an NPDES permit if consistent with 40 CFR 122.3(e).
Therefore, no npdes permit would be needed by the city for the operation of the
four golf courses (if implemented) proposed in the preferred Alternative 1, as
well as any similar existing city application sites (if such storm water point
source discharges to waters of the United states exist at these sites).
Additionally, since the land application of wastewater effluent on agricultural
sites is exempt from the NPDES permitting program, the operation of the Eastern
Expansion of the SE spray fie Id and the western Expansion thereof (if implemented)
proposed in the preferred Alternative 1, as well as any existing City application
sites such as the SE Sprayfield (if such storm water point source discharges to
waters of the United States exist at these sites), would not require an NPDES
permit if these sites are consistent with 40 CFR 122.3(e).

Included in the proposed spray irrigation of wastewater effluent in the
preferred Alternative 1 is the generation of and land application of wastewater
sludge. Section 405(d) of the Clean Water Act requires that the disposal or
reuse of sewage sludge be regulated. This regulatory activity is to be
accomplished through the utilization of permits based upon technical federal
regulatory standards. The USEPA established federal sludge disposal'/reuse
standards which were promulgated in the Federal Register at 40 CFR 503 on
February 19, 1993. In general, these standards must be complied with by all
treatment works treating domestic sewage by February 19, 1994. violation of
these standards would be a violation of the Clean Water Act. It is anticipated
that current and proposed sludge disposal/reuse activities would be regulated
through an NPDES permit, where applicable, or through issuance of a "Sludge-Only"
permit. This federal permitting activity would be issued by the USEPA/Region IV
until program authorization is given to the state of Florida. Therefore, the
newly promulgated federal regulations are in addition to the State of Florida
sludge disposal/reuse regulations. Relative to the preferred Alternative 1, the
City must also make application for a Sludge Only permit for the current and
proposed sludge disposal/reuse activity associated with the SE Sprayfield and the
Alternative 1 proposal, as well as any other City sludge disposal/reuse practice.
These federal regulations are in addition to the State of Florida sludge
disposal/reuse regulations.

Specific to the City of Tallahassee, the USEPA last issued an NPDES permit
for land application to the City of Tallahassee for the City's Thomas P. smith
wastewater Treatment Plant in 1980. This federal permit was to expire in 1983
but was inactivated by the USEPA on April 6, 1981.

Failure to obtain prior authorization for discharges under the NPDES program
may result in the USEPA assessment of administrative, civil, and/or criminal
penalties under Section 309 of the Clean Water Act.

In addition to the NPDES permitting, the preferred alternative would also be
subject to the requirements of a Section 404 (Clean water Act) permit, which
would include any unavoidable direct losses of wetlands through dredge-and-fill
activities such as land clearing and construction activities. However, proposed
spray irrigation areas within the proposed Eastern Expansion Area of Alternative
1 were selected to avoid wetland areas since hydric (wetland) soils would not be
suitable/desirable for effluent disposal. Nevertheless, any project wetland
losses would be subject to 404 permit determinations by the Jacksonville District
COE, as well as wetland determinations by the state of Florida and Leon County,
as appropriate. Conveyance pipeline crossings of wetlands would likewise also
be subject to Section 404 permitting. Also, the USEPA reviews 404 permit

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applications for the COE. Secondary impacts to wetlands and surface waterbodies
could also occur. Periodic water quality monitoring of surface waters and
selective application measures would help minimize such secondary impacts,
surface waters should not be allowed to become eutrophic due to spray irrigation
of wastewater nutrients.

The permitting guidance outlined in this document is very general and is
not intended to be used to make final decisions on the applicability of the NPDES
or sludge regulations, or section 404 of the Clean Water Act. Site-specific
conditions are always important factors in making these determinations.

4.7 ENVIRONMENTAL PROTECTION MEASURES

in addition to the environmental protection measures described in section
4.6, the following measures are intended to lessen the potentially detrimental
impacts of the preferred alternative. These measures are recommended by the
USEPA for implementation by the City of Tallahassee if the preferred alternative
is pursued for implementation by the City. They are categorized as to the
likelihood of implementation:

Measures that will be implemented -

•	Comply with the existing National Pollutant Discharge Elimination System
(NPOES) permitting program (40 CFR Parts 122 and 124) and the "NPDES Permit
Application Regulations for Storm Water Discharges" (55 FR 47990 dated
November 16, 1990), which require an NPDES permit for:

*	Point source storm water discharges to waters of the United states from
regulated domestic wastewater treatment facilities actually treating

domestic wastewater that have design flows of a* 1*"t

*	Point source storm water discharges to waters of the United states from
all construction activities associated with the ®pray irrigation project
(including initial clearing of the application site until
disturbing a total of five or more acres of land — application by 90 days
prior to commencement of construction.

Pursuant to section 405(d) of the Clean water Act, the City must also make
application for a Sludgi only permit for the current and proposed sewage

sludge disposal/reuse activity associated *i.th th« P"po"gQP"2!®^SS
well as anv other City sludge disposal/reuse practice. Also, standards

promulgated It to CFR^03 (February 19

with by all treatment works treating domestic sewagia by February 19^ 1994.
Permit application should therefore also be made by the city with the

USEPA/Region IV for:

. *11 current .nd propo.ed .ctiviti.. involving the land application of
sludge.

.uv	rmalitv of the effluent leaving the

•	Conduct monitoring of the water qu y e££luent gpray irrigation) for

wastewater treatment plants	P"	beinq conducted (40 parameters

the parameters and at the	such as biochemical

including 17 metals on a	d ao{id8 (TSS), total nitrogen, chlorine

oxygen demand (BOD), total 9U®P®"fand other parameters on a twice a
residual, chlorides, pH, fecal coliforms, ana^ner^p ^	baflig)< Jf

week basis; and the six (6) __it iimitations, correct problems in the
pollutant concentrations exceed permit limitationsy
treatment operations and/or design as soon as possible.

•	Conduct monitoring of.the wate^,^a\itsyp°ay9irrig^tion site8 tor hth«°i»ixh*6)
mile of the PreJef"dmffrequency currently being conducted (nitrite
parameters and at the quarterly frequ y	nitrogen, chlorides, and
and nitrate as nitrogen, nitrites, totai

4-17

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dissolved organic carbon (DOC), as well as any other water quality
parameters specified by the State of Florida in order to detect any
exceedances of relevant water quality standards. If monitoring data exhibit
concentrations exceeding State of Florida water quality standards for
groundwater and/or permit limitations, correct problems with irrigation
operation and/or design as soon as possible.

Conduct frequent monitoring of the water quality of surface waters. Surface
waterbodies, for example, should not be allowed to become eutrophic.

Retain wildlife corridors within the Eastern Expansion area proposed by the
city for near-future construction (and in the Western Expansion area if ever
developed). wildlife corridors should maintain a portion of the natural
vegetation of the on-site upland and wetland habitats. Corridors are
intended to provide habitat areas contiguous to spray irrigation areas to
allow undisturbed movement of wildlife around these irrigation areas,
including Gopher Frog reproductive migrations. The Eastern Expansion Area
wildlife corridors should include an isthmus area (a minimum of 300-500 feet
wide) west of center pivot Area c to maintain corridor interconnection for
north-south wildlife movement. The wildlife corridors should essentially be
continuous, although occasionally would be crossed by dirt, gravel or paved
access roads. Proposed logging activities within portions of the corridors
should be minimized and selective. (Note: If the configuration of the areas
to be irrigated (Areas A-E) in the Eastern Expansion Area are altered by
local decision-makers from those shown in Figure 4-2, the USEPA recommends
that an appropriate north-south wildlife corridor still be maintained.
Likewise, if the proposed spray irrigation acreage (909 acres) of these
areas jure changed, the USEPA recommends that adequate on-site sandy areas
still be maintained for the Gopher Tortoise. Additional coordination with
the FG4FWFC is recommended, as appropriate.)

Retain/create a buffer zone around the field areas that is a minimum of 400
feet in width along Tram Road and 100 feet along the other sprayfield
external boundaries to minimize perturbations attributable to the sprayfield
expansion area, particularly aerosol spray drift. The buffer zone should
act as a year-round, vegetative screen and as such must be a dense evergreen
forested area. The use of evergreen buffer areas, in combination with the
above-described forested wildlife corridor areas, should greatly reduce the
spread of aerosols off site by acting as barriers and by reducing wind
velocities. The southern boundary already has a densely-forested buffer as
a result of an existing gas pipeline right of way. The southern buffer
width would be at least 400 feet. Buffer strips should also be retained
around on-site waterbodies and along streams for field runoff filtration.

Protect and preserve archaeological sites located in buffer areas and
designated wildlife corridors. For the examined Eastern Expansion, these
include Sites SFl, SF4, SF9, SF19, SF21, SF22, SF23, and SF26. Of
particular concern is Site SF9 (Eagle Lake site). The primary protection
zone for this site should be a 1400-foot diameter circle, the center of
which is to be coordinated with and established by the Florida SHPO.

utilize all agricultural crops raised via spray irrigation (e.g., corn, soy
beans, canola, and rye/rye grass) at the proposed sprayfield expansion
site(s) and existing sprayfields only for animal feed and/or for processed
food for humans (e.g., canola oil; soy bean oil), i.e., not for direct human
consumption, to the extent consistent with the state of Florida (Chapter 17-
610 F.A.C.). Grazing of cattle on proposed or existing irrigated
sprayfields only to the extent consistent with Chapter 17-610 F.A.C., and
utilization of crops grown for consumption (e.g., bermuda hay for livestock
feed) on existing sludge fields (Class B or equivilent) only to the extent
consistent with chapter 17-640 F.A.C.

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•	Comply with sound agricultural practices such as field terracing and row
crop contouring.

•	comply with all federal, State of Florida, Leon County and City of
Tallahassee standards, permits and/or ordinances relevant to the proposed
sprayfield expansion.

Measures that are planned for implementation -

•	Consider any reasonable public complaints made before or during operation of
the proposed sprayfield expansion regarding effluent aerosol dispersion or
other operational impacts.

•	Conduct agricultural operations with the primary goal being the proper
disposal of effluent.

•	Conduct frequent monitoring of the water table level at the spray irrigation
areas and adiust the effluent application rates accordingly. Application
rates are not to exceed State of Florida permit conditions. The City's
existing SE sprayfield is currently permitted by the state of Florida to
spray irrigate at a rate of 3.16 inches per week.

•	Monitor weather conditions to avoid spraying effluent during cf0P harvesting
and during inclement weather conditions (e.g., rainy' £et, windy, freezing
conditions) if spraying during those conditions would be expected to cause
detrimental environmental or human health effee s,

ineffective from an effluent disposal perspective. Swilar

operations should also be undertaken to the «*tent. feasible «^-^g Pe*iods

of increased relative humidity, lower temper	viahilitv and

studies have shown that these conditions prolong pathogen viability and
increase th^distance of aerosol travel. Spraying should also not result in

effluent pondin, i.. order to	lTa",	Ibe^'di^

£rH«; <$&„Tha. ££ntT occurred' i„ the sc corner of the exi.tin,
SE sprayfield).

•	create 6- to 8-inch vegetated (herbaceou.	"""> "fof"	S

the eprayfield	such bene would help contain eurfaoe

farmer's agricultural practices. muc	filtration of the applied

water runoff and a.11.owa P®"?^iqation areas. This would help reduce the
effluent in designated »P«y ir g f waterbodies within the sprayfield

probability of wetland and other surfa	System) from

expansion area (as well as the adjacent
becoming eutrophic.

•	create 10- to 12-inch vegetated

"r^ce ¦££ /ro£h£°^"ow" fro„ Srec? aLese to groundwater and thereby
help protect groundwater quality.

•	During the design and proposed cons truetion^phas e a^	al	avoided
(other than the discussed Stiv. soils could be
If avoidance is infeasible, f * wetlands. The fill soils should
tried unless these depressional a"®8 drainage into the Karstic areas
only be moderately well-drained, so t preferably be mixed with
would not be encouraged. Native soils ."^u^tiao1n8Oa^iuent filtration and
organic material to enhance .spray g subsequently subside, slight

pollutant removal. Since/U5h,5,Additional filling using the same soil
initial mounding may be advisable	the depreBgional area collapse and

mix may subsequently be needed. Shioul	area should be stopped and

become a -live" sinkhole, spray irrigationinthe areaano	^ve>

vegetated earthen berms created around the sinkhole

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•	Preserve as many trees at the site as possible. Tree clearing should be
limited to the sprayfield areas and designated farm operation areas. This
would minimize habitat losses, habitat disruption, and global climate change
(greenhouse effect) impacts. Additional proposed silvicultural timbering by
the St. Joseph Land and Development company on land in the Eastern Expansion
area leased to the City should be minimized, selective, and exclude
jurisdictional wetlands designated by the coe and/or the FDEP due to
reproductive migrations of the protected Gopher Frog. Also, as specified by
the Florida Game and Fresh Water Fish Commission (FG&FWFC), timbering should
be limited to the thinning of alternate rows of planted pines in the
proposed wildlife corridors, with vegetation in exposed areas between
remaining trees being moderately maintained in coordination with the FGAFWFC
through periodic control burns or perhaps mowing to benefit the habitat of
the protected Gopher Tortoise, should land access to the Western Expansion
area be obtained by the city and the site developed, timbering should be
similarly limited there.

Measures that could be implemented -

•	Protect cultural resources on the edge of irrigation fields by incorporating
them into "protection areas" (wildlife corridors and buffer zones) as
determined by the Florida SHPO. These include sites SF2, SF7, and SF18.
Additional City coordination with the Florida SHPO should be provided, as
appropriate.

•	Protect cultural resources located in irrigation fields as determined by the
Florida SHPO. These include sites SF3, SF5, SF6, SF8, SF10, SFll, SF12,
SF13, SF14, SF15, SF16, SF17, SF20, SF24 and SF25. Of these sites only one,
SF3, which is located in the fixed sprinkler irrigation area, appears to
warrant additional systematic archeological examination. Additional City
coordination with the Florida shpo should be provided, as appropriate.

•	Protect any listed or uncovered cultural resources located along pipeline
corridors to the satisfaction of the Florida SHPO.

The preferred option for protection of cultural resources inside the
irrigation areas is to limit construction activities on the sites to the
placement of fill only (in non-wetland areas). This would provide additional
protection without precluding their use as part of the sprayfield. This option
also prohibits grading, ditching and other excavation at the sites, it appears
that clearing and grubbing to a depth of 12 inches would be acceptable but is
subject to review by the Florida SHPO.

It should be noted that the construction of groundwater monitoring wells is
not expected to produce significant negative short- or long-term environmental
impacts. Minor earth disturbance would be expected to occur due to operation of
a drill rig. The overall effect would be environmentally beneficial because the
wells would allow for monitoring of the groundwater resource.

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CHAPTER 5

EIS COORDINATION

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CHAPTER 5 EIS COORDINATION

5.1	INTRODUCTION

Public participation programs are mandated by federal regulations governing
the preparation of Environmental impact statements. Public participation is an
important and valuable part of the EIS process in that it provides for active
public (includes interested groups, individuals, and private and governmental
agencies) involvement in developing and evaluating wastewater management
alternatives and in selecting a preferred alternative. Public participation was
an integral part of the preparation of the 1983 USEPA EIS. A public
participation program was also developed for the preparation of the EIS
Supplement. Section 5.3 describes the public participation programs of the 1983
EIS and the EIS supplement.

5.2	COORDINATION WITH LOCAL, REGIONAL, STATE AND FEDERAL AGENCIES

i -i	-f.fo and federal agencies were contacted for

inforaation during t"h. pr-P-ti-' o'

supplied information necessary to tne aecisxuu » „	studies

agencies that were contacted during one or both of the EIS studies.

5.3	PUBLIC PARTICIPATION PROGRAM
5.3.1 1983 EIS Public p-fHwlpation

The public participation	"flraed t^^erve" in°M

to*USEPA "and th.it	^"d °f 25

representing 10 public agencies and 13 p

. , Ka.ri.na (scoping meeting) was held in the city
on November 29, 1978, a Public h egg tha USEPA WOuld use in preparing the
of Tallahassee to describe the proc	^ purpose and background of

1983 EIS. The meeting included	J ia.ue.P to be addressed; the EIS

the EIS, the 201 Study, the 8C°P*.° _ublic participation program. Afterwards,

schedule, and a description of tne Pu 	 *

several citizens and officials made coram

»>¦ held on May 16, 1979 in the City to
The first Review Committee me®V ?h a*igtinq data base for terrestrial and
review the EIS Plan of Study. G*p	tha design of a sampling program was

aquatic systems were discussed, *	f:_, an major issues of the EIS had

P?...nt.d, Th. committ.. v..	" th. «rk

b«.n id.ntifl.fl and incorporate into th. worK «"

meeting and all subsequent ones
The format of the first Review ccnmr	followed by the Committee

consisted of a presentation by the e±s>	At the end of the evening, a

dividing into two round table dl8CU"/-°^ \he discussion for the benefit of the
representative from each table summarized the disc

other table and observers.

id January 9, 1980, in the city to
The second Review committee was j?0* t and the Alternatives Development
review the Environmental inventory	uo sessions, Review committee concerns

task report. During the discussion? P astewater flow projections, the
centered on spray irrigation ^P^fij-tions of the Tallahassee urban area,
development potential of the north*"* **treatment plant, impacts to vegetation
the desirability of a Northeast wastewater trea	* # uae o£ on-lot disposal

and wildlife, and the implementability or wi
¦yatems or small community systems.

Id on January 15, 1981, in the City
The third Review Committee ®®?^n5aa"report. Each of the four alternatives
to review the Alternative Evaluation	^iniy on Alternative 1 (T.P. Sau-th/

"as discussed in turn, concern f alternative 4 (No-Federal-Action). Th
Southwest and Northeast Plants) an . maintenance continued to be a matter
Widespread use of on-lot systems and their m on_lot systems were perceived
concern. Institutional management aspects o

5-1

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TABLE 5-1
AGENCY CONTACTS
Local and Regional Agencies and Organizations

city of Tallahassee, Hater and Sewer Department and sewer Division

Environmental Science Engineering, inc.

Leon county Environmental services

Leon County Public Health Unit

Leon County Public Works Division

Munson Area Preservation, Inc.

Post, Buckley, Schuh & Jernigan, inc.

Springhill Road Concerned Citizen

Tallahassee Historic Preservation Board

Tallahassee Leon County Planning Department

Tallahassee office of Management and Budget

Tallahassee Water Quality Laboratory

Tall Timbers Research Station

Talquin Electric Cooperative, inc.

wm. M. Bishop Engineers, Inc.

w.v. McConnell, Land Management Planner/Forestor
State Government Agencies

Florida Department of Environmental Regulation, Bureau of Wastewater

Management and Grants
Florida Department of state, Division of Archives, History, and Record
Management

Florida Game & Fresh Water Fish Commission, Office of Environmental services
Federal Government Agencies

U.S. Department of Agriculture, Soil Conservation Service
U.S. Department of Commerce, Census Bureau
U.S. Department of Defense, Army Corps of Engineers
U.S. Department of Interior, Fish and wildlife Service
U.S. Department of Interior, Forest Service
U.S. Department of Interior, Geological survey

U.S. Department of Transportation, Federal Aviation Administration
Federal Emergency Management Agency

5-2

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to be a serious problem, other questions addressed cost analyses and wastewater
flow projections.

The fourth Review committee meeting was held on July 9, 1981 in the City to
present a briefing paper describing the No-Federal-Action Alternative that was
selected by the USEPA Region IV Regional Administrator. Discussion focused on
the need for and responsibilities of a management agency for on-lot and small
community systems. In addition, committee members requested an expanded
discussion in the Eis of causes of system failure, corrective actions, and
mitigative measures.

5.3.2 EIS supplement Scoping Meetings and Public Hearings

The public scoping meeting for the EIS Supplement was held in the City on
April 19, 1988. Section 1.2.1 of this document presents the list of concerns
that was developed from discussions made during the meeting and from written
comments received by the USEPA. Section 1.2.2 presents the EIS Supplement's
issues that evolved from the concerns and from the 1983 EIS issues.

It was decided at the public scoping meeting that no Review Committee would
be formed for the project. The public meetings would be held by the USEPA and
would serve as the sole forum for advising the USEPA and their consultants of the
needs and preferences of the concerned public. Other meetings between the USEPA,
their consultants, and interested parties were held throughout the course of the
study as needed. These meetings were primarily for exchange of information and
for providing updates of the project's status.

The second public meeting was held November 15, 1988 in the City. The
purpose of this meeting was to present the preliminary wastewater management
alternatives developed by the USEPA and their contractors. This included an
effluent disposal alternative utilizing a land exchange option with the U.S.
Forest service (USDA FS). These alternatives were discussed and additional
alternatives were identified. These included golf course irrigation disposal,
artificial wetlands disposal, conservation and effluent reduction, and higher
treatment levels prior to disposal.

Two new and independent issues were raised at the second public meeting. The
first was the use of public (USDA FS) land for effluent disposal by spray
irrigation. Central to this issue was the USEPA's and the USDA FS's
responsibility to assure all human and other environmental impacts are fully
considered during the EIS process. The second issue concerned the evaluation of
alternative wastewater management systems. The additional alternatives
identified at this meeting were to be included in the on-going development of
alternative systems and environmental impact assessment for the EIS Supplement.

The third public meeting was held on August 15, 1989 in the City. The
purpose of this meeting was to present the results of the wastewater management
alternative evaluation process. As a result of this meeting, the use of USDA
FS's lands, both south of the TPS Plant and west of the Municipal Airport, were
dropped from further consideration as alternative spray irrigation sites.

The USEPA released the Draft EIS Supplement (DEISS) to the public on June 29,
1990. A copy of the DEISS and/or a DEISS Public Notice was provided to numerous
federal, state and local agencies and interested groups and individuals.
Approximately 120 DEIsss and numerous public notices were mailed. The Notice of
Availability (NOA) for the DEISS (EIS No. 900217) was noticed in the Federal
Register (55 FR 28751 [June 29, 1990]). Written comments on the DEISS were
received by the USEPA until the end of the NEPA-mandated 45-day comment period
on August 24, 1990. Twelve (12) comment letters were received during this
comment period, including a post card from the State of Florida Clearinghouse
acknowledging receipt of copies of the DEISS for circulation within the State
government (Table 5-2). A copy of the DEISS Public Notice and the set of 12
comment letters are provided at the end of this Chapter 5. Individual USEPA
responses follow each comment letter in the set of letters. Comment letters and
corresponding responses cure ordered by number (1-12).

5-3

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1

2

3

4

*5

6

7

8

9

10

11

12

TABLE 5-2

COMMENT LETTERS RECEIVED BY USEPA FOR TALLAHASSEE-LEON
COUNTY WASTEWATER MANAGEMENT DEISS DURING THE 45-DAY

COMMENT PERIOD

DATE	SOURCE	AUTHOR

7/03/9 0 U.S. Department of Housing and Ivar O. Iverson
Urban Development; Atlanta, GA

7/10/90 Florida Department of Natural Grant Gelhardt
Resources; Office of
Environmental Services;

Tallahassee, FL

7/12/90 Florida Department of State;	George W. Percy

Division of Historical
Resources; Tallahassee, FL

7/12/90 U.S. Department of Agriculture; T. Niles Glasgow
Soil Conservation Service;

Gainesville, FL

7/12/90 Florida Game & Fresh Water Fish Bradley J. Hartman
Commission; Tallahassee, FL

7/13/90 Florida State Clearinghouse;	state of Florida

(recvd) Office of the Governor;

Tallahassee, FL

7/17/90 w.V. McConnell, Land Management w.V. McConnell
Planner/Forester;

Tallahassee, FL

8/10/90 Department of Health and Human Kenneth w. Holt
Services; Centers For Disease
Control; Atlanta, GA

8/14/90 U.S. Department of the	James H. Lee

Interior; office of
Environmental Affairs;

Atlanta, GA

8/22/90 Florida Department of	van R. Hoofnagle

Environmental Regulation;

Facilities planning section;

Tallahassee, FL

8/24/90 Florida Forestry Association; William Carol Lamb
Tallahassee, FL

8/24/90 w.V. McConnell, Land Management W.V. McConnell
Planner/Forester;

Tallahassee, FL

5-4

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During the DEISS comment period, a USEPA Public Hearing was held in
Tallahassee, Florida. This Hearing occurred at 7:00 PH on August 9, 1990 at the
City Commission Chambers, second floor, City Hall, 300 South Adam Street. The
USEPA announced the Hearing via the above Public Notice in the "Legal Notices"
of the Tallahassee Democrat on July 9, 1990. The USEPA also prepared a press
release to announce the Hearing and provide it to the Florida media served by "PR
Newswire" and also directly to the Tallahassee Democrat to use at their
discretion.

Twenty-four (24) people attended the Public Hearing, including one who
stayed only briefly and did not register (Table 5-3). Eight (8) people provided
verbal comments, with one person (Elmer Leek) speaking twice (Speaker #4 and #9).
The nine (9) speakers are presented in Table 5-4. Two (2) speakers (Speaker #3:
Jessie Brown and speaker #4 and #9: Elmer Leek) also provided associated written
comments with their speeches. A copy of the Public Hearing Press Release and the
Public Hearing Transcript with associated speaker written comments are included
at the end of this Chapter 5, following the DEISS Public Notice and the 12 DEISS
comment letters with USEPA responses. The set of individual USEPA responses to
the nine speaker comments then follow the Transcript and associated speaker
written comments and are ordered by number (1-9). USEPA transcript responses
apply to both verbal and written Public Hearing speaker comments.

Copies of this FEISS document and/or notices of its availability are being
circulated to numerous federal, state and local agencies as well as interested
groups and individuals. All agencies and individuals that provided written
comments on the DEISS and/or provided verbal comments at the USEPA Public Hearing
held in Tallahassee on August 9, 1990, and/or were registered attendees of the
Public Hearing and requested a copy of the FEISS, are being provided a copy of
this FEISS and/or a notice of its availability.

The following is a partial list of the federal agencies that are being
mailed one or more copies of this FEISS and/or a notice of its availability:

•	U.S. Environmental Protection Agency - Washington, D.c.

•	U.S. Department of Agriculture, Forest Service - Washington, D.c.

t U.S. Department of Agriculture, Forest service - Atlanta, GA

•	U.S. Department of Agriculture, Forest Service - Tallahassee, fl

•	U.S. Department of Agriculture, Soil Conservation Service - Washington, D.C.

•	U.S. Department of Agriculture, Soil Conservation service - Gainesville, FL

•	U.S. Department of Health and Human services - Washington, D.c.

•	U.S. Department of Health and Human services, Centers for Disease Control -

Atlanta, GA

•	U.S. Army Corps of Engineers - Jacksonville, FL

•	U.S. Food and Drug Administration - Washington, D.C.

•	U.S. Department of Housing and Urban Development - Atlanta, GA

•	U.S. Geological Survey - Reston, VA

•	U.S. Department of the Interior - Washington, D.C.

•	U.S. Fish and Wildlife Service - Atlanta, GA

•	U.S. Fish and wildlife service - Jacksonville, FL

•	council of Environmental Quality - Washington, DC

•	Advisory council on Historic Preservation - Washington, D.c.

•	Federal Highway Administration - Washington, D.C.

•	Economic Development Administration - Atlanta, GA

•	National Science Foundation - Washington, D.C.

Copies of this FEISS and/or notices of its availability are also being
circulated to the state of Florida, primarily through the Florida state
Clearinghouse which sends copies to divisions of the State deemed appropriate.
However, to ensure that those State agencies that provided comment letters on the
DEISS would also receive a copy of this FEISS and/or notice of its availability,
the following State agencies in addition to the state Clearinghouse are being
mailed a copy of this FEISS and/or notice of its availability (Note: FDER and
FDNR replaced by FDEP for this circulation):

5-5

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1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

TABLE 5-3

ATTENDEES AT THE USEPA PUBLIC HEARING; CITY HALL;
CITY COMMISSION CHAMBERS; TALLAHASSEE, FLORIDA;
AUGUST 9, 1990

Name
Jessie Brown
Dexter Cherry
John Dean
c. Florko
Margaret L. Fogg
Guest of M.L. Fogg
Flo P. Gray
John Gray
Sharon Gray
Carolyn E. Grimes
Robert Grimes
Mildred R. Hall
Judy Hancock
Dan Hendrickson

Van Hoofnagle

Elmer Leek
Maxine Leek
Carla M. Perry

Jim Peters
Barbara Rambo
John P. Strickland
Richard Taylor
Keith Turner
Unident. Attendee

Representing
Munson Area Preservation, Inc.

Lake Munson Preservation
City of Tallahassee

Florida Department of Natural Resources

Lake Munson Preservation

Lake Munson Preservation or Self

Self (wife of John Gray)

Springhill Neighbors

Lake Munson Area Preservation

Munsoh Preservation Commission

Munson Preservation commission

Self (South end of Tallahassee)

Florida chapter of Sierra Club

Springhill Road Association & Big Bend
Group Sierra Club

Florida Department of Environmental
Regulation

Self

Self

Florida Department of Environmental
Regulation

City of Tallahassee

self

City of Tallahassee
Self

City of Tallahassee
(only stayed briefly)

Heinz J. Mueller
Cory w. Berish, Ph.D.
Christian M. Hoberg

USEPA Hearing officer
usepa DEISS Proj. Monitor
USEPA FEISS Proj. Monitor

5-6

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TABLE 5-4

PUBLIC HEARING SPEAKER COMMENTS PROVIDED AT THE USEPA

PUBLIC HEARING; TALLAHASSEE-LEON COUNTY WASTEWATER
MANAGEMENT DEISS; CITY HALL; CITY COMMISSION CHAMBERS;
TALLAHASSEE, FLORIDA; AUGUST 9, 1990

Number	Speaker	Representing

1	Margaret L. Fogg	Lake Munson Preservation

2	John Gray	Springhill Neighbors

3	Jessie Brown	Munson Area Preservation, Inc.

4	Elmer Leek	Self

5	Barbara Rambo	Self

6	Judy Hancock	Florida Chapter of sierra club

7	Dan Hendrickson	Springhill Road Association & Big Bend

Group Sierra Club

8	Mildred R. Hall	Self

9	Elmer Leek	self

5-7

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•	Florida state Clearinghouse, office of the Governor - Tallahassee, FL

•	Florida Department of Environmental Protection, Facilities Planning

Section - Tallahassee, FL

•	Florida Department of Environmental Protection, office of Environmental

services - Tallahassee, FL

•	Florida Game and Fresh Water Fish commission - Tallahassee, FL

•	Florida Department of State, Division of Historical Resources -

Tallahassee, FL

FEISS and/or notice of availability circulation to local entities is also
being provided. The following is a partial list of regional/local/city agencies
and private groups that are being mailed a copy of this FEISS and/or a notice of

its	availability:

•	City of Tallahassee, Sewer Division - Tallahassee, FL

•	Leon County Board of County Commissioners - Tallahassee, FL

•	Leon County Public Health Unit - Tallahassee, FL

•	Talquin Electric Cooperative, Inc. - Quincy, FL
$	Leon County Public Works - Tallahassee, FL

•	Florida Wildlife Federation - Tallahassee, FL

•	Apalache Audubon society - Tallahassee, FL

•	Tallahassee-Leon County Planning Commission - Tallahassee, FL

•	sierra Club - Tallahassee, FL

•	Florida Federal Women's club - Tallahassee, FL

•	Isaak Walton League of America - Palmetto, FL

•	League of Women Voters - St. Petersburg, FL

•	Florida Lung Association - Tallahassee, FL

•	Florida Conservation Association - Tampa, FL

•	Florida Forestry Association - Tallahassee, FL

•	Mana-Sota 68 - Palmetto, FL

•	Leon County Public Library - Tallahassee, FL

•	Coleman Memorial Library, Florida A & M Univ. - Tallahassee, FL

•	Robert Manning strozier Library, Florida state Univ. - Tallahassee, FL

In addition, the following U.S. and State of Florida congressmen and local
government officials representing the Tallahassee-Leon County area are being
provided a copy of this FEXSS and/or a notice of its availability:

•	Honorable Bob Graham (U.S. Senate)

•	Honorable Connie Mack (U.S. Senate)

•	Honorable Pete Peterson (U.S. House of Representatives)

•	Honorable Pat Thomas (Florida senate)

•	Honorable Charles D. Williams (Florida Senate)

•	Honorable Hurley W. Rudd (Florida House of Representatives)

•	Honorable Alfred Lawson, Jr. (Florida House of Representatives)

•	Honorable Robert D. Trammell (Florida House of Representatives)

•	Honorable Allen F. Boyd, Jr. (Florida House of Representatives)

•	Honorable Dorothy Inman-Crews (Mayor of Tallahassee)

In addition to the above addressees, numerous individuals are also being
provided a copy of this FEISS and/or a notice of its availability. These
include, but are not limited to, the speakers (See Table 5-4) and other
registered attendees of the USEPA Public Hearing (See Table 5-3) and individuals
who provided written comments on the DEISS (W.V. Mcconnell, planner/Forester).

The USEPA understands from the city of Tallahassee that Leon County held a
public hearing in Tallahassee on July 23, 1991. The county apparently held the
hearing in response to citizen concerns for existing residents east (and north)
of the Eastern Expansion area of Alternative 1, which the city proposes for near-
future construction. The usepa understands from the city that citizen concerns
regarding aerosol spray drift, odor, and decreased property value were voiced by
some 20 speakers in the public hearing.

5-8

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PUBLIC NOTICE

U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV, 345 COURTLAND STREET, NE
ATLANTA, GEORGIA 30365

Availability of the Draft Environmental Impact Statement
Supplement (OEISS) entitled "Tallahassee-Leon County, Wastewater
Management, Tallahassee, Leon County, Florida" is being noticed
in the Federal Register by the United States Environmental
Protection Agency (EPA). The DEISS concludes that the preferred
alternative is a centralized approach. Wastewater will be
conveyed to the south to be treated at the improved Lake
Bradford Road Plant and the improved and expanded T.p. Smith
Facility. Effluent disposal will be handled by spray irrigation
at the.expanded Southeast Agricultural Sprayfield and local golf
courses. The preferred alternative is cost effective, readily
implement able and has few environmental impacts.

In order to solicit further public participation on the proposed
project, a Public Hearing is scheduled for August 9, 1990, and
will begin at 7t00 p.m. at the City Commission Chambers,
Tallahassee, Florida. Both oral and written comments will be
accepted, and a transcript of the proceedings will be made. For
accuracy of thf record, written comments are encouraged. The
Hearing Chairman reserves the right to fix reasonable limits on
the time allowed for oral statements.

Persons who do not provide c©amenta at the public hearing may
respond in writing before the close of the public comment period
on August 24, 1990 to Heins J. Kueller, Chief, Environmental
Policy Section, Federal Activities Branch, U.S. Environmental
Protection Agency, Region IV, 345 Courtland Street, NE, Atlanta,
Georgia 30365. Facsimile transmittals may be sent to SPA at
(404) 347-5056.

A Final IXtt (FIXSS) will be published after the close of the
public coHSDt period. Reviewers should be aware that BPA will
not reprint the material contained in the OBISS for the FBISS.
The FBZS8 will comprise the following* a summary of the OBISS,
EPA's decision on the preferred alternative, responses to
comsMnts received on the DBXSS, the transcript of the public
hearing (or a summary thereof), and any other relevant
information or evaluations developed after publication of the
DBISS.

5-9

(MORE ON BACK)

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Copies of the DEISS are available for review at the following
locations:

Leon County Public Library
1940 N. Monroe Street
Tallahassee, FL 32301
ATTN t Ms. Linda Barber
(904) 487-2665

Coleman Memorial Library
Florida A fc M University
P.O. Box 78i Room 304C
Tallahassee, FL 32307
ATTN: Mrs. M. B. Crump
(904) 599-3370

Robert Manning Strosier Library
Florida State University
Tallahassee, FL 32306-2047
ATTNs Ms. Sharon Schwerzel
Head/ Dirac Science Library
(904) 644-2706

A limited number of copies are available upon request from EPA
at the afore referenced address.

5-10

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U.S. Department of Housing and Urban Development

Atlanta Regional Office. Region iv
Richard B Russell Federal Building
75 Spring Street. S.W
Atlanta. Georgia 30303-3388

July 3, 1990

Mr. Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch
U. S. EPA - Region IV
345 Courtland Street HE
Atlanta, Georgia 30365

Dear Mr. Mueller:

This refers to your Notice dated April 25, 1990, transmitting the
Draft Environmental Impact Statement Supplement for the Tallahassee Leon
County Wastewater Management project in Florida.

Our review indicates there will be no significant adverse impact on
any HUD programs as a result of this action.

Thank you for the opportunity to review and comment on the proposed
project.

Very truly yours,

Ivair

Regional Environmental
Clearance Officer

5-11

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LETTER #1: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT;

ATLANTA, GEORGIA; JULY 3, 1990; IVAR O. IVERSON,
REGIONAL ENVIRONMENTAL CLEARANCE OFFICER

Thank you for your comments. No response necessary.

5-12

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State of florid* ^

»»i	•

\ v f'

Departing^ of IflSftural Resources

pfflnwpi1

>lii 'JUL I I 1990 ~

Div. of Resource Mgmt.

. ^-;-?!Vhch



July 10, 1990

TO:

FROM:

SUBJECT:
FILE NO.:
APPLICANT:
PROJECT:

Jack Woodard, Assistant Director
Division of Resource Management

Grant Gelhardt, Planner IV
Office of Environmental Services
Division of State Lands

Consistency Review

FL9006221695C

Tallahassee - Leon County

Wastewater Treatment

I have conducted a review of the information supplied by the
applicant for the above mentioned project. It does not appear,
at this time, that any state owned upland resource will be
impacted. If the project traverses any sovereignty submerged
lands, an easement from the Board of Trustees of the Internal
Improvement Trust Fund will be required. Any portion of the
project that traverses sovereignty submerged lands should be
designed to have minimal impacts to the submerged and wetland
communities.

If you have any questions, please contact me at (904)488-6242.

GG/cw

Attachments

cc: Susan Radford

5-13

¦ m 'ecfox ——' (fcY

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LETTER #2: STATE OF FLORIDA DEPARTMENT OF NATURAL RESOURCES;

TALLAHASSEE, FLORIDA; JULY 10, 1990; GRANT GELHARDT,
PLANNER IV; OFFICE OF ENVIRONMENTAL SERVICES, DIVISION
OF STATE LANDS (LETTER PROVIDED BY STATE OF FLORIDA
CLEARINGHOUSE)

Thank you for your comments.

In regard to state sovereignty submerged lands, one force main to the proposed
Eastern Expansion Area of the existing City's SE sprayfield is expected to
traverse Munson Slough, and one possibly two additional crossings of the upper
reaches of Munson Slough are expected relative to the proposed golf course
irrigation. Munson Slough is a water course wider than 10 feet at the above
points of crossing, which the USEPA understands from the Florida Department of
Environmental Protection (FDEP) is a critical minimum width for inland
recreationally-navigable waters. Also, Pump Pond, Bonnett Pond, Eagle Lake, Turf
Pond and other wetland areas are located on the Eastern Expansion proposed for
near-future construction by the City of Tallahassee. Regarding the need for an
easement, this should be resolved through the wetland permit application process
that would be initiated by the City of Tallahassee and involve the FDEP and the
U.S. Army Corps of Engineers (COE). The crossing of Munson Slough will require
an easement whereas the presence of ponded areas in the SE Sprayfield is not
expected to require an easement.

5-14

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FLORIDA DEPARTMENT OF STATE
Jim Smith

Secretary of State

DIVISION OF HISTORICAL RESOURCES

R.A. Cray Building
500 South Bronough
Tallahaiiee. Florida 32399-0250
Director s Office Telecopier Number (FAX*)
(904) 466-1440	(904) 4M-3353

>



IP m
rn 2.

cn



o
X

July 12, 1990

Ms. Karen K. MacFarland, Director
State Planning and Development

Clearinghouse
Office of Planning and Budgeting
The Capitol

Tallahassee, Florida 32399-0001

In Reply Refer To:

Laura A. Kammerer
Historic Sites
Specialist
(904) 487-2333
Project File No. 901780

RE: Cultural Resource Assessment Request
SAI# FL9006221695C

U.S. Environmental Protection Agency
Tallahassee-Leon County Wastewater Management
Draft Environmental Impact Statement (DEIS)

Dear Ms. MacFarland:

In accordance with the procedures contained in 36 C.F.R., Part
800 ("Protection of Historic Properties"), we have reviewed the
above referenced project for possible impact to archaeological
¦and historical sites or properties listed, or eligible for
listing, in the National Register of Historic Places. The
authority for this procedure is the National Historic
Preservation Act of 1966 (Public Law 89-665), as amended.

It is the opinion of this agency that the above referenced DEIS
is not complete or sufficient. It does not adequately address
our concerns for the cultural resources that may -be impacted by
the proposed project. First, we note that the document indicates
that "There are no known archaeological or historical resources
within the proposed sites'* (page 3-20). However, there is no
reference as to how this conclusion was reached.

Using the general proposed activity sites location map (page 2-
23), we have reviewed our data in the Florida Master Site File,
and note the possibility that project activities may impact seven
(7) known archaeological sites (see enclose map). In order for
this agency determine adequately whether or not project
activities will impact those sites or other previously unrecorded
archaeological or historical sites, we request that the applicant
submit to this office the final project alternative location
areas plotted on U.S.G.S. topographic quadrangles.

5-15

Archaeological Research Florida FollcJife Program Hbtoric Preservation Museum of Florida History
(904) 4*7-2299	(904) 397-2192	(904) 4*7-2333	(904) 4M-1484

-------
Ms. Karen K. MacFarland
July 12, 1990
Page 2

Finally, we note that the proposed mitigation of impacts on
cultural resources (page 3-28) does not indicate that a
professional archaeological and historical survey will have been
performed to locate and assess sites prior to initiating project
site preparation, nor does it contain provisions to avoid or
mitigate impacts to identified significant sites. This agency
concurs that archaeological sites discovered during project
related activities should be reported to the Florida SHPO and
that ground disturbing activities affecting such discovered
resources be discontinued pending their assessment and, if
necessary, mitigation. However, relying on the discovery and
reporting of archaeological resources during construction, in our
opinion, does not satisfy s.106 review implemented by 36 CFR Part
800.

It is, therefore, the opinion of this office that there is a
reasonable probability of project activities impacting known and
unrecorded archaeological and historic sites or properties,
potentially eligible for listing in the National Register of
Historic Places, or otherwise of national, state, regional, or
local significance. Since such archaeological and historic sites
may be present, it is our recommendation that, prior to
initiating any project related land clearing or ground disturbing
activities within the project areas, they should be subjected to
a systematic, professional archaeological and historical survey.
The purpose of this survey will be to locate and assess the
significance of cultural resources present. The resultant survey
report must be forwarded to this agency in order to complete the
process of reviewing the impact of this proposed project on
archaeological and historic resources.

If you have any questions concerning our comments, please do not
hesitate to contact us. Your interest in protecting Florida's
archaeological and historic resources is appreciated.

Sincerely,

^/^Caorge W. PercyT Director
J/ Division of Historical Rei

Division of Historical Resources
and

State Historic Preservation Officer

GWP/lak

xc: Heinz J. Mueller, EPA
Enclosures (1)

5-16

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5-17

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LETTER #3: FLORIDA DEPARTMENT OF STATE; DIVISION OF HISTORICAL
RESOURCES; TALLAHASSEE, FLORIDA; JULY 12, 1990;

GEORGE W. PERCY, DIRECTOR OF DIVISION OF HISTORICAL
RESOURCES AND STATE HISTORICAL PRESERVATION OFFICER
(LETTER PROVIDED BY STATE OF FLORIDA CLEARINGHOUSE
AND DIRECTLY BY THE DIVISION OF HISTORICAL RESOURCES;
THE LATTER COPY IS PROVIDED)

Thank you for your comments.

The Final Environmental Impact statement Supplement (FEISS) has been amended in
response to your reference to the Draft Environmental Impact statement supplement
(DEISS) statement of concern on page 3-20 ("There are no known archeological or
historical resources within the proposed sites"). section 3.2.1.5 has been
corrected per your July 12 letter and your August 31, 1990 letter to the city of
Tallahassee. This Section now indicates that three known sites (8LE546, 8LE548
and 8LE1436) exist in the preferred alternative and the existing SE sprayfield
and that a nearby fourth known site (8LE1681) was determined to be outside the
preferred alternative area (per your August 31 letter). Your August 31 letter
indicated that sites 8LE546 and 8LE1436 should be relocated and evaluated, Site
8LE548 should not be affected if project site construction (drilling a
groundwater monitoring well) avoids the site, and that site 8LE1681 lies outside
the proposed Eastern Expansion area, in addition to section 3.2.1.5, information
in Sections 2.5.2, 3.2.2.8, 3.3.5, 4.6.1, and 4.7 also pertain to archeological
matters and have been edited accordingly, particularly section 4.6.1. Figure 2-9
(as well as Figures ES-5, ES-6, 4-2, and 4-3) has been added to show the location
of listed archeological resources at the SE sprayfield and expansion areas and
the T.P. smith Plant area (as well as the alternative SW Sprayfield expansion
areas).

The city of Tallahassee has retained a professional archeologist and has
completed a survey of the three known sites. The survey also included a search
for potential, as yet uncovered/unrecorded sites within the 1,803-acre site for
the proposed Eastern Expansion and the 296-acre TPS Plant facility Bite, where
collectively most of the near-future construction proposed by the city of
Tallahassee related to the preferred alternative is planned. Although the City
does not currently propose near-future construction in the Western Expansion of
the existing SE sprayfield, any such expansion would need to be preceded by
coordination with the Florida SHPO and an appropriate archeological survey.

The archeological survey was completed on December 31, 1990 and a final report
has been prepared (see Penton, 1991). In summary, 26 new sites were identified;
all of which were found in the Eastern Expansion area. Five of these sites are
considered significant and in need of additional study. Your Division may wish
additional coordination with the city and/or the USEPA after your review of a
final survey report. The above-referenced sections of the FEISS have been edited
to in- corporate the report's conclusions and recommendations. in addition,
Figures ES-5 and 4-2 illustrate the general location of the new sites.	'

Your request for the applicant to provide the location of the final (preferred)
alternative on USGS topographical maps was addressed in a letter from the City
of Tallahassee dated August 14, 1990. A copy of an aerial of the proposed
Eastern Expansion of the SE Sprayfield was also provided by the City, and
included the City's proposed site irrigation system layout. A copy of the August
14 letter without enclosures has been attached as part of this response. The
final proposed site layout (Eastern Expansion area) is presented in Figures ES-5
and 4-2 of this FEISS. As indicated above, it is USEPA's understanding from the
city of Tallahassee that the city currently only proposes near-future
construction in the Eastern Expansion area and at the T.P. Smith facility
acquisition of and construction at the Western Expansion area appears unlikely
at this time. However, since the Western Expansion area is part of the preferred

5-18

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alternative, Figures ES-6 and 4-3 have been added to the FEISS to depict this
aprayfield area. Any future sprayfield construction in this area by the City
would need to be preceded by an archeological survey similar to that conducted
by the City for the Eastern Expansion area.

Also included as part of this response are: 1) the City of Tallahassee's letter
dated August 14, 1990 responding to your original July 12, 1990 letter; 2) your
letter to the City dated August 31, 1990; 3) the city's letter to the Institute
of West Florida Archeology, University of West Florida dated October 30, 1990
(the contracted cost has been deleted in the copy provided here in this FEISS);
4) the uSEPA's letter to your Division dated December 21, 1990; and 5) your
letter to USEPA dated January 14, 1991.

5-19

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lllla.^Lalltl ¦¦	Ci'v -Au	DOOCNi* NMAN

¦^1 lllllHIIIIII^V 'ALLAHASSEc. :l	MovOr-Co»rw>.iiion«r

P ' 'lillllrvUu •' kT 32301-1731	STEVE ME.SWJDG

JUT	004/599-8100	cS^S*

CfTV OF TALLAHASSEE		

BOA HlGMlOWff)	DANIEL A 
-------
Ms. Laura A. Kj-nrerer
Historic Sices Specialise
August 14, 1990
Page 2

After reviewing chis information, please advise me as to whether any further
archeo log Lea I assessment will be required before the City can begin
construction. By copy of this letter to U.S.E.P.A., I am advising them that any
further archeological assessment required for them to complete the E.l.S. should
be coordinated through you.

Should you need to contact me by telephone, my number is 575-011^.



Jbnn L. Dean
Superintendent

JLD:jfm

Enc losures

xc :

Heinz J. Mueller, Environmental Protection Agency
Corey Berish, Environmental Protection Agency
Chris Hoburg, Environmental Protection Agency
Skip Cook, Camp, Dresser 4 McKee
James H. Peters, Director - Water & Sewer Dept.
C. Keith Turner, Supervisor - Sewer Treatment
Frederick J. Dressel, Plant Supervisor
Randy Bond, Chief Plant Operator

William G. Leseman, Superintendent - Water Quality Lab

5-21

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FLORIDA DEPARTMENT OF STATE

Jim Smith
Secretary of State

DIVISION OF HISTORICAL RESOURCES

R.A. Cray Building
500 South Bronoufh
Tallaha****. Florida 32399-0220
Director's Office	Telecopier Number (FAX)

(904) 4M-14S0	(904) 4M-33J3

August 31, 1990

t?A

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& 10 I 15 PM '90

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asse: : -

• S J ii

Mr. John L. Dean
Superintendent, Sewer Division
City of Tallahassee
City Hall

Tallahassee, FL 32301-1731

In Reply Refer To:

Laura A. Kasunerer
Historic Sites
Specialist
(904) 487-2333
Project File No. 902383

RE: SAI IFL9006221695C

U.S. Environmental Protection Agency
Tallahassee-Leon County Wastewater Management
Draft Environmental Impact Statement (DEIS)

Refer. Project File No. 901780

Dear Mr. Dean:

In accordance with the procedures contained in 36 C.F.R., Part
800 ("Protection of Historic Properties"), we have reviewed your
letter and naps of August 14, 1990 which details the proposed
construction schedule for three activities. The following
comments discuss those activities individually and presently
known sites are plotted on the enclosed maps.

1.	Expansion of the Thomas P. Smith Wastewater Trantment Plani-

This office recommends a professional archaeological site
assessment survey of the entire expansion area. Sites are
expected to be found in association with Munson Slough.
Previously recorded site, 8LE546, should be relocated and
evaluated.

2.	Eastern Expansion of the Southeast Snravflairt

We recommend a professional archaeological site assessment
survey of the entire expansion area. Sites are expected to
be located in association with the ponds and Eagle Lake, and
other sinkhole features, site 8LE1436 located adjacent to
Pump Pond should be relocated and evaluated. A review of
the Florida Master Site Pile form and map for site 8LE1681
indicates that it is located outside the expansion area.

5-22

Archaeological Research Florida Folklife Programs Historic Preservation Museum of Florida History
(904) 417-2299	(904) 397-2192	(904) 4*7-2333	(904) 4M-14I4

-------
Mr. John L. Dean
August 31, 1990
Page 2

3. Groundwatpr Monitoring Well Construction

Although we have insufficient information to adequately
evaluate the potential impact of this activity on site
8LE548, if the site location is sufficiently avoided, there
will be no effect.

In conclusion, we look forward to receiving a professional survey
report(s) for the two expansion projects discussed above. The
survey of these areas can be combined as one project or completed
and evaluated individually in order of the proposed construction
scheduling. When or if, alternative sprayfield sites other than
these two are scheduled for construction, this office must be
consulted to review the proposals.

If you have any questions concerning our comments/ please do not
hesitate to contact us. Your interest in protecting Florida's
archaeological and historic resources is appreciated.

£«or44 W. Percy, Director
Division of Historical Resources
and

State Historic Preservation Officer

GWP/lak

xc: Don Henningsen, OPB (W/Encl)

Heinz J. Mueller, EPA (W/Encl)

Enclosures (2)

5-23

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CONTOUR INTERVAL 10 FEET
OOTTED UNCS REPRESENT 5-fOOT CONTOURS
DATUM IS MEAN SEA LEVEL

5-24

THIS MAP COMPLIES WITH NATIONAL MAP ACCURACY STANOAROS
FOR SALE BY U. $. GEOLOGICAL SURVEY. WASHINGTON. 0. C. 20242
A FOLOCR DESCRIBING TOPOGRAPHIC MARS ANO SYMBOLS IS AVAILABLE ON REQUEST

• QUAOIUNCLC LOCATION

-------

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UNITEO STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IV

343 COURTLANO STREET. N.E.

ATLANTA. GEORGIA 30365

December 21, 1990

Ms. Laura Kammerer
Historic Sites Specialist
Division of Historical Resources
Florida Department of State
500 South Bronough
Tallahassee, FL 32399-0250

RE: Project Files No. 901780 / 902383
SAI# FL9006221695C

Tallahassee-Leon County Wastewater Management

Draft Environmental Impact Statement Supplement (DEISS)

Dear Ms. Kammerer:

This is in response to Mr. George Percy's letter of July 12, 1990,
concerning the above-referenced EIS project. The U.S. Environmental
Protection Agency (EPA) is also aware of a City of Tallahassee letter
to the Division of Historical Resources (DHR) dated August 14, 1990
and DHR's response letter dated August 31, 1990 regarding this
matter. We have also discussed archaeological aspects of this
project with you and the City of Tallahassee by telephone. As the
lead Federal agency for this EIS, EPA understands our
responsibilities under Section 106 of the National Historic
Preservation Act and will strive to ensure that the following are
accomplished:

1.	An archaeologist, whose qualifications and proposed methods
are approved by DHR, will be engaged to perform an archaeological
survey to assess portions of the DEISS preferred alternative. We
understand that the City of Tallahassee, as the applicant, has
retained the archaeologist and that the archaeological survey has
been initiated and is to be completed in the very near future.

2.	The survey includes an assessment of known sites (8LE546,
8LE548 and 8LE1436) within the preferred alternative and the
existing Southeast Sprayfield referenced in the DHR letters dated
July 12 and August 31. Site 8LE546 is located at the Thomas P.
Smith Wastewater Treatment Plant site, Site 8LE548 is located in
th existing Southeast Sprayfield, and Site 8LE1436 is located in
the proposed Eastern Expansion of the Southeast Sprayfield.
Another nearby another site, 8LE1681, was determined to be
outside the perferred alternative area per the August 31 letter.
The survey also includes a search for potential sites as yet
uncovered/unrecorded within the 296-acre Thomas P. Smith
Wastewater Treatment Plant site and th# 1803-acre site for the
proposed Eastern Expansion of the existing Southeast Sprayfield.
Most of the near future construction proposed by the City of

5-27

Printad on tocycbd Papt

-------
-2-

Tallahassee related to the EIS project is planned for these two
areas, pending successful completion of the EIS process. The
significance of all sites will be investigated in consultation
with the DHR to determine their potential eligibility for
inclusion in the National Register of Historic Places.

3. As sites and their relative significance are revealed,
appropriate environmental protection and/or mitigative measures
(i.e., avoidance, preservation, or other as directed by DHR) will
be developed in consultation with DHR.

Although we understand that the City of Tallahassee does not
currently propose near future construction in the Western Expansion
area of the existing Southeast Sprayfield due to land acquisition
difficulties, any such or other construction related to the preferred
alternative would need to be preceded by coordination with the
Florida SHPO and any appropriate archaeological survey.

I hope that these proposals address your concerns for the cultural
resources that may be impacted by the proposed project. EPA
requests to be copied on correspondence concerning this matter for
documentation. EPA will continue to keep the Florida SHPO on the EIS
mailing list, so that a copy of the Final Environmental Impact
Statement Supplement will be sent to your Office for review.

Please contact me, Chris Hoberg or Marion Hopkins if you have any
questions (404/347-3776). We greatly appreciate your cooperation.

Sincerely,

Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch

cc: Don Henningsen, Florida State Clearinghouse

John Dean, City of Tallahassee Sewer Division

5-28

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FLORIDA DEPARTMENT OF STATE

Jim Smith	1 7 R£M)

Secretary of State
DIVISION OF HISTORICAL RESOURCES

R.A. Gray Building
500 South Bronough
Tallahasiee. Florida J2399-0230
Director s Office	Telecopier Number (FAX)

(904) 488-1440	(904) 488-3353

January 14, 1991

Mr. Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch
U.S. Environmental Protection
Agency, Region IV
345 Courtland Street, NE
Atlanta, GA 30365

RE: SAI# FL9006221695C

Tallahassee-Leon County Wastewater Management

Draft Environmental Impact Statement Supplement (DEISS)

Dear Mr. Mueller:

In accordance with the procedures contained in 36 C.F.R., Part
800 ("Protection of Historic Properties"), we have reviewed the
above referenced DEISS. We find that the DEISS proposals
adequately address this agency's recommendations concerning
cultural resources. The inclusion of the of your December 21,
1990 proposals in the final Environmental Impact Statement will
satisfy this agency's considerations.

If you have any questions concerning our comments, please do not
hesitate to contact us. Your interest in protecting Florida's
archaeological and historic resources is appreciated.

Sincerely,

^^^Seorge^/ Percy ,' Director
As Division of Historical Resources

and

State Historic Preservation Officer

GWP/lak

xc: Karen K. MacFarland, OPB

5-29

In Reply Refer To:

Laura A. Kammerer
Historic Sites
Specialist
(904) 487-2333
Project File Mo. 903752

ArdiMolosical RmmtcIi Florida Folldtfe Program fteoric Pwrvalhw Mtanun of Florida History
(904) 487-2299	(904) 3*7-2192	(904) 487-2333	(904) 488-1484

-------
Unitad Stat*	Soil	Stats Office, Room 248

Department of	Conservation	401 S. E. First Avenue

Agriculture	Service	Gainesville, PL 32601

Heinz J. Mueller, Chief
Environmental Policy Section
EPA, Region IV
345 Courtland St., N.E.
Atlanta, Georgia 30365

Dear Mr. MueI Ier:

JuIy 12, 1990 .

Co



Me have reviewed your Draft Environmental Impact Statement (DEIS)
for Tallahassee-Leon County Wastewater Management and have no
comments to offer at this time.

We appreciate the opportunity to comment on this proposal.

S i ncereIy,

'J, ^

-j j. ^ -1

Y. Ni I es i»^asgow
State Conservationist

cc: James B. Newman, SCS, NHQ, Director, Ecological Sciences Division

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LETTER #4: UNITED STATES DEPARTMENT OF AGRICULTURE; SOIL

CONSERVATION SERVICE; GAINESVILLE, FLORIDA; JULY 12,
1990; T. NILES GLASGOW, STATE CONSERVATIONIST

Thank you for your comments. No reaponas necessary.

5-31

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Florida Game and fresh water fish commission

WILLIAM G. BOST1CK. JR.
Winter Haven

DOS WRIGHT
Orlando

THOMAS L. HIRES. SR.
Lake Wfefct

MRS. GILBERT W. HUMPHREY
Miccoaaitae

JOE MARLIN HILLIARO
Oewtston

ROBERT M. BRANTLY. timiitt Dnrw
XI.LAN L. E(iBCRT. Ph.D.. Amhum E«ciHiif DtracMr

FARRIS BRYANT BUILDING
t2C South Meridian Strm
TallahaM**. Florida 52)99-1 bCC
(9041 *««>• I WiC

July 12, 1990

* ** . .

~ v .. ; •• ; •. %.••v
< • v

M I3U»

Ms. Karen MacFarland, Director
State Clearinghouse
Office of Planning and Budgeting
Executive Office of Lhe Governor
The Capitol

Tallahassee, Florida 32399-0001

RE: SAI# FIS006221695C, Draft

Environmental Impact statement
Supplement, Tallahassee - Leon
County Wastewater Management

Dear Ms. MacFarlaxrl:

The Office of Environmental Services of the Florida Game and Fresh
Water Fish Ccntaission has reviewed the referenced draft Environmental
Inpact Statement Supplement. We previously ocrmented on a preliminary
draft of this wastewater management project and reocmnended further
consideration of Alternative 9 over the "preferred alternative",
Alternative 1. The ccnments provided in our 16 February 1990 letter to
the Environmental Protection Agency (enclosed) still apply.

Please aontact Mr. Larry Perrin (904/488-6661) if you have any
questions.

Sircerely,

Bradley J. Hartman, Director
Office of Environmental Services

BJH/LP
ENV 1-3-2
Enclosure

5-32

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Florida Game and fresh Water Fish commission

C. TOM RAINEY. D.V.M. WILLIAM G. BOSTICK. JR.

Miami	Wmtrr Hjv ANT ML I.I.DJNi; .
<>iSnurh Mmdofn-^frrrf «' ¦
TjlhK;i»vrr flmidl )2 WS-HOCj

i«o«f	" '



.1v

February 16, 1990

Dr. Cory w. Berish
U. S. EPA Region IV
EIS Preparation Section
345 Courtland Street
Atlanta, Georgia 30365

BE: Twllnhfuwew -Leon County
ftestauater Managwent EIS
SupploMnt

Dear Dr. Berish:

The Offfioe of Environnerttal Services of the Florida Game and Fresh
Water Fish Camissian has reviewed the referenoed preliminary draft EIS
Supplement and offers the following ocmnents.

This EIS Supplement addresses the projected wastewater management
needs for Tallahassee-Leon Gcunty through the year 2010. Nine wastewater
management alternatives were developed. Eight of theee were considered
as centralized systems (large-scale facilities incorporating a network
conveyance system}. The remaining alternative was a decentralized system
(a system which focuses primarily on snail-scale, on-lot treatment
facilities). The nine alternatives were narrowed down to four
alternatives, three centralized alternatives and the one decentralized
alternative. Following the evaluation of these four alternatives, the
Environmental Protection Agency selected Alternative l as the preferred
alternative. The selection of Alternative 1 over the other three
alternatives was based on the ranking results of the four alternatives
and the fact that the City has had experience operating this type of
system.

Alternative 1 is a centralized system and oonsists of improving the
Lake Bradford Plant, iaprcrving and expanding the T. P. Smith Plant, and
increasing the size of the existing scutheest agricultural sprayfield
irrigation site by 1,410 acres. Sludge produced by UeatmenL apiiitiene
would be applied to the land around T. P. Smith, the existing Southwest
spray field, and an expanded airport site.

5-33

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Dr. Cory W. Berish
February 16, 1990
Page 2

In reviewing the ranking evaluation conducted for the four
alternatives, three of the alternatives (Alternatives 1, 2, and 9) had
essentially equal overall values. Alternatives 1 and 2 each had a
ranking score of 13 and Alternative 9 had a score of 12. The remaining
alternative evaluated, Alternative 7, had a ranking soore of nine.

Because of the subjectivity involved in this type of ranking method and
the close soores of three of the alternatives, further evaluation of
these options seems warranted. Fran this standpoint, both Alternative l
and 2 were similar in almost every respect (costs, ranking evaluation,
and "present worth value") except that Alternative 2 involved a forested
sprayfield application rather than agricultural sprayfield irrigation.

Alternative 9 on the other hand, represents the decentralized
alternative and would consist of improving the Lake Bradford Plant,
expanding the Killaarn Lakes Plant, expanding the Southeast Agricultural
Sprayfield by 469 acres, and using on-lot traatanent systems. From
reviewing the information provided for this alternative, it appears that
this option should receive greater consideration.

As previously mentioned, the ranking evaluation for Alternative 9
was similar to Alternatives 1 and 2. In addition, according to Table 2-
20 this alternative has the lowest "present worth value1* (value that
incorporates both initial capital outlay and future annual costs) of any
alternative. While the overall total system cost for this alternative is
given as almost $100 million, $93 million of this total is projected for
development of on-lot systems (Able 2-19). At the public meetings held
for the discussion of wastewater management options, it was brought out
that the development of on-lot systems do not have to be a public
expenditure and these features could be made the responsibility of
development interests. Such a position would result in an extremely
large cost reduction for this alternative. Further, to reduce concerns
with respect to the proper operation of on-lot systems, this report
fUsmssee the creation of a joint Tallahassee-Laon County wastewater
management agency as a possible eoluticn. Xt would seem likely that such
a joint agency could also assist other areas of water management such as
storawater management, and inspection and enforcement programs.
Additionally, this report notes that centralized systems are ocnplex and
difficult to operate while decentralized systems are staple to operate
and maintain (Table 2-23). Moreover, decentralized systems are also
reported to provide increased flexibility for handling future demands due
to the large amount of suitable soils in the study area.

In conclusion, cur agency is pleased that the alternatives
considered in this report no longer include any proposals for use of the
Apalachioola National Focest. Further, we reocanand that Alternative 1
be reconsidered in view of seme of the apparent benefits associated with
Alternative 9. It seems likely that Alternative 9, if properly
implemented, oould reduce environmental iapacts relative to centralized
systems, lessen the need far extensive land areas, and place the

5-34

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Dr. Cory w. Barish
February 16, 1990
Page 3

responsibility for expanded wastewater facilities on those individuals
that would benefit from these services, rather than have than provided at
the expense of the general public and our natural resources.

We appreciate the opportunity to provide ocmnents on this
preliminary draft EIS. Please contact Mr. Larry Perrin (904/488-6661) if
you have any questions.

Sincerely,

_ 1 rtriPn, r
Bradl^ J. ^krtnan, Director
Office of prvironnantal Services

BJH/LP
ENV 1-3-2

cc: Mr. Robert T. Jacobs, Forest Supervisor, U. S. Forest Service
Mayor Dorothy Inman, city of Tallahassee
Ms. Gayle Nelson, Chairman, Leon County Omission

5-35

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LETTER #5s FLORIDA GAME AND FRESH HATER FISH COMMISSIONf

TALLAHASSEE, FLORIDA; JULY 12, 1990; BRADLEY J.

HARTMAN, DIRECTOR OF ENVIRONMENTAL SERVICES
(LETTER PROVIDED BY STATE OF FLORIDA CLEARINGHOUSE)

Thank you for your comments. The various items addressed in your letter are

discussed in the following numbered sections)

1. Soils

a. North versus south Leon Countv soil types and septic tank failures.
References in this FEISS to soil characteristics and distribution
patterns include the Executive Summary (Figure ES-4), the Project Updates
Summary, and sections 2.1.4, 2.2.2, 2.3.5.1, 2.5.2, 3.2.1.2, 4.5 (Figure
4-1), C-l, and the USEPA responses to USEPA Public Hearing comments in
this Chapter 5 (speaker John Gray), as well as the cited Leon County Soil
Survey (USDA [SCS] and USFS, 1981).

From a soils suitability perspective, it appears from the 1981 soil
survey of Leon county, Florida (USDA [SCS] and USFS, 1981) that the
northern part of Leon County is generally less suitable for septic tank
and spray irrigation wastewater disposal than the southern part. This
is not to say, however, that favorable soils for septic tanks and spray
irrigation do not exist in both northern and southern areas of Leon
county or that unfavorable soils do not exist in southern Leon county.
However, the USEPA understands that the Leon County Public works
Department apparently conducted a spray irrigation site assessment in
1989 and determined that more acreage would be needed to dispose the same
quantity of effluent in the selected northern alternative sites than in
the selected southern alternative sites due to soil types. This suggests
a slower percolation rate at the northern sites.

The USEPA understands from the city of Tallahassee that the City would
concur with the County with such a trend for northern versus southern
Leon County in general, since the northern portion of the County appears
to be generally underlain by layers of clay and since sandy upper
horizons are rather shallow. The City has conducted geohydrologic
analyses by contractor for nine sites in northeastern Leon County in
1991. core soil samples generally exhibited clay layers of varying
degree in the samples collected. Such clay layers would affect the
drainage capabilities of the area and thus its suitability for septic
tank and spray irrigation disposal.

This trend also generally agrees with Table 2-9 of this FEIS8. When the
acreage predicted to be required for agricultural spray irrigation in the
SE (component Dl) is compared to agricultural spray irrigation in the NE
(component D2), the average acreage needed per effluent flow (mgd) is
much greater in the NE (430 acres/mgd) than in the SE (188 acres/mgd).
The same trend also exists for the NE forest irrigation site (component
D4: 524 acres/mgd) compared to the SE forest irrigation site (component
D3i 197 acres/mgd). (Note: This trend, however, is not true in every
instance since the artificial wetlands with RIBs disposal in the SE
(components Dll and D16) are predicted to require the sane amount of
acreage as in the NE (cosqponents D12 and D17), i.e., Ill acres/mgd). For
Table 2-9, the maximum application rate was used to estimate acreages and
was based on the soils in the 1981 Leon County Soil survey at the given
sites. However, the USEPA recommends that soil percolation testing be
conducted at any site proposed for irrigation be implementation to
determine actual soil percolation rates.

Based on the "General soil Map" for Leon County in the 1981 Soil survey,
Leon County is dominated by three soil associations t the Orangeburg-Lucy-
Norfolk association in the northern part of Leon County and the
Kershaw-ortega-Alpin and the Dorovan-Talquin-Chipley associations in the
southern part of Leon County. The orangeburg-Lucy-Norfolk soils and the
Kershaw-ortega-Alpin soils are generally well-drained while the Dorovan-

5-36

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Talquin-chipley soils are generally not well-drained, specifically, the
1981 soil Survey classifies the Orangeburg-Lucy-Norfolk soils as "well
drained soils" and the Kershaw-ortega-Alpin soils as "excessively drained
and moderately well drained soils," while the Dorovan-Talquin-chipley
soils are considered "somewhat poorly drained to very poorly drained
soils." of the two well-drained soil associations, the depths of these
sandy associations differ significantlys the Orangeburg-Lucy-Norfolk
soils are sandy to only 20-inch depths with loam below, compared to sandy
20-40 inches deep with loam below or are loamy throughout /Mote? "loam"
is a soil type that is defined in the 1981 soil survey as a mix of clay
(7-27%), silt (28-50%), and sand (<52%) particles.) By contrast, the
Kershaw-ortega-Alpin soils are sandy to 80 inches or more, with some
having loamy layers (lamella*) below 45-inch depths.

Regarding the suitabilities of these soil associations for septic tank
absorption fields, Table 11 of the 1981 Soil survey presents the
"restrictive soil features" of existing soil types. All listed
Orangeburg, Lucy and Norfolk soil types are classified as "moderate:
perca slowly" and/or "moderate! wetness," with "moderate" being defined
as having unfavorable soil properties for the given activity. The
Kershaw soils are classified as "slight" which is defined as soil
properties generally favorable for the activity. Oretega and Alpin soils
are classified as "severet poor filter," with "severe" being defined as
soil properties very unfavorable for the activity. The Dorovan, Talquin
and chipley soils are classified as "severet wetness" or "severei floods,
wetness." These classifications indicate that only the Kershaw soils
have properties favorable for septic tank absorption field infiltration
while the others do not adequately drain or drain too wall and therefore
do not provide proper filtration (i.e., adsorption of inorganics
(metals), microbes, ate.). Leon county therefore appears to be a mix of
soil types with "slight,• "moderate" or "severe" classifications
regarding the suitability for septic tank activity. The preliminary 1988
Leon county MWfcSSF also addresses the issue of soil suitability for
septic tanks within Leon county.

specific to the proposed eastern Expansion of the existing SE Sprayfield
in southeastern Leon county, Figures ES-4 and 4-1 taken from the Leon
County soil survey (USDA [SCS] and USFS, 1981), present a composite of
tha soil types in the Eastern Expansion area proposed by tha City for
near-future construction as part of preferred Alternative 1. Based on
the 1981 soil survey, the soils of tha Eastern expansion Area sprayfield
site proposed by the city are dominated by Ortega Sand, Kershaw sand with
a 0-5% slope, Talquin Pine sand, chipley Fine sand and Kershaw sand with
a 5-8% slope, respectively. of these, only the Kershaw sands are
classified as favorable for septic tank absorption fields (classified as
"slight," i.e., having favorable soil properties for the activity).

Of the portions of the proposed Eastern Expansion Area sprayfield
proposed for irrigation (i.e., center pivot irrigation Areas A-E and
adjacent fixed head irrigation areas: Refer to Fig. ES-5 or 4-2 of this
FBI88), irrigation areas associated with and adjacent to Areas A, B, and
D primarily contain Kershaw Sands while irrigation areas associated with
and adjacent to Areas c and E primarily contain Ortega Sand. As
indicated, Kershaw Sands are considered suitable soil types for septic
tank absorption fields while Ortega Sand would not be favorable due to
poor filtration capabilities (too well-drained sande). Bowever, it
should be noted that the City's proposed project is not septic tank
disposal of raw sewage, but rather spray irrigation of monitored,
aecondarily-treated sewage effluent. As such, spray irrigation would
disperse effluent over a greater area than septic tank disposal and also
would dispose wastewater of a considerably higher water quality than
untreated raw sewage wastewater of septic tanks. (Specifically, all of
the vertical soil horisons are utilised fog filtration	'¦pray

irrigation whereas several inches of soi 1 filtration are net utilised in
septic tank drainage fields, since drainage lines 8re buried several
inches below the surface; spray irrigation utilizes the entire horizontal
soil surface area whereas septic tank fields only utilise soil areas

5-37

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associated with the drainage lines; and secondarily-treated spray
affluent requires considerably less soil filtration for purification than
untreated septic tank raw sewage wastewater.)

Because of the filtration limitations of the Ortega Sand in the proposed
irrigation areas associated with and adjacent to Areas C and E as well
as some unfavorable soils interspersed in irrigation areas associated
with and adjacent to Areas A, B and D, the USEPA recommends reduced
irrigation application (inches/week) in these areas. If monitoring
exhibits compliance with State of Florida groundwater quality standards
and monitoring is conducted to the satisfaction of the state of Florida,
additional application can be tried if commensurate with groundwater
quality compliance. Groundwater monitoring is also essential since the
entire Eastern Expansion Area lies in the Woodville Karst Plain, i.e.,
Karstic geology that is subject to water dissolution and collapse
(sinkholes). In any areas of collapse, irrigation should be stopped
immediately in those areas and the state of Florida notified. The USEPA
recommends that no effluent be sprayed in a reasonable surrounding area
of the existing sinkhole depressional area located within the proposed
fixed head irrigation area adjacent to Area D, as well as any other
potentially discovered sinkhole areas (Refer to Fig. ES-5 or 4-1 of this.
FEISS). The USEPA further recommends that the State of Florida consider
the existing soil characteristics and Karstic conditions of the proposed
Eastern Expansion Area in their permitting decision for the City's
proposed sprayfield expansion.

As indicated in Section 2.1.4, septic tank drainfield failures have been
investigated and documented for the Killearn Lakes Subdivision area
located in the northeast portion of Leon county. Failures were generally
due to a combination of slowly permeable soils, high water table
elevations in confining layers, storm water runoff and drainage, and high
density development. As a consequence, the Leon Public Health Unit
recommended a central sewage system and adequate storm water collection
system for the area. The Public Health Unit also advised restrictions
for issuing on-lot sewage disposal system permits. However, this is not
to say that such failures were documented throughout Leon County, since
soil permeability and other conditions vary in the county, with some
soils being suitable for septic tanks. The County is currently compiling
a computer-based inventory of septic tank drainfield failures. However,
this inventory only includes "new" failures and therefore cannot provide
a historical record to quantify the problem caused by failures or to
identify all specific problem areas.

It should also be noted that the Leon County Public Health Unit has
indicated that the successful operation of septic tank drainf ields in the
study area is a function of available soil storage above a confining
layer and not necessarily the capacity of the soil to move water.
Accordingly, tests and the measuring of water table elevations before
development may be misleading for determining the suitabilitv of areas
to accommodate drainfields.

b. centralized versus decentralized systems and ««i-Tr pollution. it is
often believed that public health and the envirorment are better
protected with / centralized sewer system than with a decentralized
septic tank/drainfield system. Factors contributing to this conclusion
includes

SESii	maintained for preventative maintenance

SSSIllv	U.	MPtio tank/drainfields

generally are only -maintained- after a malfunction has occurred

during which time nearby water resources are threatened.

centralised systems are operated and controlled to provide specific
removal of pollutants and disinfection of the effluent Shareas
septic tanks are not -operated- and therefore do not pr "ide a high
level of control over treatment functions.	F	9

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•	A centralized system disposes of its effluent to a controlled and
confined location (e.g., a point discharge to a surface water or a
spray irrigation field); therefore, if problems arise leading to a
malfunction, the problem is localized, in contrast, a region of
septic tank/drainfield failures can affect a larger area.

•	Centralized systems generally include water quality monitoring to
check for water quality changes so that problems can be detected
and corrected quickly before water resources are severely impacted,
on the other hand, the proliferation of septic tank/drainfield
systems over a large area makes implementation of an effective
groundwater monitoring program virtually impossible, since water
quality changes are not monitored, septic tank/drainfield failures
can go undetected for a long time. The cumulative impact of
individual septic tank/drainfield failures can severely degrade the
water quality of nearby water resources during this Him *nd have
the potential of spreading water-borne diseases. Once a water
resource has been degraded in a decentralized system, it then takes
a major effort to determine the specific source(s) of the problem
and to correct the malfunctions.

•	Decentralized systems have a greater tendency for generation of
non-point source water quality problems, particularly in Florida
due to a shallow water table and potential for contamination of
surface waterbodies.

•	Changeover from a decentralized system to a sewered system is a
common pattern in urban and suburban areas, costs associated with
such a changeover are greater than if a centralized system was
implemented initially.

One option for minimizing the number of failures is to fund a large joint
Tallahassee-Leon County wastewater management agency that would regularly
and rigorously inspect drainfield siting, installation, and operation in
the region. The large "public expenditure" for funding this joint agency
was not accounted for in the costs evaluation of the FEiss alternatives.

C. Flexibility of decentralized SVStemi tOV	future demands. A.

indicated above in Item l.a., it is recognized that some soils in the
study area are suitable for septic tank/drainfield systems. This same
characteristic also promotes the flexibility of a spray irrigation system
to expand and handle future flows. The use of septic tank/drainfield
systems can be considered to be restrictive to development in that the
systems require development to allocate specific areas of the property
for the facility installation and operation. This became particularly
apparent in the Killearn Lakes Subdivision where the large number of
failures was attributed in part to small lot sizes (Refer to sections
CHECK 2.1.4 and 2.3.5.1). centralized sewer-based systems, on the other
hand, do not require specified lot sizes for development. Subsequently,
a sewer system allows development to be consolidated instead of spread
out to accommodate the area needs of individual drainfields.
Consolidation of development in turn could potentially, if so-managed,
preserve the remaining areas as "open space" thereby preserving valuable
wildlife habitat that ®ay otherwise be destroyed for less dense
residential and commercial development. sewering and septic
tank/drainfield land area requirements can regulate j development by
encouraging dtvilopMnt to occur vhirt itwtr liQAi wr® iQitAlltd And by
restricting development in areas not serviced by the lines. it should
also be noted that the cost of replacing septic tanks with sewers in
areas experiencing failures is up to four times the cost of installing
sewers at the time of development.

2. Efficiency of	_ ««ici.ncyofa system	its

effectiveness in removal of pollutants. •iftbe centralized systems are
operated by trained staff, maintained for preventive rather than corrective
purposes, and are constantly monitored, the efficiency of treatment of
wastewaters are generally higher than septic tank/drainfield systems. The

5-39

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treatment, using vegetative uptake and soil infiltration at the effluent
spray irrigation disposal site.

3.	concept of wastewater effluent as a water -resource'' rather than a waste.
The preferred alternative not only provides a highly efficient and effective
treatment of wastewaters (See item 2 above), but it also provides a
previously unavailable resource, a nutrient-rich water supply for irrigation
of cash crops for animal feed and/or processed food for humans to the extent
consistent with Chapter 17-610 F.A.C. In addition, the spray irrigation
system and the septic tank/drainfield systems provide valuable recharge to
the groundwater aquifers. Also, a component of the preferred alternative is
the use of treated wastewater to irrigate golf courses. This replaces the
need for using valuable potable water resources and has been successfully
used in other areas, including the city of St. Petersburg, Florida, which
sprays "gray" water onto local golf courses. If properly applied, spray
irrigation of golf courses can reduce non-point source runoff problems since
it would reduce the need for fertilizer application. (Although irrigation
of golf courses is proposed by the preferred Alternative 1, it is USEPA's
understanding from the City that the City does not plan any implementation
in the near future.)

4.	Per capita coBt of the preferred alternative centralized system. Though the
decentralized alternative has the lowest estimated present worth value of
all the four further-considered alternatives, the preferred alternative has
a low estimated average annual household cost ($270 in 1989 dollars). This
estimated value is less than the usEPA-recommended maximum for the study
area (Refer to Section 3.1.1.3.5). It should also be noted that, though the
decentralized alternative has been assigned the lowest present worth value,
there are unguantified costs that will be incurred if the alternative were
implemented. These costs include the funding of a joint Tallahassee-Leon
County wastewater management agency to inspect and enforce regulations for
siting, installing, and operating septic tank/drainfield systems (See item
l.c above). Also the disposal of the septage flushed from septic tanks
during regular maintenance cleaning would need to be addressed. The
decentralized alternative would result in a large number of tanks needing
regular cleaning to ensure proper functioning. Generally, septage needs to
be hauled to and "processed" at a wastewater treatment facility prior to
disposal. This could require special handling so as not to interfere with
the facility's biological-based operations. Costs for septage hauling and
handling were not included in the decentralized alternative's present worth
value. On the other hand, connection fees (hook-up costs) were not
considered for the centralized alternatives in the cost comparisons of the
alternatives (Note: Hook-up costs are discussed in the "Program Updates
Summary" Chapter following the Executive summary of this FEISS and also
briefly in section 3.1.1.3.5).

The USEPA appreciates your office's participation in the field survey on January
23, 1991 of the proposed Eastern Expansion site of the existing SE Sprayfield to
help characterize specific areas proposed for spray irrigation relative to
habitat value, especially relative to the protected Gopher Frog and Gopher
Tortoise. Coordination with your Office was recommended by the U.S. Fish and
Wildlife Service. (Also refer to DEISS comment letter #9 from the U.S.
Department of the Interior and the associated USEPA response including the letter
from your office dated February 6, 1991. Also refer to Section 4.4.1 of this
FEISS.)

5-40

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Executive
Office
of the
Governor

The Capitol
TaJlalMMee. n
32399-0001

EN, REGION IV
ATTN: HEINZ K'JELL£S
3*5 C3BITUM 5T, «
ATLANTA, 6A 30355-

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SAI: FL900822IS95

PROJECT: ORAFT ENVIRONMENTAL IMPACT STATEMENT SUPPLEMENT
TALLAHASSEE • LEON COUNTY WASTEWATER NANASINENT - TALL

ahas'see, leon county, Florida

RE'.EIVEC: 08/22/90	pandmerepeatingreview

TrtgiriT aSuStjipoia^aaIdeSier (2M) rtanbor! ahoum abac. uMdi should be used hal
oommtaiicatfons with Ms ofloe ooncemfcig the application or pnpfett

The 51* dutniiouK y coon*ute a review of the ^y«rattnn or protect purauant to Preai-
dentin executive Older 12372; GUjematorlai Executive Order nnrtxr 83-120; section 216312.
rtartfe SMuks; Bie national Eifttonmenbl PofcyAct- the florida approved coastal management
proven; fte Outer ConlfcienM She* Lantfe Act and after feda* or Mbmiadonat review

The review be*» on the date the eowespondence b iwetad by jhe SMe Ctearin^mae and
noma* ta connieted In 30 days, aWwurti longtr reviewperiods of 45 and 00 days are penntted
by fedent few fcr medic ftpes of appfeations or pngecfe. Completion of tie review may be delayed

send three (3) copies alyovr appfcadon or project to the appropriate fa^onai Planning Coundi
(RFC). If applicable.

Florida sure cuAiurmhovse

executive Office of the Govemor/OfB . •'

Growth Management and Planning Policy Unit
The Capitol. Tallahassee. IX 3230*0001
(904) 4084114; (SunCom) 27*0114

5-41

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LETTER #6: FLORIDA STATE CLEARINGHOUSE; EXECUTIVE OPPICE OF THE GOVERNOR;
TALLAHASSEE, FLORIDA; RECEIVED JULY 13, 1990

Thank you for your comments and circulating the Draft Environmental impact
statement Supplement (DEISS) to appropriate offices within the State of Florida.
No response necessary.

5-42

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W, \\^lcCONNELL LAND MANAGEMENT PUNNER / FORESTER

ROAD. TALLAHASSEE. FLORIDA 32304

4	July 17, 1990

iueller, Chief
tal Policy Section
ion IV
Courtland Street N.E.
Atlanta, GA 30365

Dear Dr. Mueller:

You have my letter of March 16, 1990 pointing out deficiencies in the
"Tallahassee-Leon County, Wastewater Management" preliminary DEIS. This
letter is a re-statement of the observations made in that letter. As I will
be unable to appear at the Public Hearing scheduled for August 9, this will
constitute ray formal comments on the DEIS.

CFR 1502.14(a) requires the preparing agency to "Rigorously explore and
objectively evaluate all reasonable alternatives". In preparing this DEIS
the US EPA, Region IV has not com? lied with this requirement.

Specifically, the DEIS fails to consider the alternative presented by me at
thTpublic Hearing held on August 15,. 1989. That alternative proposes that
the nc Forest Service join with the City of Tallahassee in cooperative
ce-use'of »£££ £di«! by the City: the City to furnish effluent and
the Forest Service to use this effluent on its (FS) land in a
research/demonstration project featuring the production of energy-wood in a

multi-resource management system. This R*D .**ISi w,
production of woody biooass as a means of mitigating Global Warming. A copy

of that alternative is attached to this letter.

This proposal, known ^iSrablfS^est^anTJ^rt?'	'r^iSd

letters fcoin S" Die Mississippi Forestry Association,

^	Southeastern Regional Bicnass Energy

(Oak Ridge National Labo ry	^ Agricultural Sciences (Univ. of

Program (TVA), the J^it u (ecoiogiSt and perhaps the leading authority

Florida), and Dr. Andre	» suooorting the concept advanced in that

on the longleaf-wiregrass ecosystem) supporting	^

alternative. Copies of these letters are attached.

_	m» decision to eliminate Forest Service

In preparing the DEIS the US®P f effluent disposal. The rationale for
land from consideration as asit* for ^ ^ section reveals that the
the decision is found in 2.3.3. a r«u * lQration ^ objective analysis of
decision was not based on J rigor Jj* ^ ^ CPR 1502.14(a) but rather
the "effluent to energy	^rii«r generic alternative which

on unsupported counts "Uting to ^	laftd>

proposed, in unspecified terms, cne u*

^ERGY-WOOD MANAGEMENT

5-43

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According to section 2.3.3 the primary issues with regard to using USFS land
are the concern over losing "valuable longleaf-wiregrass habitat" and the
restriction of public access. Section 2.3.3 quotes the Florida Game and
Freshwater Fish Comnission as recommending that such habitat is critical to
maintain and should be restored to the fullest extent possible. Under the
"biomass research" alternative all of the existing longleaf pine-wiregrass
ecosystem is to be maintained. The critical element in the longleaf
pine-wiregrass community is wiregrass, a species extirpated on the areas
proposed for treatment. Longleaf pine can be replanted and the Forest
Service's policy is to replant this species on appropriate sites. The
wiregrass component is another matter. Dr. Andre F. Clewell is a specialist
in the restoration of native plant conmunities and their habitats on
reclaimed and disturbed lands. He is the author of the 1971 report, THE
VEGETATION OF THE APAIACHICOLA NATIONAL FOREST, AN ECOLOGICAL PERSPECTIVE and
a leading authority on the longleaf pine-wiregrass ecosystem. I'm attaching
a reprint of his most recent publication, NATURAL HISTORY OF WIREGRASS
(Aristida stricta, MICHX, GRAMINEAE). In a letter to me dated March 27,
1989, Dr Clewell states "At present, there is no technology available to
restore wiregrass and its botanical compatriots of the longleaf pineland
undergrowth. — Until that time comes, I doubt that we have an economical
shot at retoring the caraiunity." Clearly, the ecosystem restoration
objective, while laudable, has little basis in reality.

Using this pie-in-the-sky vision of eco-restoration as a justification for
blocking research into Global Wanning mitigation becomes even more
questionable when we consider the ecological consequences of Global Wanning
itself. The following abstract of a presentation made at the April 19-10
synposium "Forests in a Changing World" at Gainesville, Florida is one
scenario for Florida's eco-future.

IMPACTS OF GLOBAL WARMING ON BIODIVERSITY

Stephen R. Humphrey
Curator in Ecology
Florida Museum of Natural History
University of Florida
Gainesville FL 32611

ir oceanic and atmospheric scientists are correct, global warming will make
Florida warmer, wetter, and smaller, at rates of change much higher than in past ice
ages. Biotic communities will dissociate and form anew as species redistribute. Range
limits will shift from Florida to the Piedmont or beyond. Saltmarsh will be vastly
reduced; mangrove and tropical hardwoods will expand. Much of the Keys and
coastal basins with little sediment will go under water. Interior wetland habitats will
get wetter and displace one another upslope. Most animals' ranges will shift, but some
plants will colonize too slowly to avoid extinction. Preserve-bound species unable to
cross cultural landscapes will raise extinction rates far above recent levels. The scale
of change will force redefinition of conservation and use of natuinl resources. Pre-
emptive preserve design will fail because preserves will be too small for most species.
Preserves will be used primarily for introduction of species that might have moved if
they could have. New regimes of agriculture will have to be devised by matching
future conditions with the ecological capabilities of species not present on-site today.

The restricting of access on .2* of the Apalachicola National Forest, which
is cited as a "major concern", appears to be a modest sacrifice in view of
the stakes involved.

5-44

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The Council for Environmental Quality and your own agency, the US EPA, has
identified Global Climate Change as an environmental issue needing more
attention by Pederal Agencies in preparing EISs. The "bianass research"
alternative relates to the Global warming Issue in 3 ways. First, through
the quantifiable high volume sequestration of carbon in a rapidly growing
energy plantation (as opposed to the low volume sequestration in
non-intensively managed stands on the lor-productivity sites involved in this
proposal). Second, through the real and quantifiable reduction in carbon
emissions which will occur through the production of renewable fuels as a
replacement for fossil fuels. Finally, and most jjiportantly, the
non-quantifiable but vital contributions which this research and
demonstration project can make towards world knowledge and use of non-fossil
fuel energy sources.

You are required by law and rule to rigorously explore and objectively
evaluate alternatives. I request that, as part of your decision making
rationale, you specify, quantify and evaluate these 3 inpacts for the
•effluent to energy" (biomass research) alternative vis-a-vis other
alternatives.

You may wish to consider recanmending the use of either the east or the west
Forest Service sites, but not both. 1*118 would reduce the Forest Service net
acreage from 1,000 acres to 500 acres, enough to support an adequate research
effort. This reduction in size, together with the mitigating measures
suggested in the original alternative, should make this proposal acceptable
to moderates on all sides of the issue.

cc City CcouLssioners

City of Tallahassee, Water and Sewer
U.S. Forest Service, N.Fs in Florida
Qiief, U.S. Forest Service

• 		a

rvicoc

USEPA Office of Policy, Planning and Evaluate
USDOE Office of Policy, Planning and Analysis

Dept.

Evaluation
Analysis

Hiss. Forestry Ccramission
Florida Forestry Association
National Wood Energy Association

DUE (UBK Kiage x	/«•«*

Southeastern Region Biomass Ene^	t

Dr. Andre Clewell

5-45

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THE EFFLUENT TO ENERGY ALTERNATIVE

A CONCEPT PROPOSAL
FOR

DEVELOPMENT OF AN ENERGY FARM
USING EFFLUENT FROM THE TALLAHASSEE WASTEWATER TREATMENT SYSTEM

INTRODUCTION

Hie US Environmental Protection Agency (USEPA) is preparing an Environmental
Impact Statement (EIS) Supplement covering the proposed expansion of the City
of Tallahassee's wastewater management system. A preliminary document, the
Alternatives Report, transmitted by letter from EPA dated July 17, 1989,
identifies 9 system alternatives which involve various combinations of
wastewater conveyance, treatment, effluent conveyance and disposal. The
discussion that follows explores the "Effluent to Energy" alternative, a
specification and refinement of Alternative SS5 (Southwest Forest Spray
Irrigation) shown on page D-ll of that report. In this alternative, 5.0 MGD of
effluent from the T.P. Smith plant is used for forest spray irrigation on land
now owned by the U.S. Forest Service and located south and west of the plant.
In the energy production mode, as discussed below, the effluent is used to
irrigate and fertilize hardwood trees grown under intensive management for
energy purposes. EPA reviewers should note that the design and management
measures suggested below for this system do not coincide with those shown under
D-l, Page C-8 of the Alternatives Report.

"Energy-wood Production Using Sewage Effluent: A Wastewater Management Option
for Florida" (attached) outlines the principles of, and rationale for, such
use. The following discussion considers The application of these principles to
the Tallahassee situation as conditioned by managerial and environmental
considerations. It suggests action which is responsive to immediate community
needs and current environmental interests. More inportantly, it responds to
long-term societal needs and to emerging issues that are of national and global
concern. The most important of these issues (global warming and fossil fuel
depletion) were not considered in the screening process used to evaluate
alternatives in Table D-2 of the Alternatives Report.

THE PROPOSAL

The Effluent to Energy alternative proposes that the U.S. Forest Service, in
cooperation with the City of Tallahassee install and manage an operational
energy-wood farm irrigated and fertilized with sewage effluent. The farm will
serve as a research/demonstration/education center focussing on the
environmentally sound production of effluent-based woody energy biamass as a
part of a larger multi-resource management system.

The principal features of this system will be:

AREA

1. A gross areas of about 2300 acres, with about 800 - 1000 acres under
intensive energy production.

PIANNING AND OPERATION

1. To insure a high level of environmental coordination, overall planning
for the project will be acconplished by an interdisciplinary team which
will include an ecologist, an engineer and a forester. Other specialists
(e.g. wildlife biologist, hydrologist, landscape architect, soil
scientist) will contribute as reauired.

5-46

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2.	To insure management continuity and expertise, maintain proper program
direction and control and to increase the probability of funding, all land
will remain in Forest Service ownership. Land and resource management
will be by the Forest Service. Effluent delivery and management
(including water quality monitoring and EPA and Florida Department of
Environmental Regulation compliance) will be by the City of Tallahassee.

3.	The research effort will be under the overall direction of the USDA
Southeastern Forest Experiment Station. Hie goal will be to participate
fully with interested educational, governmental and industrial agencies in
R&D projects concerned with biomass management and energy production,
resource coordination, water and effluent management, and related matters.

4.	The environmental community will participate in planning this project
and in the the conception and design of programs for research and
management.

RESOURCE COORDINATION

1.	All lands currently in longleaf pine will be retained in longleaf pine.
Only lands now occupied by off-site slash pine plantations will be

managed for energy-wood production.

2.	As part of the multi-resource management program, all undisturbed lands
within the project and suitable to long-leaf pine production will be
restored to that forest type.

3.	Lands adjacent to water bodies, or in hanrnock hardwoods or in southern
scrub oaks needed for wild-life or other resource coordination will be
retained and managed for the the appropriate resource.

4.	Appropriate mitigation measures will be taken to minimized adverse
impacts on threatened and endangered species.

5.	The effluent distribution system and plantation management will be
adapted to the existing topography. No modification of the present land
form will be needed.

6.	To protect property values, effluent will not be applied within 1000
feet of private land.

An examination of F.S. records and a preliminary field examination of the

candidate areas indicate that the area	° ?o

condition classes and vegetation cover lend themselves well to the resource

coordination strategy described above.

ANALYSIS

inters including soil suitability, location and ^t^^in^nMthe

choice of an effluent dispel site.	n* c^re

factors play a major role in the a^ision.	deals with

alternatives nor does it	wlth attention to 'how well that

aUernat^r^^S/cert^^nviSl a* social issue..

«. suggest the folding set of tissues. ^'VtWe^
SSSSSi	issue we diso.ss hew well the Effluent to

Energy alternative responds to that iss""

5-47

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LONG TERM/MAJOR
GLOBAL

-	Global wanning, the world carbon budget

-	Energy management/ fossil fuel depletion

The Feb. 1989 EPA draft report to congress "Policy
Options for Stabilizing Global Climate" outlined the
changes in world climate which are exected in the
absence of drastic modification of our energy use
habits and of our management of the global ecosystem.
Hi is issue is emerging as the over-riding environmental
concern of the next century. The EPA projects that a
major component of clinate stabilization will be the
establishment of 380 million hectares of energy-
biomass plantations worldwide. The report points out
the critical need for research in non-fossil fuel
technology including technologies for producing and
utilizing biomass.

The alternative responds directly to the research needs highlighted in the
EPA report. Additionally, the 18,000 tons of energy-wood produced
annually by the project will replace approximately 19,000 barrels of oil
and reduce annual carbon emssions by 2,000 tons (Marland, 1989).

REGIONAL

-	Air and Water quality considerations (acid rain,
ground and surfacewater protection).

-	Waste reclamation and re-use.

Wood fuel produces little NQx and SOx emissions and particulate emission
is readily controlled by current technology (Fl. DER 1981). While an
intermittant odor problem occurs at the treatment plant, no such problem
has been reported at the existing effluent field on Tram Road. Nearly 20
years of effluent application at the existing Tallahassee effluent field,
which uses field crops and grasses on similar soils, has produced no
change in groundwater except a slight increase in nitrate and chloride
concentrations (Dean, 1989). The expected higher nutrient uptake rate of
trees as ccnpared with grasses and crops, coupled with the lower
application rates, should reduce even this minor inpact. Surfacewater
protection will be provided by lake side zoning.

LOCAL

-	Endangered species habitat, the longleaf-wiregrass community

-	Life quality of local residents

-	Soil fertility

-	Ecosystem diversity

The project will result in the loss of 1,000 acres of dry sand-hill soil,
potential habitat for the gopher tortoise (a species of concern) and
indigo snake (threatened). The present population of these species within
the slash pine plantations scheduled for management is not known. About
42,000 acres of sand-hills occur within the Apalachicola N.F. (Soil
Survey, A.N.F.) and several million acres occur in the southeastern U.S.
No other threatened or endangered species are known to occur within the
area to be intensively managed.

As a part of the total resource management proposed for this area the
existing potential longleaf sites will be restored to productivity and the
feasibility of increasing the wiregrass ccnconent will be determined.

5-48

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Life quality of local inhabitats will be protected by application
restrictions near private land.

The areas proposed for intensive management on this high stress xeric site
have been drastically modified by past management and are of low
productivity for both consunptive and non-consunptive uses. The suggested
use, along with the restorative management proposed for the
non-intensively managed areas, will greatly increase the effective soil
fertility, site productivity and bio-diversity of the tract.

SHORT TERM/MINOR

-	Inpact on local economy and employment

Impacts on production of conventional forest pro-
ducts, esthetics, consumptive and non-consunptive
non-threatened wildlife, recreational and cultural
values.

-	Effect on local private property values.

Because of low soil fertility the project area has low productivity for
all resources and makes minimal contribution to the local economy, ifae
increased wood production from restored longleaf sites, project generated
enployment and increased biodiversity will result in substantial increase
in the production of- all resources.

With the restricted area of application the project will have no inpact on
private property values.

CONCLUSIONS

B» project, conbining as it does wastewater renovation with short rotation
intensive culture management, will have applicationthroughout Florida, the
southeast and nationwide. As populations grow and emrironrental awareness
increases, there will be fewer and fewer "out-of-sight" places to receive
society's waste. The social and political problems which Tallahassee has
experienced with respect to effluent disposal are being repeated again and
again in other areasV Ttiis project will suggest ways to avoid these problems

in the future.

	. nrrmcai responds to the issues which have

The action suggested in this concept p cpo alternative offers high long-term

been raised in the public he"^s* areatest value, of course, lies in its

social and erwirorron^l benefits .it	demonstration and education, to

potential for contributing, ^^iiLte stabilization and the production and
the store of information regarding climate swux

August 07, 1989
W.V. McConnell

Land Management Planner/Forester
1023 San Luis Road
Tallahassee, Florida 32304
(904) 576-7774

4 5-49

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REFERENCES

Dean, John M. 1989, Supt. Division of Wastewater Operation
City of Tallahassee. Discussion with W.V. McConnell.
August 7, 1989

Florida Department of Environmental Regulation. 1981. Some
Environmental Considerations for Biomass Energy Produc-
tion in Florida: Constraints, Opportunities and Recom-
mendations for Research. A discussion paper for the
March 31, 1981 meeting of the Biomass Advisory Council
Orlando Florida. Tallahassee FL.

Marland, Gregg. 1988., Personal communication dated
Oct. 21, 1988.Environmental Sciences Division, Oak
Ridge National Laboratory, Oak Ridge, TN.

McConnell, W.V. 1989 (Rev.) Energy-Wood Production Using
Sewage Effluent: A Wastewater Management Option for
Florida. Unpublished manuscript. Tallahassee, Fl.

US Environmental Protection Agency, 1989. Environmental
Impact Statement Supplement, Tallahassee-Leon County
Wastewater Management, Tallahassee, Leon County, Fl.
Task Series 500, Alternatives Development and Evalua-
tion. USEPA, Region IV, Atlanta, Ga.

US. Environmental Protection	Agency, 1989. Policy Options

for Stabilizing Global	Climate, Draft Report to

Congress. USEPA Office	of Policy, Planning and

Evaluation. Washington DC.

5-30

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THE VOICE OF FORESTRY

f>20 NORTH STATE STREET
JACKSON MISSISSIPPI 39202-JJ98
iftOI i .1 Si

August 18, 1989

Dr. Cory W. Berish
Project Monitor
Environmental Policy Section
Environmental Protection Agency
345 Courtland Street, N.E.

Atlanta, Georgia 30365

Dear Dr. Berish:

As a former resident of Tallahassee,- Florida, from 1983 to
1988, and a national forest recreational user, I am pleased
to support the proposal for an energy wood farm irrigated with
sewage effluent. As a demonstration, such a project would
be very useful to many small cities in the southeastern United
Statets which are seeking low-energy and less expensive alternatives
to conventional sewage treatment. The results would certainly
be useful to communities in Mississippi.

The energy wood component is especially exciting because of
the proximity ol the site to the Arvah B. Hopkins Generating
Station, a city utility power plant which is scheduled to convert
to coal! This proposed fluidized bed facility may receive
funds from the Federal Clean Coal Technology Program. If the
coal conversion goes forward, the city would still be able
^	to demonstrate lis commitment to global warming mitigation

fr* by burning a few megawatts of wood in the same facility. The

hauling distance for wood chips from the energy farm to the
©	ffpnpnHnir <-tation would be five miles or less. Even if the

H Hopkins station did not become an option for the wood fuel,
r/*-	other good energy wood markets curre y

Panhandle.

5)	5ervice°t^demonstrate°its conoitment°toUreducing the problem

of global warming. Short rotation	"'uSr"0"''

to store anJ r?h.^le»Sery megawatt of renewable energy used
32 programs. Father, every	pr0Vi
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August 18, 1989
Page Two

It should be pointed out that energy wood harvesting is already
occurring in conjunction with conventional timber harvests
on the Apalachicola National Forest. Intensive management
of a little more than a square mile of land would have minimal
impact on a portion of the national forest that is already
disturbed by a busy airport and existing sewage irrigation
of agricultural crops on adjacent lands.

The energy wood plantations would replace slash pine plantations
which are not appropriate for the sand hill topography of this
area. The appropriate plant community for this area would
have been a longleaf pine-wiregrass association; however site
preparation for the slash pine destroyed the wiregrass and
it would be difficult to restore the natural plant community.

Thus, energy wood plantations are an ideal opportunity to restore
theye national forest lands to a productive use while meeting
the needs of society for waste-treatment, energy production,
global environmental protection, wildlife habitat, and open
space.

I strongly support this proposal and hope that it can be implemented
soon.

Sincerelv .

Harold M. Draper, D.Sc.
Biomass Energy Coordinator
(601) 961-4733

copy: Grey F. Reynolds

5-52

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*

FLOR
FORES
ASSOCIAT ON

DA
FY

402 EAST JEFFERSON STREET • P.O. BOX 1696 • TALLAHASSEE, FLORIDA 32302-1696 . (904)222-5646
H. Wyndell Sapp. President	Wm. Carroll Lamb. Executive Vice President

October 3, 1989

Dr. Cory w. Berish
Environmental Policy Section
U. S. EPA Region IV
345 Courtland Street, N. E.

Atlanta, Georgia 30365

Dear Dr. Berish:

This letter is to endorse the "effluent to enerav" stra«-or,„ u
W. V. McConnell has proposed for the disposal field of th#
Tallahassee sewa9e system. The Florid. forl.try
represents the forest industries and forest l.ndow"« " oCr
Private commercial forestland comprises 3(t of the total l»na Irl. I
Florida and 83* of the total commercial forest a«ea|S?	" ln

The Association endorses this proposal for a number of reasons
The principal one is the realisation that the replacement of w??.'
fuels with renewables will be of vital important to an? national
policy of climate stabilisation. We foresee the information
by the proposed research and demonstration area will havj very
®o?ld	lon9-t«» benefits for the nation, and indeed, f« the

Also, we suggest the concept be expanded to include
non-effluent-based energy-wood production, a southeastern reoional
energy-wood research and development center, under the spon^o?ihin of
the U. S. Forest Service using National Forest land, could provide the
setting for vital on-going research. The research, combined with
operational testing, could bring energy-wood production onto
commercial forest lands of the South as well.

We understand the U. S. Forest Service is now in the process of
formulating an energy policy for National Forest lands. Forest
industry has a keen interest in this policy and we would be pleased to
offer comments on it a. it is developed. \ copj of Shi. lett"!

™l"r£ard? * F0"" S"VlC* t0 U*P "	on their	ln

5-53

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Dr. Cory W. Berish
October 2, 1989
Page Two

Certainly, the proposed "effluent to energy" research farm would
be a logical early Stepin the 0. S. Forest Service s move towards
providing leadership in energy wood research and, ultimately,
providing its share of the nation's renewable fuels.

WCLsmlj

ccs Grey F. Reynolds, USFS
Dave Rinebolt, NWEA

be: Bob Jacobs, USFS, Tallahassee
W. V. "Mac" McConnell

Sincerely

Wm. Carroll Lamb, CAE
Executive Vice President

5-54

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NATIONAL WOOD ENERGY ASSOCIATION

Suit* 610 • 1730 North Lynn Street • Arlington, VA 22209-2009 • (703)524-81
August 21, 1989

Dr. Cory W. Berish
Project Monitor
Environmental Policy Section
U.S. EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365

Dear Dr. Berish:

I am writing on behalf of the National Wood Energy
Association to endorse the proposal of Mr. W.V. McConnell to
establish a Tallahassee Energy Farm which would demonstrate the
use of sewage effluent to irrigate and fertilize intensively
cultivated hardwood trees for energy purposes.

The National Hood Energy Association is the national
trade association for the commercial/industrial wood energy
industry. Our members include developers, equipment
manufacturers, foresters, engineers, woodlot owners and other
involved in the production of energy from biomass resources.

NWEA believes that the proposal advanced by Mr. McConnell
is worth developing and funding for a variety of reasons. The
first pressing need is to demonstrate and conduct additional
research on the disposal of effluent by using it as fertilizer
and irrigation agent for intensively cultivated hardwood trees.
Effluent disposal has been and will continue to bt a major issue
issue. Previous research has indicated the positive benefits of
using effluent in conjunction with the production of short
rotation trees. NWEA believes that a project such as this would
demonstrate the environmental benefits of this disposal option.

A second justification involves the ongoing research on
short rotation forestry. This type of forestry involves the
intensive management of highly productive, aonocultural timber
stands. This type of forestry is being developed by both the
U.S. Department of Bnergy and the USDA Forest Service. While
the end product can be used for wood pulp or other traditional
end uses, the focus of current research is on the production of
wood biomass for energy purposes. The primary advantages of
using wood fuel are the eliaination of S02 emissions, the
limitation of NOX emissions and the mitigation of C02 emissions
through producing energy feedstocks on a sustainable yield
basis.

One of the issues involved in short rotation forestry is
providing sufficient nutrient levels for intensive growth.

Sewage effluent shows tremendous promise as a nutrient source.

"Wood Energy"

Th« Renewable Alternative

5-55

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August 21, 1989
Page 2

Thus, Mr. McConnell's proposal offees a *twofer' - a
demonstration of a technique to dispose of effluent and a
demonstration of the impact of sewage effluent as a fertilizer
for short rotation stands. Since both U.S.EPA and U.S. DOB are
looking at short rotation woody biomass as a replacement for
environmentally damaging fossil fuels, this proposal is
consistent with research efforts at both agencies. The
emergence of concerns over global warming should serve to
underline the appropriateness of this project.

NWEA offers its unqualified support for the Tallahassee
Energy Farm proposal. If we can provide any additional
information please feel free to contact our office. NWEA would
be happy to do anything possible to facilitate this
research/demonstration project.

encl

cc: Grey Reynolds/USFS
Earle Gavett/USOA
John Ferrell/USDOB
Rep. Bill Grant
Sen. Bob Graham
Sen. Connie Mack

David C. Rinebolt
Director of Research

5-56

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OAK RIDGE NATIONAL LABORATORY

OPfRATtD av MARTIN MARIETTA ENCWOV SYSTEMS. INC

Cory W. Bcrish, Ph.D.

Project Monitor
Environmental Policy Section
U.S. EPA, Region IV
345 Courtland St., N.E
Atlanta, Georgia 30365

Dear Dr. Berish:

I am writing this letter in regard to the proposal recently submitted to you by W. V. McConnell
of Tallahassee, Florida. His proposal that the U.S. Forest Service and the city of Tallahassee
install and manage an operational energy-wood farm irrigated and fertilized with sewage effluent
addresses a significant topic that needs more attention. I wish to comment on the concepts of
the proposal only. Soil scientists and foresters in the Tallahassee regions should be consulted
on specific aspects of the proposal such as whether the site proposed is suitable.

The technology of short-rotation intensive culture of hardwood trees has advanced sufficiently to
assure that wood energy plantations can be successful with appropriate application of the
technology. But under conditions of low fossil fuel costs, short rotation woody crop plantations
are not likely to be established by the private sector unless multiple market opportunities or
incentives are present to reduce risks. The environmental and economic advantages potentially
offered by disposing of wastewater effluents on land that is also producing wood for energy
appears to have the necessary elements to attract private sector investment. This is
demonstrated by the fact that several municipalities along the eastern coast of the United States
have expressed interest in establishing short-rotation trees in sewage effluent fields. However,
in most cases the municipalities are looking for government funding to support the projects.
The establishment of one or two large demonstration sites of the type proposed by McConnell
could go a long way towards demonstrating that wastewater application to short-rotation
plantations is economically and environmentally viable.

Previous research funded or co-funded by the Short Rotation Woody Crops Program and other
research agencies has indicated the positive benefits to tree growth of applying wastewater to
short-rotation plantation. Results after one year of application of wastewater on a sycamore
and sweetgum plantation in Edenton, North Carolina, appear to be quite positive. But, to my
knowledge, guidelines have not been developed for optimizing wastewater applications to
maximize tree growth while ensuring that surface runoff or nitrate leaching to groundwaters
does not occur. Thus a research component to the project would be necessary. The proposal
recognizes this by its recommendation of the diverse team of specialists that would be required
for implementation of the project and by including the USDA Forest Service as the coordinator
of the research effort

To meet the goal of the project as a "research/demonstration/education center focusing on the
environmentally sound production of effluent-based woody energy biomass," it must be managed
such that protection of the environmental integrity of the area is given highest priority. The
proposer appears to recognize this.

POST OFFICE BOX 2000

OAK RIDGE. TENNESSEE 3783V63S2

September 7, 1989

5-57

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Cory W. Berish

2

September 7, 1989

The size of the project is much larger than is needed for research or demonstration purposes
alone. It is not clear whether the size is dictated by the land area needed by the city of
Tallahassee for wastewater treatment or by the size of a planned market for the wood. The
project would certainly have greater value if an energy market for the wood were available. If
the site is established as a short-rotation plantation, the trees must be harvested at appropriate
intervals to maintain the vitality and high nutrient uptake capability of the stand. Failure to use
this wood for production of energy would reduce the positive "global" benefits of this project.

The projected annual tonnage of energy wood projected to be produced (18,000) is extremely
optimistic if that is to be produced on the 800 to 1000 acres under intensive culture. An
exciting aspect of this type of project, however, is that such wood production yields might be
obtainable since wastewater effluent application can provide an optimum growth environment.
However, best available plant materials and intensive culture techniques would need to be used
to attain such high yields even with the fertilization benefits offered by the wastewater.

The Department of Energy's Short Rotation Woody Crops Program (SRWCP) recognizes the
need for gaining a greater understanding of how to optimally manage short-rotation plantations
that are irrigated and fertilized with sewage effluents. It is not the mission of the SRWCP to
support demonstration trials, thus any interest the program might have in this specific project
would be limited strictly to research components of the project Requests for proposals in this
general area might be issued in 1991 or 1992 if programmatic funding levels are increased by
more than double over present funding levels. Other higher program priorities, such as genetic
improvement of hardwood trees for higher yields and pest resistance prohibit our initiation of
work in this area at current funding levels.

In summary, I believe that the concept of establishing a large short-rotation woody crop
plantation using sewage effluent for irrigation and fertilization for demonstration purposes has
considerable merit Such a project requires great sensitivity to environmental issues which the
proposal appears to reflect The project would require a research component to ensure that
best procedures are followed for protecting the environment as well as to determine optimum
management for growing the wood. Such a research component might address a research need
recognized by DOE's Short Rotation Woody Crops Program which the program is currently
unable to support. I recommend that the Environmental Protection Agency seriously consider
this proposal provided that local experts and the USDA Forest Service agree that the site
proposed is suitable.

LLW:plh

cc: J. E. Ferrell, USDOE-SRWCP Manager
W. V. McConnell, Land Management Planner
Grey F. Reynolds, USDA Forest Service

5-58

Sincerely.

Lynn ll Wright, Field Manager
Short Rotation Woody Crops Program
615/574-7378 (FTS 624-7378)

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NFDC

TcnntoM Vallay Authority
National Fertilizer Development Cnntrr

Muscl* Shoals, Alabama 35660
(205) 386-2601
Tain No. 797658

August 28, 1989

Dr. Copy W. Berlsh
Project Monitor
Environmental Policy Section
U.S. SPA, Region IV
345 Courtland St., NS.

Atlanta, Georgia 30365

Dear Dr. Berlsh:

The purpose of this letter Is to voice my personal support for the
"Development of an Energy Parm Using Effluent froa the Tallahassee
Wastewater Treatment System" as proposed by W. V. McConnell of
Tallahassee, Plorlda, at the SPA Tallahassee public hearing on August 15,
1989. My current position is manager of the DOB Southeastern Regional
Biomass Energy Program (SSRBBP). SSRBBP covers 13 States in the
Southeast, including Plorlda.

The proposed project touches on several important issues facing our
Nation and local communities Including protection of water quality and
waste disposal. The proposed technology would not only demonstrate a
technology with numerous environmental benefits, but also through the
associated research, refine and add to the body of available technical
knowledge on these systems. Demonstration and more experience would
expedite the application and use of this beneficial technology. The net
result would thus not only benefit the citizens of Tallahassee, but
Improve the quality of life of citizens throughout our Nation.

Part of the new Porest Service energy plan is to promote the use of
National Porests for wood fuel purposes. There are presently several
markets for wood fuel in the region. The city of Tallahassee is
currently negotiating with DOI for a "Clean Coal Technology" grant to
replace its 250 MV electric oil and gas fired power plant with a
coal-fired boiler. Vood fuel could be used to supplement the coal and
reduce acid emissions. The use of wood fuels, by virtue of carbon
recycling, would also reduce atmospheric buildup of C02 and hence reduce
the greenhouse effect. Other wood fuel user* such as Proctor & Gamble at
Perry; St. Joe Paper Co. at Port St. Joe; and the Panama City Resource
Management Center; are in the vicinity. Because of its numerous
environmental and economic advantages, the use of wood fuels will
continue to grow in the future.

5-59

An Equal Opportunity Employ*

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2

Dr. Cory W. Berish
August 28, 1989

In sunsnary, the project is well planned and provides an excellent
opportunity to EPA and the USPS to serve the citizens and taxpayers of
this country. There are times when government must take the lead in
technology development. I believe the project is one such example and
believe any publicity would be positive and beneficial to EPA and the
USPS.

Because of this belief, we will support this project in any way possible
and encourage you to do likewise.

Please let us know if we can provide you additional Information or assist
you In any way with this project.

Sincerely,

Phillip C. Badger, Manager
Southeastern Regional Biomass
Bnergy Program

cc: Dr. Gray P. Reynolds
Porest Service - USDA
V3A, Room 1210 RDR
P.O. Box 96090
Washington, D.C. 20090-6090

Mr. W. V. McConnell
Land Management Planner/Porester
1023 San Luis Road
Tallahassee, Plorida 32304

5-60

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UNIVERSITY OF FLORIDA

INSTITUTE OF FOOD AND AGRICULTURAL SCIENCES

GAINESVILLE rtOfliOA 326M

m 'OA llOMAll IMCROT
• VILOINO 401

TIWIMONIi •	1

IUNCOM. l/ltl'tl« I
f Afli IO4/1IH0II

August 21, 1989

Dr. Cory W. Berish
Project Monitor
Environmental Policy Section
US EPA, Region IV
345 Courtland St., NE
Atlanta, GA 30365

Dear Dr. Berish:

I have reviewed the proposal "The Effluent to Energy Alternative" for Tallahassee,
Florida prepared by W.V. McConnell. This is to indicate that I believe this to be a
sound concept whose time for application has arrived. There are so many benefits to
the proposed project that it has to be considered seriously.

Because I did the early work on effluent irrigation in Tallahassee that showed the
responsiveness of hardwoods to effluent; have performed research since then on energy
wood plantations; and managed a comprehensive bioenergy program, I recognize the
technical feasibility of the project. As an environmentally concerned citizen, I also
recognize that the project is an environmentally benign way of dealing with serious
pollutants.

My only criticism of the proposal is that it did not go far enough. It would be more
comprehensive if landspreading of composted waste in forest sites were also included.
Many believe composting yard trash, if not all the biologically degradable fraction of
MSW, is the method of choice for solid organic waste reduction and landspreading on
forest sites as the most acceptable terminal recycling step. There is evidence for this in
the enclosed paper recently accepted for publication in the Journal of Environmental
Quality. While this dimension was not included I see no reason why the concept could
not be expanded to include this option also.

5-61

COLLIOI Of AGRICULTURE	AGRICULTURAL EXPERIMENT STATION	COOPERATIVE EXTENSION SERVICE

SCHOOL Or FOREST RESOURCES ANO CONSERVATION	CENTER fOR TROPICAL AGRICULTURE

T1* Inatltuta of F*od and Agricultural SctoMM to •« Cqual Opportunity • Affirmaitv* Action Employer authorltad to provtt* rataarefc. educational
Information 0*4 otfcar tarvioa* only to MkrMuali and inttitutiont that function without ratard to rsca, color, mx, or national ortfin.

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August 21, 1989
Page 2

As Director of the Biomass Center and Coordinator of this institute's solid waste
program, I would be pleased to cooperate with the US Forest Service, EPA, and others
dedicated to supporting this project and making it successful.

Wayne H. Smith
Director and Professor

WHS:LS8\Berish

Enclosure: Growth and Elemental Content of Slash Pine 16 Years After Treatment
With Garbage Composted With Sewage Sludge.

Sincerely,

5-62

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A.F. Clewell, Inc.

Botany, Ecology, Wetland Science, Vegetational Restoration

1447 Tallevast Road
Sarasota, Florida 34243
(813) 355-5065

September 24, 1989

Dr. Cory W. Berish

U.S. Environmental Protection Agency
34 5 Courtland Street, N.E.

Atlanta, GA 30365

RE: W.V. McConnell Proposal: Energy Farm Using Effluent

From The Tallahassee Wastewater Treatment System

Dear Dr. Berish:

I have reviewed a copy of this proposal. I understand
that it was formally presented at a public hearing in
Tallahassee on August 15 and that you are the Project
Monitor.

I would like to point out two features in favor of this
proposal. First, it is my understanding that hardwoods are
far more efficient than grasses and rowcrops for removing
nutrients from wastewater in land spreading facilities.
Herbaceous cover has two other drawbacks, relative to tree
cover: Municipalities sometimes have difficulty harvesting
and disposing of herbaceous material, and frequent
harvesting compacts the soil to the point that infiltration
is poor. My source of information was the Hardwood Research
Cooperative at N.C. State University, Raleigh. You could
call Dr. Russ Lea for more details at 919-737-3674.

Second, effluent from Tallahassee's waste treatment
facilities is presently polluting Lake Munson with excessive
nutrients. There is reasonably good evidence that
groundwater discharge from the lake is causing
eutrophication in aquifers and springs, which are part of
the Wakulla Springs system. If McConnell's proposal
alleviates that problem, it would be well worth
implementation.

I am not ecstatic about the prospect of dumping
effluent in national forests. Nonetheless, McConnell#s
proposal carefully specifies the use of lands that have
already been ruined ecologically by tree farming. Further,
he proposes the restoration of certain lands to their
original cover of longleaf pine—a definite plus.

I urge you to consider carefully the points I have
raised with regard to nutrient uptake efficiency and the

5-63

Vegetational Restoration and Management —

The New Environmental Agenda

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Dr. C. W. Berish
September 24, 1989
Page 2

potential benefit to the Lake Munson system. If indeed my
contentions are upheld, EPA and other interested agencies
should seriously consider issuing permits for this project.

COPY: G. F. Reynolds

U.S. Forest Service

P.S.: I authored the 1971 report, THE VEGETATION OF THE
APALACHICOLA NATIONAL FOREST, AN ECOLOGICAL PERSPECTIVE.

Sincerely

Andre F. Clewell, Ph.D

5-64

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Natural Areas
Journal

Rare Vascular Plant Taxa Associated
with Wiregrass

Natural History of Wiregrass

Is It Wiregrass?

Longleaf Pine Communities of the
West Gulf Coastal Plain

- " " - -

Volume 9, Number 4

October 1989

A QUARTERLY PUBLICATION OF 'l	NATURAL AREAS ASSOCIATION

5-65

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•

Natural History of
Wiregrass (Aristida
stricta Michx.,
Gramineae)

•

Andre F. Clewell

A. F. Clewell, Inc.
1447 Ttllevpsi Road
Sarasota, Florida 34243



ABSTRACT: Wiregrass (Aristida striciu) is the principal fuel for the frequent Circs liiai
arc necessary to maintain longleaf pinelands, slash pine llatwoods, and associated bogs
in much of the Adantic Coastal Plain. Wiregrass regulates the structure and floristic
composition of these ecosystems, largely through its propensity to carry fires.
Wiregrass has an exceptionally low reproductive capacity, and common land
management practices that destroy wiregrass are threatening the integrity of wiregrass
ecosystems. The life history wiregrass is presented, along with characterizations of its
vegetative condition, population structure, and habitats.

INTRODUCTION

It was Bob Godfrey who told me that
wiregrass did not reproduce. That was
back in 1962, just after I had moved to
Florida. I had been in the field long
enough to know ihat wiregrass was
exceedingly abundant on the Atlantic
Coastal Plain. In those days Bob had
already begun to acquire his reputation as
the "dean" of southeastern botanists, and
I was not about to dismiss his curious
observation about wiregrass. From that
point on. 1 became a "wiregrass watcher."
This article reveals my botanical love
atfair with this paradoxical species.

I have learned that wherever it occurs,'
wiregrass regulates the natural fire
regime. In doing so, wiregrass deter-
mines species composition and thus the
type of plant community in which it
grows. In this article I will attempt to
describe why wiregrass is such a pivotal
species and will discuss the extent and
consequences of its decline in response to
recent land use activities. In spile of in
importance, wiregrass has been largely
ignored as a focus of ecological study.
Much of the pertinent literature comes
from older papers, and most of our aute-
cological knowledge of the species
resides in an admirable but unpublished
master's thesis by Roger Parrou (1967).
To a large extent, this article pulls
together the scattered story of wiregrass,
bused on extant literature and personal
observations.

RANGK AND HABITATS

Wiregrass, Aristida stricta Michx.,
occurs on the Atlantic Coastal Plain from
southeastern North Carolina to the edge
of the Florida Everglades and westward

through ihc Florida panhandle, Georgia,
southern Alabama, and coastal Missis-
sippi. Within this geographic range, wire-
grass is the predominant herbaceous
cover in longleaf pinelands (Pinus pains-
iris), in nearly all slash pine flatwoods
(Pinus cltioiiii), and in many grass-sedge
and pitcher plant bogs. Wiregrass grows
from die driest sandhills, where it is asso-
ciated with turkey oak (Quereus laevis),
to bogs that arc seasonally wet. Wiregrass
habitats arc characterized by relatively
infertile sands and sandy loams, in which
nitrogen and phosphorous arc particu-
larly deficient. Infiltration and percola-
tion of rain water is generally rapid,
except in seasons when the water table
approaches the soil surface. Surface fires
arc frequent and occur with regularity,
perhaps every two to four years, as will
be discussed later. Wiregrass habitats arc
extraordinarily rich florisiically and con-
tain numerous species of low-growing
herbs and shrubs (Walker and Pcct 1983,
Clewell 1986).

NOMENCLATURE

The vernacular name, wiregrass, is occa-
sionally applied to two other grasses that
resemble Aristida stricta in vegetative
aspect and that sometimes grow with it,
though generally at a much lower density.
These grasses arc Sporobolus junceus
and Muhlenbcrgia capiltaris (¦ M. ex-
pansa). An alternate common name lor
Aristida stricta, pineland three-awn, is
used, particularly in U.S. Forest Service
publications, and distinguishes Aristida
stricta from the other two grasses. In this
paper the name wiregrass applies only to
A. stricta, and all other nomenclature fol-
lows Clewell (1985). The most recent
unonomic treatment of Aristida was pre-
pared by Allrcd (1986).

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HABIT

Wire grass is a cespitose perennial bunch
grass ihat arises from a clump ihai is up to
about 15 cm across at the base (Figure I).
The flat, narrow blades arc strongly invo-
luted, so that ihcy appear to be round in
cross sccuon, resembling fine wire. Hun-
dreds of leaves may arise from a single
plant (clump). The leaves often attain a
length of 0.5 m. The leaves arc sulT but
flexible and arch to the point that the
apices of the longer leaves sometimes
touch the ground. As a result, plants may
be only half as tall as the lengths of their
longer leaves.

The leaves arc highly fibrous. Wells jnd
Shunk (1931) reported that only about 10
percent of the area of a leaf in cross sec-
tion consisted of chlorcnchyinalous
(green) cells and that the rest was sclcr-
cnchyma (fiber). Parrott (1967) reported
that 85 pcKent of the leaves die wuhin 12
months of their formation. Each leaf dies
back progressively from its apex Dead
leaves are not shed immediately but per-
sist within the clump for at least a year or
two and probably longer (Parrott 1967).
The fibrous composition of the leaves,
their abundance, and the persistence of
dead leaves makes the plant highly llam-
mablc. These features also make the plant

unpalatable to grazing animals, except
during the first six weeks or so of new
growth following a fire, while all the
leaves arc still tender, nutritious, and
alive. Wircgrass was found to be less
digcsublc than some other forage grasses
growing with it (Kalmbachcr 1983).

The roots arc wiry and often very dense.
Parrott (1967) said that roots may reach a
depth of 45 cm and that 55 to 60 percent
of ihc root biomass lies within the upper 5
cm of the soil The shallow, dense mat of
roots appears to be cITectivc in absorbing
nutrients, including ihc flush of soluble
nutrients from ash that percolates into the
soil with the first rain following fire.
Wircgrass roots arc generally shallower
than the roots of associated species
(Wells and Shunk 1931) and would have
ihc initial advantage in capturing these
nutrients.

NUTRIKNT SEASONALITY

Carbohydrate reserves in the roots arc
highest in February and lowest in mid-
July (Woods ct al. 1959). Nitrogen and
phosphorous reserves in the roots decline
sharply in September and gradually accu-
mulate thcrcaficr (Woods ct al. 1959,
Satcrson and Vitousck 1984). The distri-
buuon of nutrients and other cellular con-

stituents varies substantially among
roots, leaves, and other plant parts
according to the season (Kalmbachcr
1983), suggesting a well regulated tem-
poral translocation of materials wiihin a
single plant.

SOIL MOISTURE TOLERANCE

Wircgrass tolerates wet soils. During two
years of observations, Parrott (1967)
noted that wircgrass grew in soils in
which the water table was continuously
within 5 cm of the soil surface for up to
114 days. He documented soil moisture
tolerance more precisely in a controlled
environment. He transplanted wircgrass
clumps into an elongated, sloping lank,
so that soil in the lower end was
immersed. Where water remained wiihin
5 cm of the soil surface, all plants died
within 200 days. Where it remained 5 to
13 cm below the surface, some plants
survived. Where the water tabic was
deeper, all plants survived.

Parrott (1967) noted that wircgrass plants
were elevated on tussocks about 10 cm
tall in wet sites. Clcwcll (1971) con-
firmed that tussocks were the typical
growth form in grass-sedge bogs and that
each tussock originated from an accumu-
lation of earthworm casungs that were
deposited in the centers of clumps of
wircgrass. Wircgrass roots growing in
tussocks are presumably well aerated.
Plants of nearly all of the many herba-
ceous species growing in grass-sedge
bogs were rooted along ihc sides of wire-
grass tussocks.

Wircgrass retains its dominance to the
point on clcvational gradients where soils
are too wet for wircgrass to survive. At
that point, wircgrass communities arc
abruptly replaced by grass-sedge bogs
(e.g., pitcher plant bogs and, in south cen-
tral Florida, by "cutthroats" dominated
by Panicum abscissum) or more com-
monly by shrub bogs, often consisting of
species of Cliftonia, Cyrilla. Ilex, Lyonia,
or Nyssa. Fires burn through the wire-
grass to the edge of shrub bogs but arc
unable to carry into them for lack of ade-
quate fuel, except under unusually dry.

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windy conditions. The frequent Tires in
wiregrass communities prevent these
shrubs from colonizing wiregrass
habitats.

POPULATION DENSITY

A remarkable feature of wiregrass is that
it is uniformly dense wherever it grows
without disturbance. Wiregrass density
was determined in 30 1-m* quadrats. Ten
quadrats were in sandhill sites, 10 in flat-
woods sites, and 10 in boggy sites
(Clewell 1986). All sites were recently
burned and kicked evidence of soil distur-
bance. The mean density per square
meter of wiregrass was S.3 clumps in
sandhills, 4.6 clumps in flatwoods, and
4.8 clumps in bogs. The standard errors
for these means were low, respectively
0.S, 0.7, and 1.2. There was no apparent
relationship between wiregrass density
and tree cover at these study sites.

Reconnaissance in numerous stands con-
firmed a density of about five plants/m*
throughout the entire geographic range of
wiregrass. These observations were lim-
ited to those stands that appeared to have
sustained little if any soil disturbance,
that appeared to have a long history of
frequent surface fires, and that contained
few or no dicotyledonous trees, including
those growing as coppice sprouts. Excep-
tions were small oaks that ordinarily
occupy sandhills (e.g., turkey oak. blue-
jack oak [Quercus incana], and sand-post
oak [Q margaretta]).

A departure from the natural fire regime
allows brushy vegetation to mask the
abundant wiregrass. Infrequently burned
or lightly winier-bumed pine flatwoods
become overgrown by shrubs, especially
saw palmetto (Sertnoa rtpens), gallberry
{fits glabra), or fctujrbush (Lyonia
luctda). Production of wiregrass leaves
diminishes, and after a decade or two of
fire suppression, many clumps of wire-
grass become dormant. After winter fire,
the torpid wiregrass clumps rejuvenate
and assume dominance at the expense Of
the top-killed shrubs. The shrubs gradu-
ally coppice-sprout from their roots.
After summer fire, wiregrass not only

recovers, but also many shrubs are
entirely killed, as is being documented by
personnel at Myakka River State Park.
Florida (J. Huffman pcrs. comm.).

A density of about five clumps of wire-
grass per square meter is maintained to
the very edge of its geographic limit of
distribution. For example, it reaches that
limit in the longleaf pinelands of north-
western Escambia County, Florida (near
Pensacola), where other grasses, espe-
cially slender blucsiem (Schiiachyrium
lenerum), abruptly and entirely replace
densely spaced clumps of wiregrass
beneath these pines (Clewell 1986).

"Wiregrass watching" requires an excep-
tionally carclul vigil for traces of past
disturbance. Otherwise investigators may
be lulled into thinking that sites with low
densities or irregular distributions of
wiregrass arc "natural." Such sites con-
sistently reveal subtle signs of past distur-
bance or prolonged fire suppression, such
as unusual combinations of associated
species, hardwood coppice-sprouts, or
slight topographic irregularities caused
by disturbance, such as scars caused by
bushhogging.

Perhaps the biggest variable in determin-
ing wiregrass density is the observer, who
must decide whether a small plant should
be tallied independently or as pan of an
old clump that is in the process of (rag-
mentation, as described below. Point-
interception or point-quancr sampling
relieve the observer from having to make
that decision. These sampling techniques
also obviate the considerable errors
inherent in determining wiregrass abun-
dance on the basis of cover or biomass,
values that vary with recency since the
last fire.

ORIGINAL ABUNDANCE

Throughout its geographic range, wire-
grass is essentially ubiquitous within
longleaf pinelands, slash pine flat -ds,
and associated grass-sedge bogs. U is
often difficult to take a step without
brushing against wiregrass, at least in
relatively undisturbed and frequently

burned "barrens," as these commumues
were called by early naturalists. We arc
fortunate to have large tracts of "pine
barrens" that are preserved in national
forests and other public lands. Virtually
all of the old-growth pines were har-
vested and have been replaced by second-
growth trees, but the original
groundcovcr remains, and it is consis-
tently dominated by wiregrass. From
these tracts, the extent of original wire-
grass lands is surmised.

We cannot be absolutely certain that
wiregrass has always been as dominant as
it is in the remaining "barrens." For
example, differential grazing by cattle on
the open range may have favored wire-
grass at the expense of more palatable
species. Nonetheless, large herbivores
were abundant at the lime of European
colonization and would have asserted
similar grazing pressures prior to the
introduction of cattle. We do know that
wiregrass has an exceedingly low repro-
ductive potential and that successful
reproduction is initiated by summer burn-
ing, as will be discussed below. It would
be difficult to explain how wiregrass
could have increased its density in his-
toric times, when winter-burning has
dominated. The most defensible conclu-
sion is that the current abundance of
wiregrass in undisturbed stands with
natural fire regimes is similar to what its
abundance once was in the indefinite past
and that wiregrass has been the principal
source of fuel for fires that maintained
the "barrens."

Old records provide a feel for the vast-
ncss of these "barrens" that were pre-
sumably covered by wiregrass. Williams
(1827) traversed the region between
Pensacola and Jacksonville by horseback
and reported that die pine barrens occu-
pied two-thirds of the terrain. Smith
(1884) wrote, "One who has never trav-
eled through pine barrens can have little
idea of the impression of utter desolation
on which they leave the mind. Nothing is
to be lumns of the pine, with here
at	a pond or lakelet." Harper

(I	lished that these pine barrens

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were frequently burned and thai without
fire the barrens are soon colonized by
competitive hardwoods.

FIRE

The uniformly dense population structure
of wiregrass assures that the arching
leaves of each clump overlap the leaves
of neighboring plants. In a clump that has
not experienced fire for at least two years,
the fibrous leaves are numerous, mostly
dead, and persistent. It would be difficult
to conceive of a better tinder. Wiregrass
virtually "begs" to be ignited by a bolt of
lightning or by embers falling from a
smouldering, punky pine that was light-
ning-struck during a thunderstorm, which
 of a
once i > "iinunm population of wtrcgrass.
Indications of fire lupprewion are uni-
versal at such location*. The question is
how long wiregrass can survive fire sup-

pression. The answer is approximately
two or four decades, depending on soil
fertility and flammability of the site, as
will be seen in the following three
examples.

One remnant wiregrass colony was
described by Clewell (1986). Sapling
hardwoods containing 17 to 20 annual
rings were growing beneath older long-
leaf pines. These hardwoods lacked
chaned bark and must have seeded into
the site subsequent to the last fire. The
hardwood undergrowth was fairly dense
on the relatively fertile sandy loam soil.
Wiregrass clumps displayed various
degrees of torpor, and those growing in
the deepest shade contained only a few
living leaf blades. Brush and leaf litter
had accumulated to a point that a fire
would kill wiregrass by raising the tem-
perature to a lethal degree within the
superficial soil .layer in which wiregrass
is rooted.

At the Olustee Experimental Forest, Flor-
ida, fire was excluded from a longleaf
pine flat woods for 25 yean. Saw-pal-
meuo and gallberry overtook the under-
growth before hardwoods could become
established. Foreman John Perry (pers.
comm.) said that wiregrass was not evi-
dent beneath the rough of saw palmetto
and gallbeny. A few weeks after fire,
though, wiregrass, sprouting from previ-
ously dormant tussocks, covered the site.
In this instance, wiregrass was able to
survive suppression and revive after fire.
The infertility of the sandy soil may have
prevented hardwood colonization and the
accompanying fuel accumulation,
thereby allowing wiregrass to survive the
fire.

Bock with (1967) reported no wiregrass in
a longleaf pine woods from which fire
had been excluded for 34 years. The rela-
tively clayey soil promoted the rapid
growth of undemory hardwoods that pre-
sumably eliminated wkegrass.

COMPETITION

In frequently burned terrain, wiregrass
gives every indication of being a highly

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compcutive and successful, long-lived
perennial species. The uniformly dense
populations of wiregrass assure ihai the
roots of each clump intermingle with
roots of neighboring clumps. Wells and
Shunk (1931) suggested that wiregrass
roots exerted strong companion with
other species. They wrote. "Anywhere in
sandhills where weed vegetation has
invaded old fields bordering wiregrass
with bare areas between tussocks, no
weeds appear, even during rainy seasons
during which thousands of weeds sprout
a few feel away on the old Held." They
suggested that there was compcuuon for
nutrients in that instance, but they also
speculated that the competiuon might be
for water in xeric sites. Woods (1957)
provided confirmation by determining
that lower soil horizons were drier than
the upper soil horizons, in which wire-
grass was rooted. Soil moisture from
rainfall was mainly absorbed by the
superficially rooted wiregrass. leaving
relatively liule moisture that could infil-
trate deeper.

Woods (1958) also showed that wire-
grass. rather than turkey oak, was respon-
sible for the removal of water by transpi-
ration from droughty sandhill soils. He
noted that it took 15 rainless days for the
soil moisture to drop from 8 percent
(slightly above field capacity) to the wilt-
ing point (1.5 to 1.9 percent) in natural
stands of longlcaf pine-turkey oak-wirc-
grass. In a plot where the turkey oaks
were deadened by herbicides, the same
reducuon in soil moisture also took 15
days, demonstrating that turkey oaks
were inconsequential in removing water
by transpiration. But on plots where at
least half of the wiregrass had been
removed by plowing furrows, it took 23
days for the soil moisture to reach the
wilting point. This result showed that
wiregrass effectively removed water
from the soil by transpiration Woods
(1958) estimated that it would lake 30
days for the soil to reach the wilting point
if wiregrass were eliminated entirely. He
continued, "On denuded areas, soil mois-
ture in the first foot remained well above
the wilting range even during the most
extended droughts. This was true despite

tlie fact that the moisture-retention capac-
ity of the undisturbed plots was greater
than that of the denuded plots, apparently
because of the higher organic matter
content."

One wonders how wiregrass survives on
dry sandhills during prolonged drought.
One possibility that lacks verification is
that the copious leaf blades are con-
structed for the efficient collection of
dew. Dew may accumulate within the
hollow farmed by the in-rolled leaf mar-
gins, and other dew droplets may roll
down the arching leaves to the base of the
clump where superficial, spongy roots
absorb the moisture (Clewell 1986).

VEGETATIVE PROPAGATION

A small clump of wiregrass consists of a
solid mass of many tillers, each consist-
ing of a short stem bearing several leaves.
As the clump expands in diameter, the
central portion dies, making the clump
doughnut-shaped (Figure 2). The soil of
the central portion is peaty from the dead
remains of roots and tillers. With contin-
ued expansion to a diameter of about 15
cm, the "doughnut" begins to fragment.
Each fragment is now a small clump that

lias the potential lo expand and form its
own "doughnut."

Such growth represents the only mode of
vegetauve propagation in wiregrass. The
rate of propagation was measured at St.
Marks National Wildlife Refuge, Honda,
in plots established in December 1977 by
refuge personnel. Measurements of wire-
grass growth were made in these plots in
December 1979, and the data arc on file
at the refuge. Founcen mature clumps of
wiregrass ranged from 1.2 to 7.0 cm in
diameter in 1977. In 1979, 13 surviving
clumps had increased in diameter on an
average of 39 percent.

From these measurements, wc can moke
a rough estimate of the rate of vegetative
growth Assume thai a fragment from a
"doughnut" is 1.2 cm in diameter, that
this fragment increases in diameter by 39
per :cnt every two years, and that it grows
to .ccome a "doughnut" 15 cm in diame-
ter- le size at which fragmentation
begi ^ anew. That process will be com-
pleted in 15 years. Although these
assumptions need verificauon, it is obvi-
ous that the rate of vegetative propaga-
tion for wiregrass is nominal and nearly
negligible.

FIGURE 2. Doughnut-like wiregrass clump with leaves removed to show tillers arising
.n near its periphery. Ruler is 15 cm long.

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FLORAL INDUCTION

Wiregrass commonly produces inflores-
cences following fire, especially fire in
summer (Abrahamson 1984). Parrou
(1967) noted that inflorescences were
also produced following defoliation and
minor soil disturbance. Defoliation under
natural conditions could be caused by
grazing, but the probability is low that a
grazing animal would defoliate a fibrous
->lant of wiregrass with its many dead
leaves. Crazing is common only after
fire, which would have already stimu-
lated floral induction. There is no natural
mechanism for soil disturbance in wire-
grass lands, as will be discussed below.
Fire remains as the only natural agent that
could cause frequent and widespread flo-
ral induction.

Anthesis occurs no longer than nine
months following fire, defoliation, or dis-
turbance. usually much sooner. The flow-
ers are rarely perfect and almost never
produce seeds. Parrou (1967) performed
a number of experiments involving floral
induction with conflicting results. His
data suggested that temperature and ptoo-
lopcriod must be satisfactory if perfect
(lowers and seeds are produced. The
details are complicated by the unequal
responses of plants from different geo-
graphic areas, suggesting genetic differ-
ences. He never observed perfect flowers
at his study sites on the Caloosa range in
southern Florida, except once following a
fire in July and again following defolia-
tion in September. No seeds were pro-
duced, though.

SEED PRODUCTION

Floristic manuals lack descriptions of
wiregrass seeds, which suggests that
seeds are rarely produced (Small 1933,
Radford et al. 1968). I examined the
many specimens of wiregrass in the her-
baria of Florida State University and the
Missouri Botanical Garden. None con-
tained seeds.

To my knowledge, the only recorded
occurrences of seeds are as follows. In
1955 Q- Kyle (Clewell 1971) observed

wiregrass in the Apalachicola National
Forest with the inflorescences bent over,
presumably from the weight of seeds.
Doves were numerous and may have
been feeding on these seeds. The inflo-
rescences were produced following an
early summer fire. Parrou (1967) found
seeds in several populations in North
Carolina. Floral induction was stimulated
by fires in several months, both summer
and winter. In I97S Bruce Means (pcrs.
comm.) discovered seeds in Bay County.
Florida, on a site thai had been summer-
burned. I germinated some of these seeds
on moist filter paper. In 1977 seeds were
collected by personnel at the Sl Marks
National Wildlife Refuge, Florida, fol-
lowing a summer fire. I collected seeds in
1977 at Torreya State Park, Florida, from
a site that was summer-bumed. All of
those seeds, though, had been destroyed
by a fungus whose black spores filled the
cavity inside the seed coat. Steven P.
Christman (pcrs. comm.) wrote, "I have
found the seeds on a dozen or so occa-
sions from Ochlockonee State Parte (Flor-
ida) and Sl Marks National Wildlife Ref-
uge to Riverside Island in the Ocata
NF... always in the autumti, and always
following a summer fire." Christman sent
me specimens with seeds that he col-
lected in Putnam County, Florida, in
1984. All were filled with fungus similar
to that from my collection at Tbneya
State Park.

SEED DESCRIPTION

The wiregrass seeds supplied to me by
Bruce Means were translucent-brown in
color and flinty in texture. They were 4.S
mm long and nearly cylindrical in shape.
They were 0.4 mm wide at a point 1.5
mm from the base and tapered slightly
towards either end. The seeds remain
tightly enclosed by a ihrce-awned lemma
after disarticulation from the inflores-
cence. S. P. Christman (pen. comm.)
observed that the degree of union of the
awns varied with their moisture comem
and that alternate twisting and untwisting
of these awns while in contact with the
soil could serve to bury the seed. This
mechanism seems likely an# needs
verification.

GERMINATION

Parrou (1967) ran several germination
experiments. He found that germination
occurred both in light and dark. At least
75 percent of the seeds placed in dry sand
and exposed to a temperature of 120°C
for 800 minutes germinated. Seeds
placed in wet sand likewise germinated
after exposure to a temperature of 100*C
for 10 minutes, but the percentage of ger-
mination dropped sharply if either tem-
perature or time of exposure were
increased. It took 127 days for three-
month-old seeds to germinate on moist
filter paper, and the germination percent-
age ranged from 2 to 33 percent, depend-
ing on the population from which the
seeds were obtained. One-year-old seeds
germinated in IS days, with the germina-
tion percentage ranging from 60 to 97
percent, depending on the population.

SEEDLINGS

I have been looking without success for
wiregrass seedlings in natural popula-
tions since 1962. Woods (1959) said tint
wiregrass normally propagates vegcta-
tively but will increase in abundance after
seeds are produced following fire. He
gave no documentation of Ms claim. 1
have asked many individuals if they had
ever seen wiregrass reproducing in the
field. None gave affirmative replies, and
these individuals included botanists,
ecoiogists, range specialists, wildlife spe-
cialists, foresters, Soil Conservation
Service personnel, surveyors, anthro-
pologists, and foremen at game
plantations.

Finally, seedlings were observed follow-
ing the aforementioned bum at Sl Marks
National Wildlife Refuge. At this rite, ail
merchantable trees were clearcut and the
remaining woody refuse was pushed into
brush piles and ignited iA inly 1977. The
fire escaped into a natural wiregrass
population. Wiregrass flowered prodi-
giously in response to that Gre and pro-
duced seeds in abundance (Figure 3).
Most seeds were sheg by December. Ref-
uge bwlogiMi s—Minted swt Nn* plots.
Three ptots were undisturbed and con-
tained mature clumps of wiregrass (the

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Volume 9(4), 1989

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FIGURE 3. Frank Zontek (left) and Joe While of Sc. Marks National Wildlife Refuge
inspect wire grass and associated species blooming prodigiously in November 1977,
following fire in July.

same ones described previously), and
three plots were disturbed and lacked
wiregrass. Wiregrass seeds were har-
vested in December 1977 and scattered
on each plot. In December 1979 the un-
disturbed plots contained 12 wiregrass
plants that arose from seeds, and the dis-
turbed plots contained S3 wiregrass
plants. To my knowledge this is the only
documentation of seedling production in
ihc Held. The data are unpublished and
arc on file at the refuge headquarters.

CRITERIA FOR SEXUAL
REPRODUCTION

From the preceding discussion, it seems
probable that sexual reproduction in
wiregrass is dependent upon sequential
criteria, all of which must be met.

(1)	Summer fire (at least in Florida) that
stimulates the production of inflores-
cences with perfect flowers.

(2)	An unknown event that allows perfect
flowers to produce viable seeds. This
event could be a weather-dependent
pollinauon system, or it might be
related to the levels of nutrients or
other cellular constituents and their
distribution within the plant at the

lime of fire. The latter possibility, il
correct, may be complicated by the
fact that nutrient levels vary accord-
ing to the length of lime since the last
fire (Chnstcnscn 1977).

(3)	After-npcning of ihe seeds for most or
all of a year. It is possible that after-
ripening may be accelerated by heat
from a subsequent fire, as suggested
by Parrou's findings on the heat toler-
ance of the seeds.

(4)	Midsummer temperatures at the time
of germination.

This sequence of events would be
expected only to occur in its entirety at
irregular intervals. Even then, the seeds
may be consumed by herbivores or
destroyed by fungi.

POPULATION STABILITY

Wiregrass populations arc remarkably
stable and seem immune to disturbance.
Soil disturbances, other than those of
human insugation, arc all but lacking in
wiregrass habitats. Soils arc exception-
ally stable, held together in large part by
the exceedingly dense, shallow mat of
wiregrass roots. The wiregrass turf is sel-
dom interrupted by tip-up mounds from

wind-lhrown trees. Relative to hardwood
Lrccs, ovcrstory pines arc not typically
uprooted. Instead, their trunks break at or
above the soil surface. Burrowing ani-
mals large enough to kill wiregrass are
nearly absent, with the possible excep-
tion of gopher tortoises on drier sites.
Gopher tortoises do not necessarily
exhume or bury wiregrass clumps while
burrowing. Their burrows are widely
spaced and are occupied for extended
periods, so that burrowing activities arc
quite limited relative to total land area. In
short, there are no natural agencies
known that could disrupt or replace a
wiregrass populauon under a natural fire
regime. Once established, a population of
wiregrass persists indefinitely, assuming
a natural fire regime and baning human
interference.

Once a wiregrass population is estab-
lished, there is apparently no further need
for sexual rcproducuon. The slow rate of
vegetative propagation seems more than
adequate for replacing an occasional
clump of wiregrass lost at a gopher tor-
toise burrow or from beneath a wind-
thrown tree.

The mechanisms ihai commonly prevent
production of perfect flowers and seeds
may have adaptive significance. By
circumventing sexual reproduction,
energy and nutrient resources may be
allocated entirely into important vegeta-
tive functions. For example, more leaves
may be produced, which would facilitate
the spread of fires. These fires, in turn,
prevent colonization by competitive but
fire-intolerant shrubs and trees.

PALEOECOLOGY

Once established, wiregrass seemingly
persists indefinitely. The question arises,
how long ago did the seed germinate that
gave rise to a particular clump of wire-
grass? Older plants presumably undergo
fragmcntauon and "doughnut" formation
in approximately 15-year cycles. Roots
of wiregrass, like those of most grasses,
arc short lived and arc continually under-
going replacement (Satcrson and
Vitousek 1984). Therefore, the cells of an

Volume 9(4), 1989

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Natural Areas Journal 229

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extant clump of wiregrass are no more
than a few yean old. Nonetheless, the
seed (hat ultimately produced that clump
may have germinated well into the indefi-
nite past.

The palynological literature provides a
glimpse into that past Organic deposits
have been identified and carbon-dated
from lake sediments in Florida and adja-
cent Georgia and Alabama. Pollen in
these deposits confirmed that present-day
pine land vegetation has existed continu-
ously within the current geographic range
of wiregrass for at least the last 5000
years (Waus 1969. 1971, Delcourt 1980,
Watts and Stuiver 1980, Delcourt et al.
1983). Although there has undoubtedly
been much subsequent reproduction by
seed, at least some and perhaps many
existing wiregrass plants could have ger-
minated from seeds 3000 years ago.

POPULATION REDUCTION

Wiregrass is easily uprooted. Using a
knife, a person can sever the shallow
roots from around a clump of wiregrass
in a few seconds and easily pull the
clump and its roots from the sandy soil.
Clewell (1980) proposed that A pal ac hoc
Indians cleared extensive agricultural
fields in this manner, using shell imple-
ments for knives. If uprooted, a plant may
become reestablished as long as the roots
are placed in contact with moist soil.
Nonetheless, nearly any kind of soil dis-
turbance will destroy at least some wire-
grass plants. Wiregrass densities are
reduced by seemingly innocuous prac-
tices, such as skidding felled logs with
light equipment. Wiregrass is entirely
eliminated by clearing law) for row crops
and improved pastures.

Once destroyed, wiregrass does not
become reestablished, owing to its negli-
gible reproductive potential, lis inability
to become reestablished was noted long
ago. Loughridge (1884) observed in
southern Georgia thai wiregrass. "once
destroyed, either by cultivation or other-
wise. does not return." Bennett and Mann
(1909) noted the absence of wiregrass in
cultivated fields in Thomas County.

Georgia. Wells and Shunk (1931) wrote
the following about wiregrass in the
sandhills of North Carolina: "One of the
most peculiar facts to be noted in the
response of vegetation to habitat changes
is that related to the flora coming in fol-
lowing the abandonment of cultivated
areas. Outstanding is the observation that
the wiregrass does not return. Areas
abandoned as many as IS years ago show
no wiregrass; the transition from the
weed flora to the adjacent native wire-
grass cover is as sharp as the plow furrow
which broke the original wiregrass sod.
Consistent search for an abandoned field
or orchard in the extensive sandhill area
in which there was evidence of the return
of Arisiida failed to disclose any."

Wells (1967) elaborated. "Once it is
plowed up, as it has been over thousands
of acres, it will not return when the field
is abandoned. Couon patches and peach
orchards abandoned over ten to twenty
years ago show no trace of its coming
back; yet it will be thick in the adjoining
woodland right up to the old field edge.
Here is a botanical 'believe it or not'
which needs investigation.'* Hebb (1957)
echoed Wells' com menu when he wrote.
"A field remains clear of oaks and wire-
grass for years after it is abandoned."

In another example, some fields in Flor-
ida were cleared of wiregrass, row
cropped, and later abandoned in the early
1940's (CIcwoH 1986). Slash pines were
planted on these fields without disturbing
the soil about 19S6. Natural populations
of wiregrass existed on adjacent land and
in the uncultivated fence rows between
fields. In spite of the proximity of these
natural populations, there has been no
colonization of wiregrass on this land for
more than 30 years.

EVIDENCES OF
REPRODUCTION

A few instances have surfaced that may
represent reproduction of wiregrass in
recent tines. The laic wildlife biologist,
H. L Staffed, wa« imcwued in wire-
grass and transplanted some dumps to a
plot in a woods he owned in Grady

County, Georgia. He mentioned that he
had established this plot in the late 1930's
to his colleagues, Ed and Roy Komarek.
In 1974 the Komareks and I rediscovered
this pkx. The site had once been a long-
leaf pine woods from which fire had been
excluded long enough for its replacement
by a pine-oak-hickory forest The plot
was I x 2 m in size and consisted of two
rows of densely planted wiregrass. The
rows were as straight as the day on which
Stoddard planted them 40 yean earlier.
Two additional wiregrass plants grew
within 2 m of the plot, but they obviously
were not pan of it. Although other expla-
nations are possible, these two plants
may very well have arisen as offspring
from Stoddard's transplants. If so. they
emphasized the negligible rate of
reproduction.

Other isolated clumps of wiregrass are
seen occasionally in old borrow pits and
in former fields of sharecroppers. These
plants may also represent modest
examples of recent reproduction; how-
ever, other explanations are possible. In
borrow piu. pre-existing wiregrass plants
grow along the edges. When undercut by
erosion, they fall into the piu. where they
may take root. Wiregrass in sharecrop-
pers' fields may have persisted from prior
times, owing to the inefficiencies of non-
mechanized agriculture.

FOREST MANAGEMENT
AND WIREGRASS

Modem practices of commercial forestry
nearly always include chopping, disking,
or other modes of soil disturbance during
site preparation. Such practices are
designed to eliminate wiregrass and other
native vegetation that compete with
planted pine seedlings. Woods (I9S9).
Grden (1962), and Hebb (1971) reported
that double chopping in sandhills elimi-
nated nearly all wiregrass. Greicn (1962)
said, "A few clumps of Aristid* stricta
were missed by the chopper; ihcy
increased in size but no seedlings were
recorded." Hebb (1971) said that wire-
grass JiiaiiMml fnwii a tuitl density of
14 J planta/m* to leas than 0.1 after
chopping.

2.10 Natural Arms Journal

5-73

Vatumf 9(4), I989

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Wircgrass is also adversely impacted by
site preparation in pine flatwoods. Shuliz
and Wilhiie (1974) reported (hat wire-
grass was reduced by disking in Baker
County, Florida. Harris et al. (1974) said
thai wiregrass declined with increasing
intensities of site preparation. While et al.
(1975) compared plant biomass in flat-
woods that were site prepared with and
without soil disturbance. They discov-
—cd that the biomass of wire grass in the
-..ics that suffered soil disturbance was
reduced 73 to 89 percent below the bio-
mass produced on undisturbed soil.

Thirty pairs of natural and neighboring
site-prepared stands of wiregrass were
compared (Clewell 1986). The sites were
equally divided (10 pairs each) between
dry sandhills, mesic flatwoods, and
boggy sites. Site preparation always
involved some form of soil disturbance.
Wircgrass density was reduced by 75
percent on the average in boggy sites, 85
percent in flatwoods, and 91 percent in
sandhills. The differences in actual den-
sity values between natural and disturbed
stands were highly significant (Wilcoxon
sign-rank lest). The results indicated that
wircgrass had a better chance of recover-
ing in wet soils than in dry soils.

W1REGRASS DEMISE

Witegrass is being destroyed on thou-
sands of hectares each year by intensive
site preparation for commercial forestry.
Additional wiregrass is destroyed as
lands are cleared for agriculture, urban
development, and other purposes. At the
present rate of destruction, wiregrass,
which was probably the most abundant
plant in the extensive pine barrens region
of the Southeast, could become rare in a
few decades. It is not even safe on
national foresu and other public lands,
although public pressure has mounted in
favor of "natural" management practices
of remnant pine barrens on federal lands.

A resumption of summer burning is being
attempted on some public lands as a
method of natural management Several
state parks in Florida are providing lead*
eiship in this effort, and the U.S. Forest

Service is beginning to experiment with
prescribed summer fue. In comparison to
the usual winter fires of this century,
summer fires provide better control of
saw palmetto, gallberry, and other shrubs.
Summer burning appears to be the only
alternative for producing wiregrass
seeds, which could potentially repopulate
former wircgrass habitats. As urbaniza-
tion encroaches on public lands, though,
there will be increasing public pressure lo
eliminate summer fires, which are per-
ceived as being less easily controlled than
winter fires. Public education regarding
the value of summer fires is essential.

ASSOCIATED SPECIES

The relatively large spaces between wire-
gross clumps are occupied by numerous
species of herbs and low-growing shrubs.
Clewell (1986) made floristic inventories
of eight wircgrass sites in Georgia and
Florida and listed from 66 to 133 species
of vascular plants at each of them. Xeric
ridges contained the fewest species and
bogs the most species. The number of
herbaceous species in these eight sites
ranged from 49 to 103. Most were com-
posites, legumes, and grasses—nearly all
were perennials. Numerous wiregrass
associates were also recorded by Walker
and Pcet (1983) and Rome (1988) in
North Carolina.

Studies by Clewell (1986) at Tall Timbers
Research Station, Florida, showed that
some, but not all, of the species regularly
growing with wircgrass appear in pine-
lands on abandoned agricultural lands
that have been intentionally burned
nearly annually ever since second-
growth pines were large enough lo sur-
vive surface fires. Dominated by tall
loblolly and shonlcaf pines (Piiuu laeda,
P. echinata), these stands resembled
longleaf pinclands in aspect, although
wiregrass was absent. It was replaced by
broom sedge (Ardropofoii virginicus)
and other ruderal species that persisted
after their colonization on recently aban-
doned fields. Many common wiregrass
associates also were absent. One small
area, though, was exceptional and con-
tained wiregrass associates that were usu-

ally lacking on such lands. An elderly
resident later explained that the site was a
former cemetery for slaves and was never
cultivated.

Some of the many wiregrass associates
that arc rare or absent in ptnelands that
developed on fallow agricultural fields
are bracken (Pteridium aquitinum). shiny
blueberry (Vaccimum myrsiniies), dwarf
huckleberry (Gayiussacio dumosa), run-
ning oak (Quercus pumita), dwarf-live
oak (Quercus minima), dwarf wax-
myrtle (Myrica cerifera var. pusilla), tur-
key oak, bluejack oak, and saw palmetto.

Herbaceous species that grow with wirc-
grass bloom prodigiously following fire.
During the next two or three years they
decline in profusion and become rare
thereafter until after the next fire. Wire-
grass and eventually shrubs like saw pal-
metto and gallberry dominate the vegeta-
tive cover between fires, and most of the
perennial herbs go dormant. The wire-
grass associates generally appear in
greater profusion and bloom more proli-
ne ally after a summer fire than following
the usual winter burns (Abrahamson
19&4).

NEED FOR PROTECTION

Until a few decades ago, wiregrass was
probably the most abundant species in
longleaf pine lands and "wiiixi herb
bop and prairies within its broad range
of geographic distribution. Its shallow
root system makes it especially suscep-
tible to modest soil disturbances. Its neg-
ligible reproductive capacity makes
regeneration particularly difficult. At its
present rate of destruction, wiregrass
could become a candidate for federal pro-
tection under the Endangered Species Act
within a few decades. With it may be
doomed an undetermined but rather large
number of asiociated species that rarely
occur except with wiregrass. Wiregrass is
the keystone species for determining the
natural fire regime. Wiregrass asserts
competition indirectly through fire and
directly through its roots, as was
described earlier. Therefore, wiregrass is
instfumcntal in shaping the physiognomy

Volume 9(4), 1989

5-74

Natural Areas Journal 231

-------
of the community and directing both
arboreal and nonaitoreal species compo-
sition and abundance. The continuing
demise of wiregrass threatens the eco-
logical integrity of all longlcaf pine-wire-
grass lands and other wiregrass
communities.

Since most large populations of wire-
grass currently exist in national forests
and other public lands, 1 urge the adop-
tion of the following policy on all public
lands: management and use of lands in
which the groundcovcr is characterized
by Aristida siricta should be limited to
those techniques and activities that con-
tinually foster the perpetuation of Am-
tida siricta as a dominant species. This
policy would protect associated species.
It would also assure the preservation of
longlcaf pine Lands and other wiregrass
communities that once covered the
majority of the terrain within the geo-
graphic range of wiregrass. This policy
would require frequent prescription burn-
ing but would not necessarily preclude
carefully supervised timber harvests.
Natural regeneration df pines would
replace those practices of site preparation
that entail soil disturbance. Educational
efforts are needed to encourage private
landowners to adopt this policy.

Efforts should be made to restore dam-
aged wiregrass lands. Summer burning
should be attempted to encourage seed
production and to reduce competition
from shrubs. Since reproductive poten-
tials are limited, meristemming tech-
niques should be attempted as a means to
provide planting stock.

LITERATURE cited

Ab'ahamson, W. G. 1984. Species response*
fire on the Florida Lake Wales Ridge.
American Journal of Botany 71:33-43.

A»rcd. K. W. 1986. Studies in to* Aristida
(Gramukac) of the southeastern United
Sutes. IV. Key and conspectus. Rhodora
M: 367-387.

B«ckwilh. S. L. 1967. Chinsegut Hill-
McCany Woods. Hernando County.
Florida. Quarterly Journal of the Florida
Academy of Sciences 30: 230-261.

Bermcu. H. H. and C. J. Mam. 1909. Soil
swvey of Thomas Courtly, Georgia.
USOA Bureau of Soils. Washington
D.C. 64 p.

Chapman. H. H. 1932. Is the longlcaf type «
climax? Ecology 13: 328-334.

Christcnsen. N. L. 1977. Fire and soil-plant
nutrient relations in a pine-wiregrass
savanna on the coastal plain of North
Carolina. Oecologia 31: 27- 44.

Ctcwell, A. F. 1971. The vegetation of the
Apaiachicola National Forest an
ecological perspective. USOA Forest
Service. Tallahassee, Fla. 152 p.

Clewell, A. F. 1980. The vegetation of Leon
County. Florida. Pp. 386-441 in The Leon
County bicentennial survey project.' an
archoological survey of selected portions
of Loon County. Florida. Florida Division
of Archives, History and Records
Management, Bureau of Historic
Properties, Misc. Project Report Series
No. 49.

Gcwell, A. F. 1983. Guide to the vascular
plants of the Florida panhandle. Florida
State University Press/University Presses
of Florida. Tallahaaaee. Fla. 616 p.

Clewelt. A. F. 1986. Natural setting aid
vegetation of the Florida panhandle.
COGSAM/PDEI-860O!. U.S. Army
Corps of Engineers. Mobile. Ala. 773 p.

Detcourt, H. R., P A. Oelcowt. and T.

Webb. 1U. 1983. Dynamic plant ecology:
the spectrum of vegetation change in
space and time. Quaternary Science
Review 1:153-173.

Dekourt, P. A. 1980. Goshen Springs: late
Quaternary vegetation record for southern
Alabama. Ecology 61:371-386.

Grclen, H. E. 1961 Plant succession on
cleared sandhills in northwest Florida.
American Midland Naturalist 67:36-44.

Harper. R. M. 1911. The relation of climax
vegetation to islands and peninsulas.
Bulletin of the Torrey Botanical Club 38:
513-523.

Harris. L D.. L. D. White. J. E. Johnston,
and D. O. Mikhunas. 1974. Impact of
forest plantations on north Florida
wildlife and habitat. Proceedings of the
Annual Conference of the Southeastern
Association of Game and Fish Commis-
sioners 28:639-677.

Hcbb. E. A. 1937. Regeneration m the
swdhills. Journal of Fowatry 33:210-
211

Hebb. E. A. 1971. Site preparation decreases
game food plants in Florida sandhills.
Journal of Wildlife Management 35: 155-
161

Heyward, F. 1939. The relation of fire to
stand composition of longlcaf pine
forests. Ecology 2t S7-304.

Kalmbacher, R. S. 1983. Distribution of dry
maucr and chemical constituents in plant
parts of four Florida native grasses.
Journal of Range Management 36: 298-
301.

Kctcham. D. E. and J. E. Bethune. 1963. Fire
resistance of south Florida slash pine.
Journal of Forestry 61: 529-530.

Loughridge, R. H. 1884. Report on the
cotton production of the state of Georgia.
U.S. Bureau of Census. Tenth Annual
Census of the United States 6: 256-450.

Parrot!, R. T. 1967. A study of wiregrass
(Aristida siricta Michx.) with particular
reference to Tire. Master's Thesis. Duke
University, Durham. N.C.

Radford, A. E.. H. E. Ahlea, and C. R. Bell.
1968. Manual of the vaacute (tea of vhe
Carolines. University of North Carolina
Press, Chapel Hill. N.C. 1183 p.

Rome, A. 1988. Vegetation variation in a
pine-wimgrass savanna in the Green
Swamp, North Carolina. Castanea 53:
122-131.

Saterson. K. A. and P. M. Vitouaek. 1984.
Fine-root biomaaa and nutrient cycling in
Aristida stricta in North Carolina coastal
plain savanna. Canadian Journal of
Bouny 62: 823-829.

Schulu, R. P. and L P. Wilhite. 1974.
Changes in a flat woods site following
intensive preparation. Forest Science 20:
230-237.

Small, J. K. 1933. Manual of the southeast-
em Hon. University of North Carolina
Press, Chapel Hill. N.C. 1534 p.

Smith. E. A. 1884. Report on the cotton
production of the state of Florida with an
account of the general feaiurea of the
state. U.S. Bureau of Census, Tenth
Annual Census of the United Stales 6:
173-2S7.

Wahknberg, W. G. 1946. Lewfteaf pine, iu
uses, ecology, regeneratiw. protection,
growth, and management. Waatungton,
DC. 429 p.

Walker. J. aad Jt K. tat. 1983. Composi-

\ uenmm of the Green Swamp.
North Carolina. VegetatioSS: 163-179.

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Volume 9(4), IM9

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Walls, W. A l%9. A (Milled diagram Iiuiii
Mud Lake, Marion County, north-central
Florida. Bulletin of the Geological
Society of America 80: 631-64Z

Waus, W. A. 1971. Postglacial and intergla-
cial vegetation history of southern
Georgia and central Florida. Ecology 52:
676-690.

Waus. W. A. and M. Sluivcr. 1980. Late
Wisconsin climate of northern Florida
and the origin of species-rich deciduous
forest. Science 210: 325-327.

Wells, B. W. 1967. The natural gardens of
North Carolina. University of North
Carolina Press. Chapel Hill. N.C. 458 p.

Wells. II W j.kI I. V. Sliuiik. I9JI. Tltc
vegetation and habitat factors of the
coarser sands of the North Carolina
coastal plain: an ecological study.
Ecological Monographs I: 465-520.

Wlmc. L. D.. L D. Harris, J. E. Johnston,
and 0. G. Mikhunas. 1975. Impact of site
preparation on flatwoods wildlife habiut.
Proceedings of the Annual Conference of
the Southeastern Association of Game
and Fish Commissioners 29: 347-353.

Williams, J. L. 1827. A view of west Florida.
Facsimile reproduction of 1827 edition.
University Presses of Florida,

Gainesville, Fla. 178 p.

Woods, I*. W. 1957. l-atiurs limiting root
penetration in deep sands of the south-
eastern coastal plain. Ecology 38:357-
359.

Woods, F. W. 1958. Some effects of tile
preparation on soil moisture in sandhills
of west Florida. Soil Science 85: 148-\ 55.

Woods. F. W. 1959. Converting scrub oak
sandhills to pine forests in Florida.

Journal of Forestry 57: 117-119.

Woods. F W , H. C. Harris, and R. E.
Caldwell. 1959. Monthly variations of
carbohydrates and nitrogen in root] of
sandhill oaks and wiregrass. Ecology 40:
292-295.

oiunw 9(4), 1919

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Natural Areas Jourr <

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LETTER #7: W.V. McCONNELL, LAND MANAGEMENT PLANNER / FORESTER;
TALLAHASSEE, FLORIDA; JULY 17, 1990

Thank you for your comments. The various items addressed in your letter are
discussed in the following numbered sections. Also refer to Letter #11 from the
Florida Forestry Association (Lamb) and Letter #12, a follow-up letter to this
letter.

!• Global climate Chanaa - in response to the issue of using biomass as a global
climate change mitigation procedure, a description of the "greenhouse effect" and
global climate change has been provided.

The global temperature is regulated through energy received from the sun and
through energy released from the earth. The energy received from the sun is of
a higher frequency than energy emitted from the earth, and passes relatively
readily through the earth's atmosphere. The lower frequency energy emitted from
the earth is absorbed by certain gases present in the atmosphere, slowing its
dissipation into outer space. These gases include carbon dioxide (CO,), methane
(CH4), nitrous oxide (N20), and chlorofluorocarbons (CFCs). These gases are
termed "greenhouse gases" (GG's) because of their role in regulating this energy
balance. As these gases accumulate in greater concentrations and trap more lower
frequency energy, the earth's atmosphere is expected to become warmer. The
potential warming of the earth as a result of increased concentrations of GG's
is called global warming or global climate change. As a result of warming of
the earth's atmosphere, significant changes in the earth's climate (e.g.,
temperature, precipitation, and cloud cover) are also expected to occur; hence
the term global climate change (GCC). While CO, has attracted a great deal of
attention because it is the most abundant of the GG's, its capacity to absorb
radiation is the lowest, other gases — such as CH4, CFC's and N,o — exist in
lower quantities yet they may play a significant role in GCC because their
capacity to absorb radiation is greater. A description of the CSG followsi

•	Carbon Dioxide - The significant role of increasing concentrations of co,
in GCC has been well documented. C02 concentrations in the atmosphere
have increased from 270 ppm to 339 ppm since pre-industrial times and
have been increasing by approximately 1 to 1.5 ppm per year. The primary
anthropogenic (si&nsi&d#) soutcts contributing to th6 incntiid
accumulation of CO, include fossil fuel combustion and deforestation. In
1986, an estimated 5.4 billion metric tons 
-------
• Nitrous Oxide - Like the other important GG'm, atmospheric nitrous oxide
(N30) concentrations are increasing (USDOE, 1988). However, records are
not extensive enough to confidently pinpoint reasons for the increase.
Annual global increases are estimated at approximately 0.6 ppb per year
between 1976 and 1980, and 0.8 ppb per year between 1979 and 1982
(Dickinson and Cicerone, 1986). n20 emissions are the result of both
natural processes and human activities. The estimated Nao emissions from
natural sources — including oceans, estuaries and natural soils — range
from 5.0 to 12.0 million mT per year. Agricultural activities, biomass
burning and fossil fuel combustion contribute another 3 to 5 million mT
per year of nitrogen to the atmosphere.

2. Forest Sprav Irrigation - Appendix C (Section C-2) of the FEISS documents the
components of a typical forest spray irrigation system. In general, the USEPA
concurs with the concepts presented in your letter and attachments in regard to
biomass, global climate change, and "effluent-to-energy". However, USEPA
believes that a potential longleaf pine-wiregrass ecosystem within a Forest
Service site, such as the Apalachicola National Forest, is not an appropriate
site (Refer to item 2 below). The City is also aware of the possible advantages
of a forest spray irrigation system over an agricultural system. It is the
understanding of the USEPA that the city of Tallahassee is to try forest spray
irrigation for an undetermined number of acres in the Eastern Expansion Area (of
the city's SE SprayfieId) on a small demonstration project basis as part of the
implementation of Alternative 1 (Refer to item 4 below) . Below is a list of
possible advantages and disadvantages of forest versus agricultural spray
irrigation systems anticipated from a general applicationt

Forest Sprav irrigation

•	Advantages

Higher nutrient-consumption potential.

Higher water-using potential.

Requires less vegetation management on an annual basis.

Less land clearing (e.g., stump removal) needed which would reduce

potential for soil erosion.

- Reduces global climate change impacts associated with land
clearing of natural vegetation.

•	Disadvantages

Relatively new approach for treated wastewater disposal but is used

in southeast and Florida.

Requires reduced irrigation levels for four to five years on newly
planted plots.

Harvesting constraints due to irrigation system lowers the return
on the timber product.

Requires understory vegetation maintenance.

May require operational changes such as "drip" versus "spray"
irrigation techniques which may reduce the per-acre effluent
disposal capacity of the operation and therefore require more
sprayfield land area.

Agricultural sprav Irrigation

•	Advantages

Long history of successful operations for disposal of treated
wastewater.

•	Disadvantages

Use of harvested crops restricted to animal feed or processed food
for humans to the extent consistent with Chapter 17-610 f a c
Requires clearing and grubbing of land in preparation of farming,
which increases potential for soil erosion.

3* 9U? gP»cj.fj.9itY - The examined Forest service sites can generallv be
•xpected to contain one or more of the protected animal and plant species common

5-78

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to Longleaf pine-wiregrass ecosystems. The USEPA believes the longleaf pine-
wiregrass Forest service sites are not ideal for spray irrigation. The USEPA
concurs that the cost of complete wiregrass restoration is very expensive;
however, wiregrass communities would be expected to slowly regenerate over time
in association with longleaf pines. Also, during the restoration of the longleaf
pine-wiregrass ecosystem, many endangered and other animal species can already
colonize and multiply in such recovering systems. The USEPA has therefore
concluded that the Forest Service sites were not the best sites to use for
anything that would increase development, such as agricultural spray irrigation
which would involve land clearing, we concur with the Florida Game and Fresh
Hater Fish Commission that any reasonably undisturbed longleaf pine-wiregrass
communities should be preserved. Additionally, disturbed communities could be
replaced or enhanced, if feasible, or simply allowed to naturally recover as
indicated above.

4.	"gffluent-to-Energy" concept - Notwithstanding, however, the USEPA believes
this concept is a good idea that could be applied in other appropriate areas
where sensitive communities, such as the longleaf pine-wiregrass ecosystem, do
not exist. In general, many acres of land exist that are suitable for spray
irrigation of trees and other vegetation, and do not support wiregrass or other
sensitive communities. (Note: while wiregrass patches exist in the proposed
Eastern Expansion area of Alternative 1, they are as a rule considered, when
compared to the Forest Service sites, remnant patches in a generally disturbed
silvicultural area of planted pines.)

5.	Demonstration Project - In addition to the above concept of forest spray
irrigation at the Forest service sites, Alternative 2, a non-Forest-Service site,
proposes forest spray irrigation. Alternative 2 is essentially the same as
Alternative 1 except Alternative 2 proposes forest spray irrigation and
Alternative 1 proposes agricultural spray irrigation for the same expansion area
of the City's existing SE Spray field. Although Alternative 1 and 2 were tied as
having the most favorable overall ranking in terms of the four evaluative
criteria considered in the EIS supplement (Refer to Executive Summary and Chapter
4), Alternative 1 is considered the preferred alternative of the EIS Supplement
since the City of Tallahassee has had successful experience in agricultural spray
irrigation. However, as indicated above (See item #2), forest irrigation is to
be tried as a small demonstration project by the City of Tallahassee for
Alternative 1 for an undetermined number of acres. The tree species in this
demonstration project would utilize the typical existing St. Joseph Land and
Development Company's pine plantation (young slash and sand pine), so that land
conversion in this area would not be needed for the forest spray irrigation. The
City plans to operate the demonstration project area initially and is
investigating existing forest spray irrigation operations in Clayton County,
Georgia for guidance, which is one of 66 forest application sites in the
southeast including 31 in the state of Florida. It is anticipated that in the
future, the City would involve a private entity for harvesting trees, specifics
on crop management practices have not yet been finalised. The small forest
irrigation demonstration project that the City is to try as part of Alternative
1 (if implemented), should provide an excellent opportunity for local decision-
makers to compare the merits of agricultural irrigation versus forest irrigation,
operational, environmental and nutrient uptake (crop nitrogen demand) aspects of
each technique would need to be considered by local decision-makers.

5-79

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t

DEPARTMENT OF HEALTH & HUMAN SERVICES	Puol'C Heain Ser.-ce

Centers for Disease Comrci
Atlanta GA 30333

August 10, 1990

Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch
U.S. EPA, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365

Dear Mr. Mueller:

We have completed our review of the Draft Environmental Impact
Statement Supplement (DEISS) for "Tallahassee - Leon County
Wastewater Management, Tallahassee, Leon County, Florida". We
are responding on behalf of the U.S. Public Health Service.

Potential public health impacts, which are described in the
DEISS, are related to potential aerosols containing pathogens
traveling away from the spray field area and potential
groundwater and surface water contamination. Of particular
concern is the Floridan Aquifer, a source of drinking water for
the area.

Because these potential impacts are inherent to a project of
this type, adequate design and location, and careful operation
of proposed systems must be assured. We believe the DEISS has
addressed these issues, and that proper treatment of the
wastewater, routine monitoring of effluent quality, selective
operation times on approved sprayfield areas, and proper
implementation of the other described mitigative measures should
minimize potential impacts of concern. Also, when compared to
the failing on-site septic systems within the jurisdiction, a
situation which will only worsen, we believe the proposed
alternative is preferable.

The Final document should emphasize that well-trained and
certified wastewater treatment plant operators will be capable
of operating the planned facility according to State and Federal
standards and regulations. We also emphasize that provisions of
the Occupational Safety and Health Act be closely followed to
ensure worker safety and health.

Thank you for the opportunity to review and comment on this
document. Please insure that we are included on your mailing
list to receive a copy of the Final EIS, and future EIS's which

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5-80

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may indicate potential public health impact and are developed
under the National Environmental Policy Act (NEPA).

Sincerely yours,

Kenneth W. Holt, M.S.E.H.
Environmental Health Scientist
Center for Environmental Health
and Injury Control

5-81

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LETTER #8: DEPARTMENT OF HEALTH & HUMAN SERVICES; PUBLIC HEALTH

SERVICE; CENTERS FOR DISEASE CONTROL; ATLANTA, GEORGIA;
AUGUST 10, 1990; KENNETH W.HOLT, M.S.E.H., ENVIRONMENTAL
HEALTH SCIENTIST; CENTER FOR ENVIRONMENTAL HEALTH AND
INJURY CONTROL

Thank you for your comments.

Regarding your concern about plant personnel and compliance with the Occupational
Safety and Health Act (OSHA), the Florida Department of Environmental Regulation
(FDER) requires that the wastewater treatment plant be under the supervision of
an on-site, certified wastewater treatment plant operator at all times. Florida
law further requires that the on-site chief operator be a class "A" Operator.
The City of Tallahassee requires that all wastewater treatment plant operators
be certified by the state of Florida. To insure worker safety and health, the
City is regulated by the Florida Department of Labor and Employment security,
Bureau of industrial safety and Health. Although the City is technically exempt
from OSHA regulation, the city is regulated by the Florida Hazardous
communication standard which adopts OSHA standards by Florida statute.

5-82

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United States Department of the Interior

Aug lO

¦v \

OFFICE OF THE SECRETARY
18 'H '30 Office of Environmental Affairs
Richard B. Russell Federal Building
75 Spnng Street. S.W.
Atlanta. Georgia 30303

AUG 1 4 1990

ER-90/583

Mr. Greer C. Tldwell
Regional Adminlstrator
Environmental Protection Agency
345 Court land Street, NE.
Atlanta, Georgia 30365

Dear Mr. Tidwel1

Wa s tewater Manage me n t °Ta f 1 aha s see ""Teon1 c	Supplement for

following comments? Ta11ahassee' Leon c°™ty, Florida, and have the

We concur with the preferred alternative i ^ ,

mftlgattve measures described on page K-8^1,1^.*.	th" th*

plans.	should be Incorporated Into project

The document does not mention mineral resoure®*	,

near the study area, and occurrences of ^snh iM^ clay deposits occur

and peat also are reported 1n the vIclnltTtH. ' }\mston*> ful1#M Mrth-

commodities occurring 1n the studv	tny 0thtr m1n€r41

subsequent reports o?	-"d

with impacts and necessary ¦Itlg.tloJ S«u7JT J]i SJ statement along

near or through the area; however	9" pip#11nes pass

detailed to pinpoint their exact	not sufficiently

pipelines if thev oass through	P1,ns for ''•locating or protecting

adverse impacts to	X*	,hould * bussed. tr no

that affect also should be (ncludjd. """ "*	» statement to

tHe Sivrz;',™,:?::™'0" °f h,bu,t «»* ¦** <» > «»¦

^ ££•»» -*¦ *-»"
l"	?'	fro, (page 3-19) the ninth 1te»

5-83

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contiguous wildlife corridor throughout the site. In addition, we recommend
that the EPA solicit, review and Incorporate 1n plans and construction, the
recomnendatlons of the Florida Game and Fresh Water F1sh Commission relative
to the protection and conservation of the Gopher Frog and the Gopher Tortoise.

The Fish and Wildlife Service contaminants biologist has Inspected the
agricultural spray field site operated by the City of Tallahassee and has
found it to be an exemplary operation, we realize that expansion of treatment
facilities 1s necessary for the growth being experienced 1n the Tallahassee
area, and we believe that alternative one provides the best option for meeting
growth-needs while also conserving valuable fish and wildlife resources.

If you have questions regarding the endangered species, please contact
James Barkuloo, U.S. Fish and Wildlife Service, 1612 June Avenue, Panama City,
Florida 32405-3721. The Panama City Field Office telephone number 1s
904/769-0552.

Thank you for the opportunity to comment on this document.

Sincerely yours

5-34

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LETTER #9: UNITED STATES DEPARTMENT OF THE INTERIOR; OFFICE OF THE
SECRETARY; OFFICE OF ENVIRONMENTAL AFFAIRS; ATLANTA,
GEORGIA; AUGUST 14, 1990; JAMES H. LEE, REGIONAL
ENVIRONMENTAL OFFICER

Thank you for your comments.

in regard to your concern about possible mineral resources in the proposed
project area, refer to Section 2.5.2 of this FEISS which incorporates this
information.

The USEPA agrees with your concern for the conservation of Gopher Frog and Gopher
Tortoise habitat within the proposed project area. Accordingly, contiguous
wildlife corridors are to be left in the Eastern Expansion of the SE Sprayfield
proposed by the city of Tallahassee for near-future construction (Refer to Figure
ES-5 or 4-2). The locations of these corridors were based on the locations of
sensitive ecological areas, sinkholes, poorly drained soil types, the city of
Tallahassee's proposed project site layout, and coordination with various state
of Florida agencies.

At your recommendation in your August 14, 1990 letter, the USEPA has
coordinated with the Florida Game and Fresh Water Fish Commission (FG&FWFC) since
the date of the publication of the Draft Environmental Impact statement
Supplement (DEISS) and the Public Hearing to help finalize the locations of the
wildlife corridors. Coordination also occurred with the city of Tallahassee and
the FDEP. coordination with these parties involved participation in a field
survey of the proposed Eastern Expansion site of the existing SE Sprayfield on
January 23, 1991 to help identify sensitive ecological areas and delineate the
wildlife corridors (See attached letters at the end of this response; USEPA
January 11, 1991 letter verifying the planned field survey and FG6FWFC February
6, 1991 letter summarizing that agency's position on the wildlife issues
resulting from the survey).

5-85

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IV

343 COURTLANO STREET. N.E.

ATLANTA. GEORGIA 3Q36S

January 11, 1991

Mr. John Dean
Superintendent
City of Tallahassee
1815 Lake Bradford Road
Tallahassee/ FL 32304

RE: Field Survey for Sensitive Ecological Areas of Proposed Eastern
Expansion Site of Existing City of Tallahassee SE Sprayfield

Dear Mr. Dean:

This is to verify the planned field survey of the Eastern Expansion
site of your existing Southeast Sprayfield located on Old Tram Road.
As we discussed, the survey is planned for January 23, 1991; we will
meet at the Sprayfield office at 9 AM and continue the survey for
most of the day. The main purpose of the survey is to generally
locate sensitive ecological areas to help delineate wildlife
corridors for such species as the Gopher Frog and Gopher Tortoise.
Delineated wildlife corridors are to be incorporated in the
Tallahassee-Leon County Wastewater Management Final EIS Supplement.
Other areas of interest could also be discussed during the survey as
appropriate.

In addition to EPA (Chris Hoberg), the EPA contractor (Cy Whitson),
and possibly your consultant attending, we have invited several State
agencies to attend. Coordination with the Florida Game and Fresh
Water Fish Commission was recommended by the U.S. Department of the
Interior in their comments on the Draft EIS Supplement; as such, the
Commission will be an important participant. The following State
agencies were invited:

o Florida Game and Fresh Water Fish Commission (Tallahassee) - Larry
Perrin and/or Douglas Bailey;

o Florida DNR, Division of State Lands (Tallahassee) - Grant Gelhardt
and/or designee;

o Florida DER, Facilities Planning Section (Tallahassee) - Van
Hoofnagle and/or Carla Perry;

o Florida DER, Water Facilities Section (Pensacola) - Ed Chivers
and/or designee.

We understand that Florida DER wetland representative(s) may or may
not also attend, although this survey is certainly not intended as a
formal wetland determination. However, obvious wetland areas will be
considered as sensitive areas.

5-86

Printed on Rtcydtd

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-2-

We look forward to meeting with you and appreciate your assistance.
Sincerely,

Heinz J. Mueller, Chief

ivironmental Policy Section
federal Facilities Branch

cc: Larry Perrin
Grant Gelhardt
Van Hoofnagle
Ed Chivers
Cy Whitson

5-37

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Florida Gamr and fresh Water fish Commission

WILLIAM G. BOSTICK.
Winter Haven

JR.

DON WRIGHT
Orli

THOMAS L. HIRES. SR.

Feb

L H

'SI

MRS. GILBERT W. HUMPHREY
Mkcotukec

ROBERT M. BRA.NTLY. E»cuii» Dnm
ALLAN L. EGBERT. PfcJX.

jt i J -

JOE MARLIN H1LLLVRO
Clcwiston

FARRIS BRYANT BL ILDINli
oiC South Meridun 5tr«t
Tjluh»s»«e Florida JQQ-1 tjOC
I *.-4 ) *00- 1 %C

February 6, 1991

Mr. Chris Hoberg
Environmental Protection Agency
345 CcMrtlarri Street, N.E.

Atlanta, (Georgia 30365

Dear Mr. Hoberg:

With respect to the 23 January 1991 site inspection of the proposed
Tallahassee sprayfield expansion, this letter is to summarize the views I
hionigccri concerning wildlife issugs relative to this project. The
upland area of this site contains vestige longleaf pine/sandhill plant
ccmnunity characteristics. The majority of this area has been planted
into sand pine and slash pine (approximately 4 to 6 years old). These
young pine plantations contain sufficient grcund cover to provide habitat
suitable for several listed species including the gopher tortoise, gopher
frog, Eastern indigo snake, and Florida pine snake. While gopher
tortoise burrows were present, our casual survey through this area
suggests a relatively lew population.

To ensure the continued on-site existence of the wildlife species
listed above following conversion of this area to a sprayfield and
agricultural farm, the protection of 15 percent of the upland area is
recommended. This upland protection area shculd be situated adjacent to
the wetlands and identified wildlife oorridor areas. This measure shculd
provide suitable habitat for the species listed above as well as provide
additional buffer to on-site wetland areas which also support important
wildlife resources.

From a cursory review of the sprayfield configuration presented by
the City of Tallahassee, 15 percent of upland protection area may be
available under their proposal, however, an accurate determination must
be made. In addition, a 300-foot-wide upland oorridor should be
maintained between the two 122-acre pivot fields to provide a better
wildlife connection between proposed protection areas.

Further, I expressed concern for direct surface water connection
from on-site wetlands with wetlands tributary to the St. Marks River.

This river is classified as an Outstanding Florida Water and every effort
should be made to ensure its protection. Therefore, since deterioration
of on-site wetlands is expected due to proposed sprayfield and
agricultural operations, I reooranend that on-site wetlands be

5-88

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Mr. Chris Hoberg
February 6, 1991
Page 2

disconnected from off-site wetlands through installation of levees or
berms. Also, ground water inpacts relative to the St. Maries River system
should be evaluated. Several sinkholes exist on this site with apparent
direct connection with the aquifer. Since the St. Marks River receives
considerable water from springs located within a couple of miles of this
site, potential inpacts to this river system need to be addressed. Such
an evaluation is beyond the soope of our agency; however, we would lite
to be assured that appropriate precautions are taken to prevent these
potential off-site inpacts.

Please contact me (904/488-6661) if you have any questions
concerning these comments.

Sincerely,

Lrery Pterin

Offiae of Environmental Services

ENV 1-3-2

cc: Mr. John Dean, City of Tallahassee

5-89

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"*o

Florida Department of Environmental Regulation

§ Twin Towers Office Bldg. • 2600 Blair Stone Road • Tallahassee. Florida 32399-2-tOO

Bor> Mjrtmez. Governor	Dale Twachtmann. secretin	John shearer. Assistant *>ecretar\

2600 Blair Stone Road

Dale Twachtmann. secretin

August 22, 1990

Dr. Cory Berish

EIS Preparation Section

Region IV, U.S. Environmental Protection Agency
345 Courtland Street, Northeast
Atlanta, Georgia 30365

Re: Tallahassee-Leon County Draft Environmental Impact Statement Supplement
Dear Dr. Berish:

The Facilities Planning Section has reviewed the draft EIS supplement for
Tallahassee-Leon County wastewater management, and offers the following
comments:

1.	Please be aware that recently enacted legislation in Florida imposes new
requirements on domestic wastewater treatment facilities that generate
sludge or residuals which are to be applied to land. The new rule
effects not only new treatment plants, but also facilities undergoing
substantial expansion or modification (reference attached copy of
Chapter 17-640, Florida Administrative Code). The Lake Bradford Road
treatment plant expansion, and expansion of the T.P. Smith facility will
likely be effected by the new ruling.

2.	The EIS supplement should include a map Identifying environmentally
sensitive areas such as wetlands, floodplains, historic and archeological
sites, etc. within the planning area.

3.	Section 2.4 indicates that conveyance, treatment, and disposal components
detailed in Tables 2-7 through 2-9 were combined to develop the system
alternatives shown in Tables 2-11 through 2-19. For the sake of clarity,
the component breakdown should be reiterated in Chapter 4, for just the
preferred alternative. The breakdown should include estimated length of
force main, gravity sswer, number of pump stations, etc., with
corresponding component cost figures. A map showing the preferred
alternative's facilities should also be Included.

4.	Section 2.3.5.1 includes soil and septic tank drain field suitability
information derived from a soils map presented in the Soil Survey of Leon
County, Florida, February 1981, prepared by the SCS and the University of
Florida. Soils and septic tank suitability maps should be incorporated
into an appendix of the EIS supplement, to substantiate Section 2.3.5.1.

5-90

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Dr. Cory Berlah
August 22, 1990
Page Two

5. Chapter 4, the Preferred Alternative Section should be revised to clearly
and more fully describe the selected plan. The major components of the
total system should be listed, along vith associated coats. Ample maps
should also be provided to show facilities' locations. Much of the
confusion from the public regarding the preferred alternative could be
allayed by reformatting Chapter 4.

We appreciate the opportunity to comment on this document. If you have any
questions, please call oe at (904)488—8163.

Sincerely,

Van R. Hoofnagle, P.E., Administrator
Facilities Planning Section

Bureau of Local Government Wastewater Financial Assistance

VRH/cpm
Attachment

5-91

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LETTER #10: FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION;

FACILITIES PLANNING SECTION; TALLAHASSEE, FLORIDA;
AUGUST 22, 1990; VAN R. HOOFNAGLE, P.E., ADMINISTRATOR
OF FACILITIES PLANNING SECTION, BUREAU OF LOCAL
GOVERNMENT WASTEWATER FINANCIAL ASSISTANCE

Thank you for your comments.

The USEPA appreciates receiving the recently enacted Florida legislation (Chapter
17-640, Florida Administrative code: F.A.c.) concerning new requirements on
domestic wastewater treatment plants. we are hereby providing the City of
Tallahassee with a copy relative to the proposed expansion of the T.P. smith
Facility and the Lake Bradford Road plant. This chapter of the F.A.C. is also
published and available and is referenced several times in this FEISS.

in regard to your concern for inclusion of a map identifying environmentally
sensitive areas, this FEISS includes figures showing soil types (Figures ES-4 and
4-1), sinkholes (Figures es-4, es-5 and 4-2), and wildlife corridors (Figures ES-
5 and 4-2) within the Eastern Expansion of the SE spray field which the City
proposes for near-future construction. Known listed archeological sites in the
SE sprayfield and expansion areas and the T.P. Smith plant area, as well as
alternative sw sprayfield areas, are presented in Figure 2-9, as well as Figures
ES-5 and 4-2. An archeological survey to determine any additional sites in the •
areas of near-future proposed construction has been conducted by the City (see
Penton, 1991). survey results are shown in Figures ES-5, 4-2 as well as 2-9.
(Also see USEPA response to the DEISS comment Letter #3 (received from the
Florida SBPO) and Sections 3.2.1.5, 3.3.5, 4.6.1 and 4.7 in this FEISS).
Regional Karstic geology is presented in Figure 2-8.

The USEPA appreciates you and your staff's participation in the field survey on
January 23, 1991 of the proposed Eastern Expansion site of the existing SE
sprayfield to help delineate sensitive ecological areas and wildlife corridors.

5-109

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402 EAST JEFFERSON STREET • P.O. BOX 1696 • TALLAHASSEE. FLORIOA 32302-1696

(904)222-5646 • FAX (904) 222-6179

William K. Cook, President	Wm. Carroll Lamb, Executive Vice President

Fax transmission 10 > \ 2— Hrs.

August 24/ 1990

Heinz J. Mueller/ Chief
Environmental Policy Section
EPA, Region IV
345 Courtland St. N.E.

Atlanta, GA 30365

Dear Mr. Mueller:

By letter dated October 3, 1989/ we advised you of the Florida Forestry
Association's support for the "effluent to energy" alternative for ths
City of Tallahassee's enlarged wastewater disposal systsm. He were
concerned to discover that/ despite our interest and the endorsenent of a
number of highly qualified scientists and leaders in the wood-energy
field/ the EPA did not discuss this strategy in presenting its Draft
Environmental Impact Stataunt Supplesient (DEISS) of January, 1990. we
understand that budgeting problems made this necessary and that you will
fully explore this option in the Final EISS.

In addition to the points raised in our earlier letter we now raise 2
issues to which we ask that you respond. Scsie of those opposing the
renewable energy proposal hold that the area should be restored to the
longleaf-wiregrass ecosystem, rather than being used for research into
renewable fuel production/ The EPA supports this position in Section
2.3.3 of the DEISS. The economic and administrative practicality of such
restoration is, of course/ central to judging its viability as an option.
A number of considerations will influence thist cost per acre/ total acres
needing treatment/ competing needs and the availability of fund and
manpower.

Wiregrass can be re-established. Dr. Andre Clewell, specialist in
ecosystem restoration and leading authority on wiregrass estimates that
the cost/ bleed on state of the art techniques, would range frcn $10/000
to $11/000 per acre. Cost of restoring wiregrass on the area proposed for
treatment under this project would be 10 million dollars. The ttakulla
Ranger District includes 73/300 acres suited to the longleaf-wiregrass
ecosystem. While an exact figure is not available/ a search of
stand/condition class inventory records/ together with discussion with
district and supervisor's office personnel/ suggests that perhaps 20,000
acres of ths this total area could be a candidate for viregrass
re-establishment. Restoration of this area would coet an estimated $200
million/ the entire operating budget for the district for ths next 125
years1

5-110

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Heinz J. Mueller
August 24/ 1990
Page 2

Dr. Clevell points out that the quoted costs are "state of the
art" and that an aggressive research effort# if successful# could reduce
then substantially. Even the most optimistic scenario# reduction by a
factor of 10, would require an expenditure equal to the district's total
budget for a period of 12.5 years to restore the areas needing treatment
on the district.

In light of existing and expected budget constraints# other national
needs# and competing management priorities for our National Forests is
there any possibility that even a small fraction of this area vill ever be
restored? Me ask that# in responding to this letter, you assess the
administrative probability and the economic feasibility of re-establishing
viregrass on the area proposed for treatment and specifically factor these
into your decision making.

The second issue has been raised by unfolding events in the Mideast which
have drastically changed the decision-making framework for this project.
Fran concern about a comfortably distant future happening - global warming
(a probable but not-quite-certain event)# we have suddenly shifted to an
inmediate need for the replacement of an endangered oil source with
domestic and renewable fuels. The "effluent to energy" proposal# focusing
as it does on research and dononstration for renewable energy production#
directly responds to this suddenly pressing need. In responding to this
letter we ask that you recognize this national need and the unique ability
of this project to meet it. The matter of national energy
self-sufficiency is not one of casual concern, Your selection of
preferred alternatives oust reflect its significance.

These two factors# plus the many other benefits to be derived from the
"effluent to energy" option# vill make it difficult indeed to justify a
refusal to include it as a preferred alternative in the final EISS.

tin. Carroll Lamb, CAE
Executive Vice President

WCL:wm

ccs City of Tallahassee Water and Sewer Dept
Supervisor# N Fs in F1
Dr. Andre Clewell

5-111

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AUG 24 '90 10:13 H.A FORESTRY ASSOC

402 EAST JEFFERSON STREET • P.O. BOX 1696 • TALLAHASSEE. FLORIDA 32302>1696

(904)222-6646 • FAX (904) 222-6179

FAX TRANSMISSION

NUMBER OP PAGES INCLUDING COVER SHEET 3	

DATE		

to	rOueller	

t^-fuoiro 1 S^ctto
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402 EAST JEFFERSON STREET • P.O BOX 1606 • TALLAHASSEE. FLORIDA 32302-1686

(904)222-5648 ~ FAX (904) 222-6179

William K. Cook, President	Wm. Carroll Lamb, Executive Vice President

Pax transmission t0 „)2- Hra.

August 24, 1990

HSidz J. Mueller, Chief
Environmental Policy Section
EPA/ Region IV
345 Courtland St. N.E.

Atlanta, GA 30365

Dear Mr. Muelleri

By latter dated October 3, 1989, we advised you of the Florida Forestry
Association's support for thus "affluent to energy" alternative for tha
City of Tallahassee's enlarged wastewater disposal system. m vers
concerned to discover that, despite our interest and the endorsonsnt of a
numhar of highly qualified scientists and leaders in the wood-energy
field, the EPA did not discuss this strategy in prsesnting Its Draft
Environmental Itapact Statement Supplement (DEISS) of January, 1990. fta
understand that budgeting problems made this necessary and that you vill
fully explore this option in the Final KISS.

In addition to the points raised in our earlier letter we now raise 2
issues to which ve ask that you respond. Seme of thoee opposing the
renewable energy proposal hold that tha area shonld be restored to the
longleaf-viregrass eaoeystem, rather than being used for research into
renewable fuel production, ZPA supports this position la Section
2.3.3 of the DEISS. The economic and administrative practicality of such
restoration is* of course, central to judging its viability as an option.
A number of considerations will influence thist cost per acre, total acres
needing treatment, ccsjpeting needs and the availability of fond and
manpower.

Wiregrass can be re-established. Dr. Andre Clevell, specialist in
ecosystesi restoration and leading authority on wiregrass estimatee that
the coat, based on state of the art techniques, would range froa |10,000
to $11,000 per acre. Cost of restoring wiregrass on the area proposed for
treatment under this project would be 10 million dollars. lfce UMcolla
Jtanger District laciudss 73,300 acres suited to the lcnglsef-viregraee
ecosystesi. While an exact figure is not available, a eearch of
stand/condition class inventory records, together with discussion with
district and supervisor's office personnel, suggests that perhaps 20,000
acres of ths this total area oould be a candidate for wiregrass
re-establlshasnt. Restoration of this area would cost an eetlmated $200
million, tha entire operating budget for the district for the next 125
years!

5-113

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Heinz J. Mieller
August 24# 1990
Page 2

Dr. Clew* 11 points out that the quoted costs are "state of the
art" and that an aggressive research effort/ if successful/ could reduce
than substantially. Even the most optimistic scenario, reduction by a
factor of 10, would require an expenditure equal to the district's total
budget for a period of 12.5 years to restore the areas needing treatment
ca the district.

In light of existing and expected budget constraints/ othar national
needs, and acspeting managsmant prioritise for our National Forests is
there any possibility that even a snail fraction of this area vill ever be
restored? Vfe ask that, in responding to this letter/ you aseees the
administrative probability and the economic feasibility of re-establishing
viregrass on the area proposed for treatment and specifically factor these
into your decision making.

The second issue has been raised by unfolding events in the Mideast vhieh
have drastically changed the decision-making framework for this project.
Fraa concern about a ccstfortably distant future happening - global naming
(a probable but not-quite-certain event), ve have suddenly shifted to an
iBBediate need for the replacement of an endangered oil souroe with
dansstic and renewable fuels. The "effluent to energy11 proposal, focusing
as it does on research and desaonstration for rsnevable energy production/
directly responds to this suddsnly pressing need. In responding to this
letter ve ask that you recognize this national need and the unique ability
of this project to meet it. The natter of national energy
self-sufficiency is not one of casual concern/ Your selection of
preferred alternatives must reflect its significance.

These tvo factors/ plus the aeny other bsnefits to be derived from the
"effluent to energy" option, vill make it difficult indeed to justify a
refusal to include it as a preferred alternative in the final 1ISS.

Carroll Lamb/ cjub
Executive Vice President

WCL:vm

ocj City of Tallahassee Hater and Sewer Dept
Supervisor, N Vs in 71
Dr. Andre Clevell

5-114

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LETTER #11: FLORIDA FORESTRY ASSOCIATION; TALLAHASSEE, FLORIDA;

AUGUST 24, 1990; WILLIAM CARROLL LAMB, CAE, EXECUTIVE
VICE PRESIDENT (FACSIMILE TRANSMISSION ALSO SENT AT
10:13 AM ON AUGUST 24, 1990)

Thank you for your comments.

The usepa agrees that complete restoration of longleaf pine-wiregrass ecosystems
would be very expensive due to the cost of wiregrass establishment. However,
wiregrass communities will recover naturally over time in association with
longleaf pines and will eventually disseminate as succession occurs. It should
be noted that even during the recovery time of the longleaf pine-wiregrass
ecosystem, many endangered and other animal species can already colonize and
multiply in such recovering systems.

Please also refer to the USEPA response to the related DEISS Comment Letter #7
(received from Mr. w.V. McConnell) relative to the MEffluent-to-EnergyM concept
and related matters.

5-115

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W. V. McCONNELL land management planner / forester

1023 SAN LUIS ROAD. TALLAHASSEE. FLORIDA 32304
(904) 576-7774

August 24, 1990

Heinz. J. Mueller, Chief
Environmental Policy Section
EPA, Region IV
345 Courtland St. N.E.

Atlanta, GA 30365

Dear Dr. Mueller:

This is a supplement to my letter to you dated July 18,
dealing with the EISS for the Tallahassee vastevater disposal
system.

On August 2 Iraq invaded Kuvait. This act and subsequent
events produced worldwide economic turmoil and has triggered
the currently developing Energy Crisis II. This crisis,
regardless of its Intensity and duration, has again
demonstrated the vulnerability of our nation's energy system
and the absolute necessity for prompt development of domestic
and renewable energy sources.

The "effluent to energy" alternative as described in the
attachments to my previous letter has the primary aim of
promoting this end. This newly evident and massive beneficial

he inclusion of this option as a
i the final EISS.

ENERGY-WOOD MANAGEMENT

5-116

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•2LG ZA '90 10: 15 T'~r> rCRE"'v ftSSOC

ifl2 EAST JEFFERSON STREET • P.O. BOX 1686 • TALLAHASSEE, FLORIDA 32302-1696

(904)222-5646 • FAX (904) 222-6179

PAX TRANSMISS ION

NUMBER OF PAGES INCLUDING COVER SHEET

2

DATE

Oft/24/ He

TO	— HfclNTZ , J. Mi

FROM

[Q

COMMENTS:

5-117

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1/V. McCONISELL LAND MANAGEMENT PLANNER / FORESTER

1023 SAW LUtS AOAD. TALLAHASSEE, FLORIDA 02004

Heinz. J. Mueller, Chief
Environmental Policy Section
EPA/ Region IV
345 Courtland St. N.E.

Atlanta/ OA 30365

Dear Dr. Mueller»

dealina vitlP'the"??***# By *ett#r to 7«U dated July 18/

Tallahassee vastevater disposal

On August 2 Iraq invaded Kuvait. This act and subsequent
events produced vorldvide economic turmoil and has t?ioSered
th^ currently rfevMnpIng Hn^rgy P.r1«1n TT ?hie «?¦
-------
LETTER #12: W.V. McCONNELL, LAND MANAGEMENT PLANNER / FORESTER;

TALLAHASSEE, FLORIDA; AUGUST 24, 1990 (FACSIMILE
TRANSMISSION ALSO SENT AT 10:16 AM ON AUGUST 24, 1990)

Thank you for your comments.

The USEPA appreciates your additional comments emphasizing your interest in the
"Effluent-to-EnergyM concept. Please refer to the USEPA response to your
previous, related DEISS Comment Letter #7, where your comments have been
addressed. Also refer to the USEPA response to the related DEISS Comment Letter
#11 (received from the Florida Forestry Association).

5-119

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.ruTED STATES	0FF'Ce C.= --5-.C AFFAIRS

ENVIRONMENTAL PROTECTION 345 COURTIAND ST. N.E.
AGENCY REGION IV	ATLANTA. GEORGIA 3036S

flqpioa
GEona^

KENTUCKY

SSfWSScu-,,

SOUTH Carolina
TENNESSEE

347-3004

oEPA

ENVIRONMENTAL NEWS

EPA TO HOLD PUBLIC HEARING FOR TALLAHASSEE/LEON COUNTY
WASTEWATER MANAGEMENT PLAN

The U.S. Environmental Protection
Agency (EPA) will hold a public hearing Thursday, August 9, 1990 in
Tallahassee, FL to receive comments on the Draft Environmental Impact
Statement Supplement (DEISS) for the Tallahassee/Leon County
Wastewater Management Plan. The public hearing will begin at 7:00 ,
p.m. at the City Commission Chambers, 2nd floor, City Hall, 300 S.

Adam St.

The DEISS concludes that the preferred alternative is a
centralized approach. Wastewater will be treated at the improved
Lake Bradford Road and T. P. Smith Facilities. Effluent disposal
will be handled by spray irrigation at the Southeast Agricultural
Sprayfield and local golf courses. The preferred alternative is cost
effective, readily implementable and has few environmental impacts.

In order to solicit further public participation on the proposed
project, both oral and written comments will be accepted and a
transcript will be made. For accuracy of the record, written
comments are encouraged. Persons may also respond in writing before-
the close of the public comment period on August 24, 1990 to Heinz J.
Mueller, Chief, Environmental Policy Section, Federal Activities
Branch, U.S. EPA, 345 Courtland Street, NB, Atlanta, GA 30365.
Facsimile transmittals may be sent to BPA at (404) 347-5056.

Copies of the DEISS are available for review at the following
locations in Tallahassee: Leon County Public Library, 1940 Monroe
Street, ATTN: Ms. Linda Barber; Coleman Memorial Library, Florida
A & M University, Rm 304 C, ATTN* Mrs. M. B. Crump? and Robert
Manning Strozier Library, Florida State University, ATTNt Ms. Sharon
Schwerzel.

A Final Environmental Impact Statement Supplement (FEISS) will be
published after the close of the public comment period. The FEISS
will include: a revised DEISS (or a sumary of the DEISS), BPA's
decision on the preferred alternative, responses to comments received
on the DEI8#, the transcript of the public hearing and any other
relevant iMpxmation or evaluations developed after publication of
the DEISS. "

-O-	August 3, 1990

CONTACT: Carl Terry, Press Office, 404/347-3004

5-120

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USEPA TRANSCRIPT OF USEPA PUBLIC HEARING

* * *

Tallahassee-Leon County Wastewater Management

August 9, 1990
City Hall, City Commission Chambers
Tallahassee, Florida

(EPA Representative; Heinz Mueller)

My name is Heinz Mueller from the Environmental Policy Section at
EPA/Region IV and I will be tonight's Hearing Officer. I want to
welcome all of you to the Hearing tonight. The main purpose of this
Hearing is to make information available to the public and to other
agencies on the Tallahassee-Leon County wastewater management
alternatives. Our primary purpose here tonight is to receive public
and agency comments on the Draft Environmental Impact Statement
Supplement, this document here, which hopefully all of you have had
an opportunity to look at and read. The document was released June
29, 1990 and we're hoping that everyone here tonight will be...feel
free to participate. If you have not filled out a registration card
at the table when you came in, we would appreciate it if you would do
so now or do so at one of the breaks. Hopefully, you have indicated
interest in making a statement. Even if you do not wish to make a
statement, we would still appreciate you filling out a card with your
name and address because your presence becomes part of the official
Hearing record and also provides us with means of notifying you the
final results. With me tonight on my left is Dr. Cory Berish, who
has followed this project I think for a number of years now. He was
responsible on the EPA side for coming up with this Draft Supplement,
^hris Hoberg, who is the current Project Monitor, is sitting up at
che table there at the door. At this time, I would like to get any
elected officials who would like to be acknowledged, to stand up [No
one stood up]. OK. I know we probably have a number of City
officials here tonight. Also, the authority for tonight's Hearing on
the National Environmental Policy Act, which we refer to as NEPA,
requires an examination of a major federal action that might
potentially have significant impact on the human environment. Title
II of the Clean Water Act provides for construction grant money to
upgrade and construct publicly-owned wastewater treatment plants and
the associated collection facilities. The recent reauthorization of
the Act, which was about two years ago, is replacing the grant
program with a revolving loan program. An EIS on the wastewater
management alternatives for Tallahassee-Leon County, Florida, was
finalized back in '83. The present EIS Supplement was prepared in
response to the many changes which have taken place in Tallahassee
and Leon County over the last seven years. Under EPA rules and
regulations, all findings of the EIS Supplement are to be made public
and the public may provide comments on the Draft within 45 days of
its issuance. All comments made at the Hearing tonight are being
recorded and will be addressed and responded to as part of the
preparation of the Final Supplement document. To facilitate this
Hearing, I would like to lay out some general ground rules and, as I
said we can probably be a little less formal than we have to be at
times, but the primary ground rules are that we are not here, really,

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to debate any of the conclusions or recommendations of the document;
We're here to hear your comments and concerns. I may ask questions
of any of the speakers for clarification. When you come up to speak,
you may use either one of these two microphones and your statement at
that time will be recorded on tape. Submission to any written
comments will be helpful to us either tonight or you have until the
end of the comment period to get those in to us. The comment period
will end at the close of business August 24, 1990. If you are an
individual, we would appreciate if you would limit your comments to
approximately five minutes. I'm not going to set off a alarm clock
or anything, so if we run over a minute or two, that's fine. If you
represent a group, we would be glad to give you up to 10 minutes. In
terms of any clarifications or questions that you might want to ask
to the technical staff, you may do so either during the recess, if we
decide to have one, or after the meeting. And also, we're available
at the address and at the phone number provided and you can call us
really anytime. The Draft EIS Supplement was made available and
noticed in the Federal Register June 29, 1990, and as I said
previously, we will accept written comments until August the 24th.
The Draft EIS Supplement will then be revised and we will prepare a
Final Supplemental EIS. The Final Supplemental EIS will include, at
a minimum, a summary of the findings, the preferred alternative,
public comments from tonight's meeting, any written comments that
have been submitted or will be submitted to us during the public
comment period. This document will be available to the general
public, so I hope as you signed in tonight, you've expressed a desire
to get a copy of the Final Supplement. EPA's Regional Administrator,
Greer Tidwell, will examine the Final EIS Supplement, make his final
decision, and that decision then will be published in the Federal
Register. Again, if you have registered at the Hearing tonight, we
will be notifying you of the final results. Now I would like to turn
the meeting over to Dr. Berish, who will make a brief presentation
outlining the preferred alternatives and a little bit of background.
Cory...

(EPA Representative: Dr. Cory Berish)

I want to use a couple of overheads. These overheads are also
present in the Executive Summary that Chris [Hoberg] gave out, so y^u
can follow along in the Executive Summary if you'd prefer, rather
than looking at this overhead [DEISS Fig. 2-4]. As you all know,
this study really began in about 1977 when the City prepared a 201
Facilities Plan and they started looking at growth, how growth
occurred in ihis area, and what should be done about it. In 1983 is
when the U.S. Government became involved and they did their Draft
Impact Statement. At that time, they came up with their findings of
their first preferred alternative in 1983, which was the No-Action
Alternative. Essentially what the Draft found at that time was that
the City should go ahead and build their facilities up to what was
recommended in the 201, but any growth beyond that should be
addressed via on-lot septic tank kinds of systems of small package
plants through development. Heinz [Mueller] indicated there's been
some new data that's been developed. Since that time, the kinds of
things that have occurred since that original EIS...[Interruption].
The kinds of things that have occurred since them we have some

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septic tanks that have failed in the northern part of town, we have
some new data on soils which indicate some of these soils in the
northern part of town, again, are not really appropriate for septic
tanks, and then there is the issue of growth - how much growth can be
accommodated by on-lot systems? It's an interesting question because
on-lot systems are a direct contributor to non-point pollution
problems and non-point pollution problems are a very important
question in Tallahassee. There are a lot of issues involved with
Lake Munson and the pollution associated with that area. So that
takes us to where .we are now. We want to look at what the major
issues are. So the issues that we're really looking at are: is a
centralized system better than a decentralized system — and a
centralized system would be a City-run system versus a decentralized
sort of on-lot system — and then what are the kinds of options we
can look at? In fact, the EIS looked at two centralized options, 17
effluent use and disposal options, and two sludge disposal sites; so
there really were a lot of various options that were addressed in the
EIS. And, actually, reading through these various combinations, it
was rather confusing because there were so many combinations of
options. There are three general basic options that were followed.
The three basic options are identified on this figure (DEISS Fig.
2-4]. One option would be modification of the plants in the south,
then with some sort of disposal in the south. A second option would
be a modification of plants in the south with a building of a plant
in the south, I mean the north, and either disposal in the north and
the south. A third major option would be a continue on with the
decentralized kind of system. So what are the major issues that we
need to think about when we look at this? One would...what would the
environmental impacts be? And so in this EIS, we had the contractor
and ourselves look at what are the major kinds of environmental
impacts, and they'd be similar if we're to cut down an area of
forest, or cut down whatever vegetation would be there. That's going
to occur if we do that in the north or south. There would be some
damage associated with that. It's interesting if you look from the
north to the south and compare land areas that would be necessary to
use for spray irrigation. It would take much more land in the north
than in the south, the reason being the soils are generally much more
clayey in the north, and because of that, the permeability is much
less - it would take much more land. There is a negative aspect of
that: the negative aspect of that - it could cause more environmental
damage. In addition to that, one of the options could also be if we
wanted them to use rapid infiltration basins, that either in the
north or in the south, rapid infiltration basins and/or artificial
wetlands generally take a much smaller land area to maintain than
does spray irrigation. But there is an inherent problem in looking
at artificial wetlands in the sense that you need to have a pollutant
discharge permit system to use one of these kinds of artificial
wetlands. There's not a stream course that would be available to
discharge to at this present time in this area. That pretty much
eliminates from consideration the many areas for one of these kinds
of systems. About this time is when we came down just about a year
ago now, I guess, for a scoping meeting that was really well turned
out. I think we had about 130 people in the audience, if I remember,
giving comments and much of those comments dealt with the

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possibility of siting a sprayfield in the National Forest. And
there's a lot of good points and bad points about siting a
sprayfield, using effluent in a sprayfield. Mack McConnell gave some
testimony at that time about the importance of biomass generation,
especially with respect to climate change. It turned out, however,
that in our preliminary examination, that both the sites that were
selected as possible sites for spray effluent in the past had
maintained longleaf-wiregrass communities that are often associated
with a variety of endangered species. These kinds of habitats were
suggested by the Florida Freshwater Game and Fish that these should
be protected and the Forest Service thinks the same thing in one
sense, if in 'fact the habitat is not degraded. It doesn't matter if
it's slash pine, because slash pine can be replaced. It's if the
lands haven't been physically degraded that these sites are probably
better put back into longleaf pine for future generations. So taking
all these kinds of considerations into a variety of matricies, we had
our contractor do an assessment for us and it turns out then, the
alternative that we selected as the best in terms of looking at the
most...that can be most easily implemented, and would cause the least
environmental damage and is relatively cost effective, is siting a
new sprayfield next to the existing sprayfield. The City knows how
to run these kinds of operations, they're doing it successfully right
now, improving the plants that are in the south and shipping most of
that effluent to those plants. Part of the effluent, we suggest
should also be put to golf courses, and we feel this is an important
consideration. By putting some of the effluent on golf courses,
you're going to reduce the need to fertilize some of these golf
courses. You...theoretically, you should reduce non-point runoff to
your waterways, improving overall water quality. It would be
interesting if in the future, when more and additional capacity is
needed, if there would be a turnout that would really be pushing for
conservation. I think some of the recent developments in looking at
the problems you're facing in the City with respect to water, it
really argues for water conservation, the wise use of water, and the
reuse. The spray effluent is really a resource that needs to be
used. It's not something that you think of as disposal; we need to
think about using it. And spray irrigation of our crops is a wise
management technique; so is the spray irrigation of golf courses. So
that's, in a nutshell, our examination of preferred alternative.

(Heinz Mueller)

Thank you, Cory. All right, I have, I believe, six cards. Are there
anyone else who would like to sign a card?

(Question from Audience : Margaret Fogg)

I have a question...

(Heinz Mueller)

Yes ma'am.

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(Question Continued)

...that I would like to ask, is: Do you consider now that we have a
decentralized system in Tallahassee, or...?

(Heinz Mueller)

Can you tackle that [Cory]?

(Dr. Cory Berish)

I'll tackle that. I think it depends on where you draw the boundaries
of where you're looking at. With respect to the City limits, it
would be a centralized system. As you get further outside of the
area where the sewers are in place, it would be a more decentralized
system. So you have a mix. In terms of the future, as the City
grows in terms of environmental quality, I think in many areas that
you'd be preserving environmental quality by going to a centralized
system versus a decentralized system, again by reducing the amount of
pollution that would be sent to your various surface waters in this
area. [Pause] Did she [recorder] get that question?

(Heinz Mueller)

Yeah, she [recorder] may not have gotten all of your question. Would
you mind very much restating your question up here at the
microphone? And I guess in the future, I'll have to ask all of you
to come up to a microphone, if you would please.

(Speaker #1: Margaret Fogg from Audience)

[Unclear, probably: I thought we'd be informal, and I thought we...]
(Heinz Mueller)

Yeah, that's what I had hoped, but I guess what we need is a...
(Margaret Fogg)

My name is Margaret Fogg and I live at 1312 Carson Drive and on Lake
Munson, and I represent the Munson Preservation Group. And my
question is: Do you consider that we have a decentralized system or a
centralized sewage system at this time?

(Heinz Mueller)

OK. Think the question...[has been addressed]. Are you satisfied
with the response? Does that clarify it? OK. I would like to now
go through the cards pretty much I guess in the order that they were
filled out. The first individual I have is John Gray. Mr. Gray,
would you mind coming up and using one of the microphones please, and
stating your name and address for the recorder please? [Interruption
due to wiring] Caution everyone that...careful not tripping on the
wires, here.

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(Speaker #2: John Gray)

Is the recorder on? First, I would like to take exception to the
comment that seems to be always made at these meetings about the
soils. Now I'm not necessarily a soil expert, but I think if you'll
check your files, you'll have a letter that I sent to the Agency, the
EPA agency, along with some references to soils. And, while there
may be some soils in the north and the east that has a certain amount
of pipe clay involved in it that would not be suitable for disposal
of effluents, but by and large, most of that area has also a lot of
sands. And this particular report that I referred to in my letter
that was sent to you some time back, speaks contrarily to these
statements; that that is never a site to dispose of effluent. And, I
guess I'll accept your statement that it would simply take more land
to dispose of the property, but I think it leaves the impression with
a lot of the people that that's not practical to dispose of effluent
in the north and eastern section of the City...of the County, and I
would just like to say that I don't think that's quite right. I
think you can dispose of a lot of it over there. Secondly, let me
start on my little spiel, here. Referring to your report, to page
ES-5, and I'll quote the statement. This has to do with alternatives
evaluation. It speaks to the method and the mentality that you use
to arrive at some of your alternatives. :t says "[I]t should be
noted that the items addressed during the rating process for each of
the categories do not incorporate a weighting factor. Weighting of
the items would have been difficult to justify because, though
certain items could be considered more "important" than the others,
the determination of a specific weighting value is highly subjective
and dependent on the individual's or organization's needs and
wants." After I poured over this report, I found that that's
probably the most appropriate statement in the whole report, that
most of these determinations in here are highly subjective and it
depends on one's viewpoint whether you live in the northern or
eastern section of the County or in the south/southwest section of
the County. The values that you've always discussed here seems to
always refer to some varied, smoky type of values, and you say that
the impact that you would have in the south is less than impacts on
people in the north. And, that once again depends on where you live,
not how you crunch numbers in a report. But to me, this Draft
Supplement we are discussing here tonight is an exercise really in
misrepresentation. It's very blatant. This study does nothing more
than sound off and agree with most of the issues that the Tallahassee
201 Sewer Plan has always espoused, with all the harmful effects that
it will have on all the lives of those citizens that happen to live
in the southern half of our County. Now this may be a Plan that the
City has, that's the only route that they can go because of certain
political pressures, but it is very harmful to half the citizens in
half the area of the County. And we protested that Plan - the 201
Plan - then when we first read it and heard of it, and we protest
this study now. It seems the wealthy and influential people of the
County, which always seems to reside on the north and east sides of
almost all counties in the country, seem to have sway over both
City and now the EPA because this simply is a reflection, mirror

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reflection, of what the City has always wanted to do. The Impact
Statement tries to overpower the average reader with massive data and
numbers crunching that could have only come from someone's
imagination, because the numbers are based on one's opinion as to
what harm...how much harm can be done to a regional area of the
County. So it simply goes back to one's opinion as to how harmful
something it can be. Somehow, I've attended all these meetings and
read most of these reports as best I could. You'd almost have to be
up to Pharisee level to even read it, to about understand it. I
doubt if he [Dr. Berish] understands it. But everywhere you seem to
have a mind lock on a couple of words and this has been true since
the very first day that we have met up here at these public
hearings. Everywhere the word "treatment" appears in all these
reports, always the word "south" follows. It's just...its like
pounding a psychological point home to everyone who reads this book,
that "treatment south," "treatment south", it always occurs. You
never seem to grasp the fact that utilities demanded by a section of
our County should also be located as near to the demand as possible.
It's cheaper for the public, it's cheaper on the taxpayers, and it's
fair. Everyone shares in the goodies. You only seem to think of a
southern part of Leon County as a dumping place for the waste and
pollution for the entire County. Somehow, the environment of those
living in the southern half of the County is not very important. The
environment and the clean good life style is only important for those
that are wealthy enough to live in the eastern section of Leon
County. Your attitude throughout this whole procedure has been: to
hell with the land values and the neighbors and the health and their
environment of the citizens living in the southern half of the
County. Only those who lives in the other part of the County seems
to have sway on demanding and receiving considerations to have a
clean environment. And after being involved with this study and
other EPA actions in the area, and projects in the area, I personally
have come to the conclusion, this Agency seems to be just another
government agency to protect the lifestyles of the influential and
the better off people of the world. Only their welfare and their
environment rates your protection according to most of the reports
I've read. And I'm sure you can go to every County in the State of
Florida and probably every County in this country, and you would find
a similar condition being imposed upon the less fortunate people.
So, see, when you tell me you're a national Environmental Protection
Agency, it kind of becomes a joke when you live in the area where you
consider your land values are no good, and we've received all the
unsightly utilities that any agency or any municipal government seeks
to put on us. I'm saddened by the behavior of the Agency and I
personally don't intend to support too many of your mistaken goals in
the future. I look for someone else to protect me and my family's
environment, perhaps maybe the courts. Your report indicates that
you selected Alternate 1 out of a total of nine. You twiddled it
down to three, then you went down to Alternate 1. And even in the
Alternate 1, you didn't even do the courtesy of including the
proposed plan that the City officials intends to build in the
northeast section. There's no mention of that, it doesn't even
address the idea that a plant should be built in the northeast

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section of the County. It's completely left out. Was that a mistake
or is that intentionally? And if it's intentional, I would like to
know why, since the City themselves are proposing, at least they've
been proposing for the last about 5-10 years, to build one up there.
They intend to build a small one. It's about a 5-million gailon
plant which, in my opinion, compared to the one we have in our
section of the County, it's a little overgrown septic tank, when
really the northern section should have a system three times the size
we have in our area. And I'd just like to say that I protest the
total summation of this report as it stands today, as to how it
affects many lives in the southern half of this County. I thank you.

(Heinz Mueller)

OK. Thank you Mr. Gray. OK, the next person I would like to call is
Jessie Brown.

(Speaker #3: Jessie Brown)

I'm Jessie Brown. I live at 1717 Old Briar Trail and am representing
Munson Area Preservation, Incorporated. My neighborhood, as you well
know by now, is opposed to the expansion of the southwest effluent
sprayfield which would have destroyed a large section of the National
Forest that attracted us to this area of the County. And I do
understand from reading your report, that that's no longer under
consideration and we're very greatful for that. If there's any
representatives from Game and Freshwater Fish or the National Forest
Service here tonight, I'd like to say "thank you". However, we are
very displeased that the construction of a new sewage treatment plant
in the northeast is not being recommended by the Supplemental EIS.
The 201 Plan, which was approved by the City and County Commissions
in April 1977, proposed the construction of a northeast plant. The
City of Tallahassee's Master Sewer Plan acknowledges that the most
significant demand on future wastewater management facilities will
come from the northwest and northeast areas of Tallahassee, and
proposes construction of a northeast plant. The Citizens Committee
that drafted the Tallahassee-Leon County Comprehensive Plan included
a statement that future City of Tallahassee sewage treatment plants
shall be located in the northeastern quadrant of the City, and even
your own Draft EIS, on page 2-20, discusses the fact that it has been
determined that good engineering practices requires treatment of
wastewaters as close to the source as possible, and we all know this
would be in the northern part of the County. I think the dismissal
of this proposed alternative shows poor planning for our future. Our
City government has seen fit to establish a policy which prohibits
putting parks in the unincorporated area of the County, but has no
problem shipping their sewage and garbage to the unincorporated
area. As a citizen living in the unincorporated southwest section of
the County, I have a lot of problems with such a policy, especially
when that same City government proposes infringing on the National
Forest as a site for its wastewater facilities, one of the few
recreational areas available to the citizens of this section of the
County. I just want to go on record as saying I think that policy
stinks.

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(Heinz Mueller)

OK. Thank you for your statement. [Calling] Elmer, is it Leek?
(Speaker #4: Elmer Leek)

My name is Elmer Leek, and I live in the National Forest, right...it
adjoins my property. I got 13 lots in Forest Lake Subdivision. And
in 1973, I seen my water well flowing 3 foot above the ground. I
seen the water running out the sides of the hills, from flood water.
I've seen that happen six times since I've been out there in 18
years. And how anybody can consider putting the sewage treatment
water in an area like that, I just can't believe it. I've waited, I
haven't said anything, I kept quiet all these years, but all this has
been going on. But it don't make sense. I'm a master plumber, and
you don't put water on ground where the water level table is only 2
or 3 feet below the ground. It don't make sense. Now, the area...I
made these notes...the area next to the proposed sprayfield adjoins a
floodplain and a closed basin, that's a closed basin, there has no
way out — once that water...and on top of that, the City is dumping
water in the sinkholes, and the sinkholes from Lake Bradford comes up
i-n the sinkholes in the back of my house. And when there' s... you get
a lot of rain uptown, the water will rise for weeks out in the
National Forest because it's coming up from the sinkholes and out of
the ground. And then you want to spray the wastewater out there
too? It don't make any sense. There's lakes out there. There was
fish; I don't eat the fish out of the lakes anymore. But there is a
chain of lakes right through the National Forest behind my house, and
there is no way once the water gets in that basin, there's no way
out. It has to seep into the ground, and yet they want to keep
putting it out there. I can't understand it. But if they would
consult the flood map...you [Dr. Berish] had a map out there a while
ago; would you mind putting it back up there, is it possible?

(Heinz Mueller)

Yeah, we'd be glad to do it [DEISS Fig. 2-4 overhead replaced].

(Elmer Leek: Continued)

Show you where I live...[Discussion of overhead inaudible without a
microphone]... if they would get some engineers out to check, they'll
find what I'm saying is absolutely true. But nobody's ever sent an
engineer out to check. Because the sand they say is fine. I'm like
Mr. Gray, any clay...there's a lot of clay that will absorb more
water than that will. And, so what they're doing, it doesn't make
sense. But they...[Inaudible question from audience concerning Mr.
Leek's house; probably: Is the house outside the floodplain?]. But I
live there.

(Heinz Mueller)

OK. Thank you for your statement Mr. Leek, and we will look into
your concerns as part of our final document.

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(Mr. Leek)

It's a funny thing that they can go put an oil well down and
everybody hollers don't put an oil well in the Gulf of Mexico, you
know, we don't need the oil. But we can send 100,000 men over to trv
and protect someone else's oil. it's the same thing here. You oot a
National Forest and the Federal Government doesn't want to protect

(Heinz Mueller)

OK. Thank you for your comment. The next card I have is Barbara
Rambo.

(Speaker #5: Barbara Rambo)

I don't really have anything prepared tonight, I...but I have to
protest this wastewater coming to the south end of town. I feel lik«
that the issue is not whether the preferred alternations cost
effective, readily unplementable or whether it has few eivirorLnf.i
impacts, but rather I feel that everybody in this to££ thZr^J
live on the south end of town would like to send all^the	I

the south end of town that they don't want Zi !"o^d ?"e !o
something. I'd like to know where you two gentlemen rlr	^

?ail^e!?are frOU? ^ y°U froaAtlantaordoyoulivein ^

(Heinz Mueller)

We're both from the Atlanta office.

(Barbara Rambo)

From Atlanta? OK. I just want to protest, and there's a lot I'd like
to say. I may come back up here. Thank you.

(Heinz Mueller)

OK. Thank you for your comment. [Calling] Judy Hancock.

(Speaker #6: Judy Hancock)

Wondered if Dr. Berish might have expected to see me back up here
again, to be sure we weren't going to site this on the National
Forest. I'm Judy Hancock with the Florida Chapter of the Sierra
Club, and I'm going to address my comments only to your not sitina it
on the National Forest, since I'm not familiar with the other sites.
We're very pleased that the National Forest is no longer being
considered. We think the long-term maintenance of the
longleaf-wiregrass plant community is very high in the public
interest and precludes any use as a sprayfield. Longleaf is a
declining community and can only be assured consideration on public
lands, particularly national for**"^ as they are very large land

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areas which are managed for bio-diversity and maintenance of native
species. Many other public lands are not managed with those goals,
and so we have opportunity on national forests we don't have on other
lands, we don't think that the national forests are the place for
biomass production. If this is done, it should be a private sector
investment. We very much appreciate your determination that is
responsive to our concerns, and which recognizes the high values of
the longleaf community. We would like to ask, and I think I read it
in your summary and noted in the Draft EIS, that we have some
concerns about Gopher Frog migration, and I was wondering how you
were addressing that with your preferred alternative. Do you have
some plan for...?

(Heinz Mueller)

We're not prepared to really respond to that tonight, but we will be
responding to that in the Final EIS.

(Judy Hancock)

OK. Thank you.

(Heinz Mueller)

Thank you for your statement. OK, I have one final card unless some
more have been filled out. [Calling] Dan Hendrickson. Is that

[pronounciation] close?

(Speaker #7: Dan Hendrickson)

My name is Dan Hendrickson. I'm also glad to be returning up here,
since I spoke once before. I'll keep this brief. Tonight I'm here
as a representative from the Big Ben Group Sierra Club and as a
member of the Springhill Road Group. Want to initially say we
appreciate very much you all taking seriously the comments from so
many people and the input from the agencies that resulted in your
deferring and actually staying away from the National Forest
alternative for the sprayfields. Seems to have been a very sound
decision and we appreciate what you and the other agencies did in
taking those concerns so seriously. We'd also compliment in your
list of what you call "mitigative measures," the recognition there
that the same concern that you used in the, as you referred to it,
the determination that wildlife concerns may be more important than
habitat area in our wiregrass community in that area of the forest,
that the wildlife corridor would be an important mitigative measure,
as you call it. We would prefer to try to not...get away some from
the word "mitigation" because it's been over-used and actually used
in ways that's been more destructive of the environment in the past
few years, especially in Florida. But that section that you call
"Mitigative Measures" could be seen as "Environmental Protection
Measures" and we would, of course, encourage you in any ways that you
can and we would be willing to offer some help in formulating some
ways of strengthening those environmental protection measures. But

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in there you'd made comment that the importance of keeping contiguous
wildlife corridors, and we agree that it would be important not to
fragment important wildlife habitat areas that are left in the
County, since those are rapidly enough disappearing.

We had a couple of concerns on the negative side, just more or less
questions that we would like for you to consider as you are getting
ready to draft the final version. One of them, as you probably know,
that we're not involved in — and your lucky — this County and the
City both have gone through an arduous process the last year and a
half in putting together a local comprehensive plan, and in Florida
those local "comp" plans have the power of law, nothing can be done
here that's not consistent with what those plans prescribe. The plan
that was submitted recently is the proposed plan. It's not yet the
definite and final plan. We're expecting changes from the State at
any time, or in the next few months. But at any rate, as part of
that planning process that the local governments went through, that
involved hundreds, literally hundreds, of citizens over a year and a
half or longer. There were a number of additional statistical and
other data collection of information that was used in formulating
some of the policies that the County and City governments ended up
trying to formulate. And since you expressed a concern — you
mentioned new data as part of the reasons for this Draft — that we
would strongly encourage you to look into and to incorporate the new
data that has also been recently generated in the formulation of that
local comp plan, so when the final version comes, it might be as up
to date in terms of where some of those...the underlying statistics,
especially looking towards the growth measures and where the
projections for growth are in the County and City. Some of that's
sort of changed the way people have seen it in the last year or two.
We also...I would also reiterate Mr. Gray's concern, that data that
you all use not just come from the City's own planners, and that
there may...would suggest that there may be other sources of
information that we could still call more information in terms of
where the projected growth needs are as well as those environmental
measures that you talked about were not totally satisfied that even
the local comp plan and its supporting documents truly reflect all
the concerns that should be addressed. So if there are...is time for
you to incorporate some o£ those additional studies, we would
appreciate it. Second, to do with the comp plan, again picking up on
what Mr. Gray suggested, the comp plan did formalize the reflection
that somewhere off in the future, the City and County is not going to
just continue to capitalize its sewage treatment facilities in the
south. So we would suggest that in order to be consistent and to
incorporate those future...what if it ended up becoming political
decisions, we think of them as being practical and realistic, not
just equitable but that they make sense. That those plans that say
the northeast is going to have to start supporting its own sewage
should be addressed a little more seriously in this Draft...Final
EIS, if possible, especially in order to be somewhat consistent with
the local comp plan. And then third, in the list of environmental
protection, you didn't perhaps specifically enough, address the issue
of possible ground—water contamination, which you did mention in your
list of preliminary environmental concerns of the impacts of some of

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these facilities. But particularly one that I'm concerned about, in
addition to those Judy [Hancock] mentioned and others, would probably
impact what Mr. Leek is talking about in terms of those lakes we have
in that area of the National Forest, that you probably could do some
mitigative measures or some environmental protection measures more
carefully, having to do with the sludge and sludge deposit area,
particularly the airport site. A number of us seriously question
when is there going to be enough, I mean at what point are we putting
too much sludge there, and it's going to be too late and the results
of contamination indefinite, over-nutrification of some of those
lakes. We don't know what some of those results are going to be
until it's probably too late. So we would request that you look a
little more carefully into what the City's plans are for expanding
the sludge fields. Otherwise, we're looking forward to seeing the
Final Draft and would hope that in that Draft you could make
available, as much as possible, more of the underlying statistics and
data and some of the analysis that you've been able to use in pulling
together your valuable wisdom. We appreciate it.

(Heinz Mueller)

OK. Thank you for your comment. OK, I have one more card here.
[Calling] Mildred Hall.

(Speaker #8< Mildred Hall)

I have a question mainly of concern. As a biologist, I notice in
your report, and I haven't read all of the reports... have you done a
study to see where the water goes by using a dye? That is one way to
show how filtration is done to prove that it's better to put it on
the south side as opposed to putting it on the north end of town. I
live on the south end of town also and I have a problem with Lake
Bradford because the smell is unbelievable if you live near there,
and a lot of people just, you know, turn tail and run as opposed to
staying in the area, so they'd have to put up with it. I support Mr.
Hendrickson's remarks, what he said already. Some of these same
things have been said, and in the past people use this as a sounding
board and, of course, nothing really happens. So, I would like to see
some studies done on some of these things and put in lay terms where
all people, that you don't have to be a biologist or an engineer...a
person to read some of this material. Almost anybody, almost half of
the elected officials, can't read a lot of this information unless
they've had some technical training. Thank you.

(Heinz Mueller)

Thank you for your comment.

(Question from the Audience: Mr. Leek)

Could I add something to Ms. Hall?

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(Heinz Mueller)

Would you like to...OK, is there anyone else who has signed a card
Chris [Hoberg]? [Answer: No] OK, Mr., OK, I think we've got a few
moments, Mr. Leek, would you like to come back forward? I was going
to call a short recess and give everyone another opportunity here
to...but go ahead if your comments are...

(Speaker #9 [Repeat Speaker #4]: Mr. Leek)

OK. What I wanted to mention was that the airport, the whole
complete airport, is draining all the runoff stormwater into the
sinkholes and those same sinkholes come up the back of my house. I
can't get anybody to test them. I've tried the State; nobody wants
to test to see if there's any pollution or anything going into them.
And the sludge that they're dumping out there, all the sludge from
the sewer plant on Capp Circle is going around the edge of the
airport and the edge of the National Forest, and the same area, the
closed basin I'm talking about, when you get the rain from up
on...the land where they're dumping is higher than the basin and all
that runoff is coming down into that basin, and nobody tests it to
see if there is any pollution or anything. And all the...your
phosphates and enzymes and the detergents from the City from the
sewer plant and all of that, if they want to spray it into the
National Forest, it's going to wind up in the lakes. There's no
place else for it to go. That's all I wanted to add.

(Heinz Mueller)

OK. Appreciate hearing from you on those concerns. I will now call
a short recess. If there's anyone else in the audience that would
like to sign a card to speak, we will readjourn in approximately five
minutes or so.

[After the recess, no additional speakers came forward. Heinz
Mueller then officially called the Public Hearing adjourned. (Not
recorded)]

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ToV United States Environmental Protection Agency

		Ana. 9.1990_

The area next to the proposed spray fields
adjoins a flood plain and a closed basin.

Also a chain of lakes are nearby.If anyone would take
a close look , they would seethis area is not suitable
for this purpose and the last thing we need is more

water.Some one needs to look at a flood map of this
area before this project continues.

Elmer Leek
RT. 16 Box 9055
TALLAHASSEE,FLA. 32310
Phone 904-575-8051

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Statement by Jessie Brown at EPA Public Hearing
Representing Munson Area Preservation, Inc.

August 9, 1990

My neighborhood, as you well know by now, is opposed to
the expansion of the southwest effluent sprayfield which would have
destroyed a large section of the beautiful National Forest that
attracted us to this area of the County. I understand this option
is no longer under consideration and for that we are grateful.

However, we are very displeased that the construction of
a new sewage treatment plant in the northeast is not being
recommended by the Supplemental EIS. The 201 Plan, which was
approved by the City and County Commissions in April 1977, proposed
the construction of a northeast plant; the City of Tallahassee's
Master Sewer Plan acknowledges that the most significant demand on
future wastewater management facilities will come from the
northwest and northeast areas of Tallahassee and proposes
construction of a new northeast plant; the citizens' committee that
drafted the Tallahassee-Leon County Comprehensive Plan included a
statement that future City of Tallahassee sewage treatment plants
shall be located in the northeast quadrant of the City and even
your own draft EIS on Page 2-20 discusses the fact that it has been
determined that good engineering practice requires treatment of
wastewaters as close to the source as possible and we all know that
this would be in the northern part of the County. I think the
dismissal of this proposed alternative shows poor planning for our
future.

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Statement by Jessie Brown at EPA Public Hearing
August 9, 1990
Page 2

Our City government has seen fit to establish a policy which
prohibits putting parks in the unincorporated area of the County
but has no problem shipping their sewage and garbage to the
unincorporated area. As a citizen living in the unincorporated
southwest section of the County, I have a lot of problems with such
a policy especially when that same City government proposes
infringing on the National Forest as a site for its wastewater
facilities, one of the few recreational areas available to the
citizens in this section of the county. I think we will all have
to agree that this policy "stinks."

cc: City Commissioners

County Commissioners

District 1 County Commission Candidates

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USEPA RESPONSES TO VERBAL AND WRITTEN PUBLIC HEARING COMMENTS

(Speaker #1: Margaret Fogg)

Thank you for attending and participating in the Public Hearing.

Your question whether USEPA considers Tallahassee to presently have a
decentralized or centralized sewage system, was addressed by USEPA representative
Dr. Cory Berish at the Public Hearing and is part of the Public Hearing
transcript. Dr. Berish stated that: HI think it depends on where you draw the
boundaries of where you're looking at. With respect to the City limits, it would
be a centralized system. As you get further outside of the area where the sewers
are in place, it would be a more decentralized system. So you have a mix. In
terms of the future, as the City grows in terms of environmental quality, I think
in many areas that you'd be preserving environmental quality by going to a
centralized system versus a decentralized system, again by reducing the amount
of pollution that would be sent to your various surface waters in this area."
Also refer to the expanded description provided in Section 1.1.2 of this FEISS.

(Speaker 42: John Gray)

Thank you for attending and participating in the Public Hearing.

The USEPA has no record of your letter to this Agency that you referenced
regarding soil permeability in north versus south Leon County. Therefore, by
letter dated November 15, 1990 (copy enclosed at end of these nine (9) responses
to the Public Hearing speaker comments), the USEPA requested a resubmittal of
your letter. Since to our knowledge, this Agency has not received a resubmitted
copy of the letter, USEPA is providing a generic response regarding soil
permeability in the northern versus southern portions of Leon County:

References in this FEISS to soil characteristics and distribution patterns
include the Executive Summary (Figure ES-4), the Project Updates Summary,
and Sections 2.1.4, 2.2.2, 2.3.5.1, 2.5.2, 3.2.1.2, 4.5 (Figure 4-1), C-l,
the USEPA responses to received comment letters on the DEISS (Letter #5:
Bradley Hartman, state of Florida FG&FWFC), as well as the cited Leon County
soil Survey (USDA [SCS] and USFS, 1981).

From a soils suitability perspective, it appears from the 1981 soil Survey
of Leon county, Florida (USDA [SCS] and USFS, 1981) that the northern part
of Leon County is generally less suitable for septic tank and spray
irrigation wastewater disposal than the southern part. This is not to say,
however, that favorable soils for septic tanks and spray irrigation do not
exist in both northern and southern areas of Leon County or that unfavorable
soils do not exist in southern Leon County. However, the USEPA understands
that the Leon County Public Works Department apparently conducted a spray
irrigation site assessment in 1989 and determined that more acreage would be
needed to dispose the same quantity of effluent in the selected northern
alternative sites than in the selected southern alternative sites due to
soil types. This suggests a slower percolation rate at the northern sites.

The USEPA understands from the City of Tallahassee that the City would
concur with the County with such a trend for northern versus southern Leon
County in general, since the northern portion of the County appears to be
generally underlain by layers of clay and since sandy upper horizons are
rather shallow. The City has conducted geohydrologic analyses by contractor
for nine sites in northeastern Leon County in 1991. Core soil samples
generally exhibited clay layers of varying degree in the samples collected.
Such clay layers would affect the drainage capabilities of the area and thus
its suitability for septic tank and spray irrigation disposal.

This trend also generally agrees with Table 2-9 of this FEISS. when the
acreage predicted to be required for agricultural spray irrigation in the SE
(component Dl) is compared to agricultural spray irrigation in the NE
(component D2), the average acreage needed per effluent flow (mgd) is much

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greater in the NE (430 acres/mgd) than in the SE (188 acres/mgd). The same
trend also exists for the NE forest irrigation site (component D4: 524
acres/mgd) compared to the SE forest irrigation site (component 03: 197
acres/mgd). (Note: This trend, however, is not true in every instance since
the artificial wetlands with RIBs disposal in the SE (components Dll and
D16) jure predicted to require the same amount of acreage as in the NE
(components D12 and 017), i.e., Ill acres/mgd). For Table 2-9, the maximum
application rate was used to estimate acreages and was based on the soils in
the 1981 Leon County Soil Survey at the given sites. However, the USEPA
recommends that soil percolation testing be conducted at any site proposed
for irrigation be implementation to determine actual soil percolation rates.

zt may also be noted that the City indicated in an October 27, 1992 letter
to the USEPA (Refer to the end of the "Project Updates Summary" Chapter
following the "Executive Summary" of this FEISS) that the USEPA has "...been
involved with readdressing the Environmental Impact Statement of 1983
because of septic tank failures. A joint city and County Commission letter
was sent to the EPA requesting that you [USEPA] revisit the 1983 decision..
This request was prompted by septic tank failures in the County, beyond the
city limits. It's difficult to imagine that the [Leon] County continues to
promote the septic approach given the problems that are encountered with
these in clay soil areas." The USEPA recalls participating in a site visit
of the greater Tallahassee area in 1987. Several failing septic tanks were
observed, with more failures being noticed in northern Leon County than in
the southern portions of the County. Although percolation tests were not
conducted during the site visit, the effects of differences in soil
filtration were observed among as well as within some of the residential
subdivisions visited. This observed trend for northern vs. southern Leon
County are generally supported by the 1981 Soils Survey for Leon County.

Based on the "General Soil Hap" for Leon County in the 1981 Soil Survey,
Leon county is dominated by three soil associations: the orangeburg-Lucy-
Norfolk association in the northern part of Leon County and the
Kershaw-Ortega-Alpin and the Dorovan-Talquin-Chipley associations in the
southern part of Leon County. The Orangeburg-Lucy-Norfolk soils and the
Kershaw-Ortega-Alpin soils are generally well-drained while the Dorovan-
Talquin-Chipley soils are generally not well-drained. Specifically, the
1981 Soil survey classifies the Orangeburg-Lucy-Norfolk soils as "well
drained soils" and the Kershaw-Ortega-Alpin soils as "excessively drained
and moderately well drained soils," while the Dorovan-Talquin-Chipley soils
are considered "somewhat poorly drained to very poorly drained soils." Of
the two well-drained soil associations, the depths of these sandy
associations differ significantly: the Orangeburg-Lucy-Norfolk soils are
sandy to only 20-inch depths with loam below, compared to sandy 20-40 inches
deep with loam below or are loamy throughout (Note: "loam" is a soil type
that is defined in the 1981 Soil survey as a mix of clay (7-27%), silt
(28-50%), and sand (<52%) particles.) By contrast, the Kershaw-Ortega-Alpin
soils are sandy to 80 inches or more, with some having loamy layers
(lamellae) below 45-inch depths.

Regarding the suitabilities of these soil associations for septic tank
absorption fields, Table 11 of the 1981 soil Survey presents the
"restrictive soil features" of existing soil types. All listed Orangeburg,
Lucy and Norfolk soil types are classified as "moderate: percs slowly"
and/or "moderate: wetness," with "moderate" being defined as having
unfavorable soil properties for the given activity. The Kershaw soils are
classified as "slight" which is defined as soil properties generally
favorable for the activity. Oretega and Alpin soils are classified as
"severe: poor filter," with "severe" being defined as soil properties very
unfavorable for the activity. The Dorovan, Talquin and Chipley soils are
classified as "severe: wetness" or "severe: floods, wetness." These
classifications indicate that only the Kershaw soils have properties
favorable for septic tank absorption field infiltration while the others do
not adequately drain or drain too well and therefore do not provide proper
filtration (i.e., adsorption of inorganics (metals), microbes, etc.). Leon
County therefore appears to be a mix of soil types with "slight,M "moderate"
or "severe" classifications regarding the suitability for septic tank

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activity. The preliminary 1988 Leon county MW&SSP also addresses the issue
of soil suitability for septic tanks within Leon County.

Specific to the proposed Eastern Expansion of the existing SE Sprayfield in
southeastern Leon County, Figures ES-4 and 4-1 taken from the Leon County
soil survey (USDA [SCS] and USFS, 1981), present a composite of the soil
types in the Eastern Expansion area proposed by the City for near-future
construction as part of preferred Alternative 1. Based on the 1981 Soil
survey, the soils of the Eastern Expansion Area sprayfield site proposed by
the city are dominated by Ortega Sand, Kershaw Sand with a 0-5% slope,
Talquin Fine Sand, Chipley Fine Sand and Kershaw Sand with a 5-8% slope,
respectively, of these, only the Kershaw sands are classified as favorable
for septic tank absorption fields (classified as "slight," i.e., having
favorable soil properties for the activity).

Of the portions of the proposed Eastern Expansion Area sprayfield proposed
for irrigation (i.e., center pivot irrigation Areas A-E and adjacent fixed
head irrigation areas: Refer to Fig. es-5 or 4-2 of this FEISS), irrigation
areas associated with and adjacent to Areas A, B, and D primarily contain
Kershaw Sands while irrigation areas associated with and adjacent to Areas
C and E primarily contain Ortega Sand. As indicated, Kershaw Sands are
considered suitable soil types for septic tank absorption fields while
Ortega Sand would not be favorable due to poor filtration capabilities (too
well-drained sands). However, it should be noted that the city's proposed
project is not septic tank disposal of raw sewage, but rather spray
irrigation of monitored, secondarily-treated sewage effluent. As such,
spray irrigation would disperse effluent over a greater area than septic
tank disposal and also would dispose wastewater of a considerably higher
water quality than untreated raw sewage wastewater of septic tanks.
(Specifically, all of the vertical soil horizons are utilized for filtration
during spray irrigation whereas several inches of soil filtration are not
utilized in septic tank drainage fields, since drainage lines are buried
several inches below the surface; spray irrigation utilizes the entire
horizontal soil surface area whereas septic tank fields only utilize soil
areas associated with the drainage lines; and secondarily-treated spray
effluent requires considerably less soil filtration for purification than
untreated septic tank raw sewage wastewater.)

Because of the filtration limitations of the Ortega Sand in the proposed
irrigation areas associated with and adjacent to Areas C and E as well as
some unfavorable soils interspersed in irrigation areas associated with and
adjacent to Areas A, B and D, the USEPA recommends reduced irrigation
application (inches/week) in these areas, if monitoring exhibits compliance
with State of Florida groundwater quality standards and monitoring is
conducted to the satisfaction of the state of Florida, additional
application can be tried if commensurate with groundwater quality
compliance. Groundwater monitoring is also essential since the entire
Eastern Expansion Area lies in the Woodville Karst Plain, i.e., Karstic
geology that is subject to water dissolution and collapse (sinkholes). In
any areas of collapse, irrigation should be stopped immediately in those
areas and the State of Florida notified. The USEPA recommends that no
effluent be sprayed in a reasonable surrounding area of the existing
sinkhole depressional area located within the proposed fixed head irrigation
area adjacent to Area D, as well as any other potentially discovered
sinkhole areas (Refer to Fig. ES-5 or 4-1 of this FEZSS). The USEPA further
recommends that the state of Florida consider the existing soil
characteristics and Karstic conditions of the proposed Eastern Expansion
Area in their permitting decision for the City's proposed sprayfield
expansion.

As indicated in section 2.1.4, septic tank drainfield failures have been
investigated and documented for the Killearn Lakes subdivision area located
in the northeast portion of Leon County. Failures were generally due to a
combination of slowly permeable soils, high water table elevations in
confining layers, storm water runoff and drainage, and high density
development. As a consequence, the Leon Public Health Unit recommended a
central sewage system and adequate storm water collection system for the

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area. The Public Health unit also advised restrictions for issuing on-lot
sewage disposal system permits. However, this is not to say that such
failures were documented throughout Leon County, since soil permeability and
other conditions vary in the County, with some soils being suitable for
septic tanks. The County is currently compiling a computer-based inventory
of septic tank drainfield failures. However, this inventory only includes
"new" failures and therefore cannot provide a historical record to quantify
the problem caused by failures or to identify all specific problem areas.

It should also be noted that the Leon County Public Health Unit has
indicated that the successful operation of septic tank drainfields in the
study area is a function of available soil storage above a confining layer
and not necessarily the capacity of the soil to move water. Accordingly,
tests and the measuring of water table elevations before development may be
misleading for determining the suitability of areas to accommodate
drainfields.

your comments also included a quotation on page ES-5 of the OEISS indicating that
no weighting factor was used in the EIS rating process for alternatives since
the relative importance of each item addressed would be subjective. This was
interpreted in your comments to mean that most DEISS determinations were
subjective and dependent upon one's viewpoint and whether one lived in the
northern or southern part of the County. USEPA understands that weighting
factors, matrices and other forms of rating systems are somewhat subjective forms
of assessment, particularly depending on who conducts the analysis. However, the
selection of Alternative 1 as the preferred alternative of the FEISS was based
on the evaluative ranking results of the four criteria considered (cost-
effectiveness, reliability, implementability, and environmental impacts)
presented in Table ES-1 and Table 4-1. This matrix evaluation was developed at
the DEISS preparation stage (1989) . The overall favorable ranking was attributed
to: (1) projected relatively low capital costs, (2) the City's successful
experience in operating agricultural spray irrigation facilities for effluent
disposal, and (3) negative environmental impacts could be expected to be
reasonably minimized. Alternative 1 is also a practical alternative since it
would not only utilize the City's successful experience in agricultural spray
irrigation, it also proposes to expand the City's existing SE Sprayfield as
opposed to developing a new, separate sprayfield facility (or a new disposal
approach). Of the final four alternative considered, Alternative 1 was rated the
most cost-effective of the three centralized alternatives considered; was rated
the most reliable given that the proposed project would expand the City's
existing SE sprayfield as opposed to developing a new, separate sprayfield
facility; and negative environmental impacts could be expected to be reasonably
minimized despite the fact that the proposed project ranked as one of the two
least environmentally preferable. Based on these criteria, Alternative 1
resulted in the most favorable overall ranking, tied with Alternative 2.
However, Alternative 1 is considered the preferred alternative over Alternative
2 in the EIS supplement since the City has had successful experience in
agricultural spray irrigation proposed in Alternative 1 as opposed to forest
spray irrigation proposed in Alternative 2. In general, Alternative 1 is a
practical alternative that represents a continuation of the city's agricultural
spray irrigation approach to the disposal of treated effluent through an
expansion of the City's SE Sprayfield, as well as the irrigation of existing
local golf courses.

Regarding the relative harm to residents in the north versus south parts of Leon
county, usepa understands from the city that citizen concerns regarding aerosol
spray drift, odor, and decreased property value were voiced by some 20 speakers
in a public hearing held by Leon County in Tallahassee on July 23, 1991. One
residence exists immediately adjacent (east) of the proposed Eastern Expansion
(near pivot Area C), and several other residences exist further east of the site
and north of Tram Road. In general, the public health issue relative to spray
irrigation of wastewater effluent is of concern to residents living adjacent to
or downgradient/downstream/downwind of the SE Sprayfield and the adjacent
proposed eastern Expansion area as well as golf courses should they be utilized
for spray irrigation. Potential public health risks are related to aerosols
containing non-pathogenic bacteria and pathogens (e.g., pathogenic bacteria,
viruses, protozoans and other infectious microbes) migrating off-site from the

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Sprayfield area and the potential groundwater contamination of the Floridan
Aquifer, a drinking water source. Post-irrigation use of the golf courses may
also be of concern if effluent pathogens are not completely disinfected. (Also
refer to Section 4.6).

It is generally documented (Crook, 1990; Asano et al., 1992) that wastewater
treatment methods can remove significant numbers of pathogens and non-pathogenic
bacteria typically associated with sewage wastewater. However, not all may be
killed by disinfection. In the case of pathogens such as viruses, the surviving
numbers could potentially be hazardous from a human health perspective since even
a small number of viruses can be infectious. However, several precautions can
be taken to reduce the human health risk at spray irrigation sites. These
include effluent treatment, effluent monitoring, on-site containment of aerosols,
and groundwater monitoring.

The USEPA understands from the city that City effluent is disinfected in
accordance with state of Florida standards and permit requirements. The City's
wastewater treatment processes are the activated sludge process, chlorination,
and natural ultraviolet light (sunlight) treatment in the holding ponds. Prior
to effluent spray irrigation, the city also monitors its effluent for 40
parameters including 17 metals on a monthly basis; monitors for 11 parameters
(biochemical oxygen demand (BOD), total suspended solids (TSS), total nitrogen,
residual chlorides, pH, fecal coliforms, and other parameters) on a twice a week
basis; and monitors for the six (6) above parameters on a daily basis.

Studies have shown that the health risk associated with aerosols from sewage
effluent spray irrigation sites is extremely low, particularly for irrigation
with wastewater that has been disinfected. Effluent sprayer nozzle design can
also help minimize aerosol drift effects. The dispersal of aerosols is also
directly related to wind velocities. Local prevailing winds average 7.7 miles
per hour and are from a southerly direction in the spring and summer and shift
toward a more northerly direction near the end of the year, other factors which
prolong pathogen viability and. increase the distance of aerosol travel are
increased relative humidity, lower temperature, and darkness. Studies also
indicate that pathogens tend to survive longer in an aerosol than do the
traditional indicator organisms.

The USEPA also understands from the city of Tallahassee that fecal coliform
levels are monitored by the City before effluent is spray irrigated on
sprayfields and after irrigation via groundwater monitoring. The USEPA also
understands from the city that the water quality limits for fecal coliform levels
used by the city for effluent prior to sprayfield irrigation is the state of
Florida standards defining -secondary treatment" of wastewater, i.e., <200
organisms per 100 ml of effluent. Although there are no USEPA or federal
standards for fecal coliforms for spray irrigated effluent, this criterion is
consistent with USEPA guidance from the Requirements Memorandum #79-3 dated
November 15, 1978 of the former Construction Grants Program (USEPA, 1978) . The
concepts of this memorandum were incorporated in a USEPA Technology Transfer
manual entitled "Land Treatment of Municipal Wastewater" (EPA No. 625-1-81-013)
(USEPA, 1981). The 200 counts/100 ml of effluent criterion is USEPA's fecal
coliform criterion for bathing (swimming) waters. It is presumed that water
considered safe enough for swimming (which could include incidental drinking)
would be adequate for irrigation of sprayfields, particularly with vegetated
buffers. In the absence of federal standards regarding acceptable remaining
levels of fecal coliforms in sprayed effluent, the USEPA recommends that the
State of Florida the use, at a minimum, the above federal guidance (USEPA, 1981)
to help protect public health and the environment during their permitting
decision for effluent sprayfields in addition to any appropriate State of Florida
regulations (Chapter 17-640 F.A.c.) for public access areas.

The proposed Eastern Expansion sprayfield of the preferred Alternative 1 is to
include evergreen vegetative buffer zones around the site perimeter and
considerable wildlife corridors between irrigation areas (See Figures ES-5 and
4—2). The use of forested buffer and corridor areas should greatly reduce the
spread of aerosols off site by acting as a barrier and by reducing wind
velocities. Buffer strips located at the sprayfield external boundaries (100 to
400 feet wide are to be retained/created and consist of dense evergreen

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natural/silvicultural tree vegetation, while wildlife corridors are to be
retained and consist of various natural/silvicultural trees and natural
understory vegetation (a portion of these proposed corridor areas will continue
to be timbered by the St. Joseph Land and Development Company although the
Florida Game and Freshwater Fish Commission has recommended that logging be
limited to alternate rows of planted pines with exposed areas between remaining
trees being maintained to benefit the habitat of the protected Gopher Tortoise).
Such corridor and evergreen buffer vegetation should reasonably protect adjacent
and nearby residents from contacting aerosol dispersion from the proposed Eastern
Expansion spray field. In addition to the vegetative buffer areas, the USEPA also
recommends that the City implement other environmental protection measures (Refer
to Section 4.7) such as monitoring weather conditions to avoid spraying effluent
during inclement conditions (e.g., rainy, wet, windy, freezing conditions) if
spraying during those conditions would be expected to cause detrimental
environmental or human health effects, or be considered ineffective from an
effluent disposal perspective, similar prudent spraying operations should also
be undertaken during periods of increased relative humidity, lower temperature,
and darkness since the above-noted studies have shown that these conditions
prolong pathogen viability and increase the distance of aerosol travel. It is
also recommended that the City consider any reasonable public complaints made
before or during operation of the proposed sprayfield expansion regarding
effluent aerosol dispersion or other operational impacts.

in general, reasonable protection of residents neighboring a sprayfield should
be possible through the proper design and implementation of appropriate effluent
treatment methods, frequent effluent monitoring of treated wastewater prior to
irrigation, natural ultraviolet light (sunlight) disinfection, prudent spraying
operations, use of evergreen forested buffer areas along external borders of
sprayfields, use of forested corridors within the general sprayfield area, and
groundwater monitoring. The spray application of wastewater directly to forested
areas, as opposed to open agricultural fields, would further reduce the risk
associated with aerosols (forest irrigation is proposed by the City as a small
demonstration project within Alternative 1).

The spray application of wastewater to golf courses and other public access
areas, which would provide greater public exposure than agricultural or forest
sprayfields, requires additional treatment for suspended solids removal and
high-level disinfection under State of Florida regulations. Compliance with
these regulations should greatly reduce the health risks associated with aerosols
at golf courses, irrigation of golf courses using wastewater effluent is also
not an uncommon practice since 84 golf courses in Florida were being irrigated
with wastewater in 1991. in addition, golf course spray irrigation would
require, per FDEP stipulation (FOER, 1991), that an alternate disposal method be
made available as a back-up. It is the USEPA's understanding from the city that
such a contingency does not presently exist.

Potential public health effects from animal vectors at spray irrigation sites
would be minimized through effluent disinfection. Such effects could be further
minimized through prudent spraying operations that allow acceptable effluent soil
infiltration rates that avoid ponding.

Relative to groundwater human health concerns, the city is conducting an on-site
groundwater monitoring program for its existing effluent sprayfields.
Historically, over 60 monitoring wells have been drilled and tested at the SE
Sprayfield site during interagency cooperative studies. Although the City has
been monitoring wells for some time, the state of Florida required monitoring via
a Groundwater Monitoring Program by permit condition since November 1, 1984. The
City now quarterly monitors seven (7) compliance wells at the SE Sprayfield for
six (6) parameters: N02 (nitrite) and N03 (nitrate) as nitrogen; nitrites; total
Kjeldahl nitrogen; chlorides; dissolved organic carbon (DOC); and fecal
coliforms. Pesticides and herbicides are also monitored annually.

Based on this monitoring program, the USEPA understands from the city that the
City discovered five (5) nitrate-nitrogen groundwater quality violations in one
of the seven compliance wells at the City's SE Sprayfield. The USEPA further
understands from the City that these violations occurred at compliance Hell No.
SE-22 during 1989, 1990 and 1991 and that causes included a faulty well

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construction and application techniques for additional (non-effluent) fertilizer.
The nitrate concentrations in Compliance Well No. SE-22 during those sampling
periods were 10.7 mg/1 and 10.1 mg/1 (1989), 10.3 mg/1 and 10.8 mg/1 (1990) and
10.2 mg/1 (1991), compared to the 10.0 mg/1 state of Florida limit for
groundwater nitrate-nitrogen. Overall, four (4) other compliance well violations
were monitored (also for nitrate-nitrogen) at the City's SW sprayfield during
1986, 1987 and 1988. The USEPA understands from the City that causes included
the fact that a stockpile of dewatered sludge was placed near Compliance Well No.
LS-25. The nitrate concentrations in compliance Well LS-25 were 11.8 mg/1
(1986), 10.3 mg/1 and 11.0 mg/1 (1987) and 11.2 mg/1 (1988). The USEPA further
understands from the City that the exceedances in these two wells were noted by
the FDER by letter to the city but were not formally filed as violations. The
discussed exceedances involving the faulty well, additional fertilizer and
dewatered sludge were resolved by constructing a new nearby well and adjusting
farming techniques at the SE sprayfield, and by removing the sludge at the sw
Sprayfield. The USEPA understands from the City that these exceedances have been
resolved by the city through corrective actions and monitoring has shown no
additional groundwater quality violations for monitored parameters. As a rule,
nutrient groundwater quality problems can be minimized or prevented.

with regard to your concern about the complexity of the DEISS, the document is
and must remain a technical document. As such, it will be too complicated and
technical for some readers (and perhaps not detailed enough for others).
However, through the NEPA process, a public hearing was held, a 45-day public
comment period for the DEISS was provided, and a 30-day public comment for the
this FEISS is being provided, so that adequate time for clarification should
exist. The USEPA believes the Executive Summary, for example, is a readable
synopsis that can be generally understood by the layman.

The USEPA does not disagree that it is good engineering practice to locate
treatment plants near the sewage source since the amount of conveyance pipe would
be decreased. However, this was only one consideration during the alternative
analysis. Also as indicated below, the USEPA understands from the City that the
northeast is the next likely area for potential treatment plant construction.

with regard to your comment concerning the City's construction of a new sewage
treatment plant in the NE portion of the Leon County, the concept of a NE
Wastewater Treatment Plant is not a new one. it was promoted in the 1977 201
Plan, but was not the preferred alternative in the USEPA 1983 FEIS. The city's
1988 Master Sewer Plan, however, calls for a NE Wastewater Treatment Plant to be
constructed after the year 2010. The USEPA understands from the City of
Tallahassee that a Citizens Advisory committee (for a NE treatment plant) had
been established to consider the establishment of a NE treatment plant and to
determine where such a plant could be located and how best to dispose the
effluent generated. The Committee, however, did not provide a final
recommendation and has not reconvened on the issue. The USEPA further
understands from the city that the city had made a commitment that a wastewater
treatment plant in NE Leon County would be constructed in early 1997.
Subsequently, however, the USEPA understands from the City and Leon County that
the County unilaterally defranchised (cancelled) the City's water and sewer
service zones outside city limits, so that the city consequently felt that a NE
Plant would not be needed in the NE area (where the city's "urban services area"
outside the City limits was located).

However, the city of Tallahassee and Leon County have more recently signed a new
"Water and Sewer Agreement" (1993) on February 11, 1993, which establishes a new
urban services area outside of the city in northern Leon County. The USEPA also
understands from the City that the northeast is the next likely area for
potential treatment plant construction. The City already owns an 80—acre site
in the northern part of the city that was part of the welaunee annexation package
that could potentially be used for such a NE plant. The site is located south
of interstate Highway 10 and north of Miccosukee Road, in the SW quarter of
section 12, Township I.N., Range I.E. (Also refer to Figure ES-3, where this site
is depicted aa the alternative "Northeast WWTP"). Given the public interest in
such a plant (as opposed to conveyance of northern wastewater for treatment and
disposal in southern Tallahassee) as demonstrated at the USEPA Public Hearing on
August 9, 1990, local decision-makers ma/ wish to further consider such a
potential treatment plant with appropriate effluent disposal in their future

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Tallahassee wastewater management plans.

(Speaker #3: Jessie Brown)

Thank you for attending and participating in the Public Hearing and providing
associated written comments.

You are correct in noting that the alternative that would expand the existing
southwest sprayfield (Alternative 1A) has not been selected by USEPA as the
preferred alternative; Alternative 1 has been selected. As such, sprayfields
(Alternate site No.l and No.2) in the National Forest are not proposed in this
FEiss (or DEISS). However, the Alternative 1A aspect of expanding the Thomas P.
Smith Wastewater Treatment Plant facility is still proposed in Alternative 1 *
although sprayfields are proposed as an Eastern Expansion and a Western Expansion
Area of the city's existing Southeast sprayfield. It is the usepa's
understanding from the city of Tallahassee that the city currently only proposes
near-future construction in the Eastern Expansion Area and at the T.p. smith
facility since acquisition of and construction at the Western Expansion Area
appears unlikely at this time.

With regard to your interest in the construction of a new sewage treatment plant
in the NE portion of the Leon County, please refer above to the related response
to Speaker #2 (Gray).

In response to your reference to page 2-20 of the DEISS, the USEPA does not
disagree that it is good engineering practice to site treatment plants near the
sewage source. Good engineering practice generally refers to the procedures
involved in planning, designing, constructing, and operating the most cost-
effective systems that meet the needs of the people served while considering
impacts on the environment and energy sources. since a major component of
designing and operating wastewater management facilities is the treatability of
the wastewater, the problems associated with transformations that occur as
wastewater is transported becomes a consideration. However, this was only one
consideration during the alternative analysis for evaluation of alternative cost-
effectiveness and environmental impacts. overall, results from the matrix
developed for the project indicated that Alternative 1 and Alternative 2 were the
most preferable, with Alternative 1 being selected due to the City's successful
experience in agricultural spray irrigation. The additional costs that would
occur when conveying untreated wastewaters over a relatively large distance
(including costs for preventing pipe corrosion and odors and for treating more
septic sewage) should be compared against the costs for expanding an existing
treatment plant (i.e., the TPS plant) versus the costs for siting, constructing,
and operating a separate, new plant (i.e., a NE plant).

(Speaker #4: Elmer Leek)

Thank you for attending and participating in the Public Hearing and providing
associated written comments.

your comments concerning the potential location of sprayfields in the National
Forest near your residence are well taken. Alternative 1A was not selected «nH
is not proposed in this FEISS (or DEISS); Alternative 1 has been selected.
However, the Alternative 1A aspect of expanding the Thomas P. Smith Wastewater
Treatment Plant facility is still proposed in Alternative 1, although sprayfields
are proposed as an Eastern Expansion and a Western Expansion Area of the existing
SE Sprayfield. It is USEPA's understanding from the city of Tallahassee that the
City currently only proposes near-future construction in the Eastern Expansion
Area and at the T.P. Smith facility since acquisition of and construction at the
Western Expansion area appears unlikely at this time.

(Speaker #5: Barbara Rambo)

Thank you for attending and participating in the Public Bearing.

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USEPA believes that all the issues that you indicated, i.e., whether or not the
preferred alternative has few environmental impacts, is cost effective and is
readily implementable, are all important in the preferred alternative
decision-making process. Please also refer to the matrix and ranking summary in
the Executive summary (Table ES-1 and 4-1) and the text for additional factors.
Your public input through the National Environmental Policy Act (NEPA) public
review process is also important.

(Speaker #6: Judy Hancock)

Thank you for attending and participating in the Public Hearing.

You are correct in noting that the alternative that would expand the southwest
Sprayfield (Alternative 1A) has not been selected by USEPA as the preferred
alternative; Alternative 1 has been selected. As such, sprayfields (Alternate
Sites No.1 and No.2) in the National Forest are not proposed in this FEZSS (or
DEISS) . However, the Alternative 1A aspect of expanding the Thomas P. smith
Wastewater Treatment Plant facility is still proposed in Alternative 1, although
sprayfields are proposed as an Eastern Expansion and a Western Expansion area of
the existing SE sprayfield. it is USEPA's understanding from the City of
Tallahassee that the City currently only proposes near-future construction in the
Eastern Expansion area and at the T.P. smith facility since acquisition of and
construction at the Western Expansion area appears unlikely at this time.

With regard to your concerns about the proposed project and potential disruption
of Gopher Frog migrations, contiguous wildlife corridors are to be left in the
Eastern Expansion area sprayfield. The location of these corridors was based on
the locations of sensitive ecological areas, sinkholes, poorly-drained soil
types, the City of Tallahassee's proposed project site layout, and coordination
with state of Florida agencies (See Figures ES-4, ES-5, 4-1 and 4-2 in this
FEISS). The usepa and the city preliminarily finalized the locations of these
corridors since the dates of publication of the DEISS and the Public Hearing
through coordination with the City of Tallahassee and the Florida Game and Fresh
Water Fish Commission, including conducting a field survey with these parties on
January 23, 1991. (Refer to DEISS Comment Letter #9 (received from the U.S.
Department of the Interior), USEPA's response, and follow-up letter responses,
particularly the Florida Game and Fresh Water Fish Commission letter dated
February 6, 1991 regarding their field survey conclusions.) Preliminary corridor
locations were subsequently confirmed by the city based on the city of
Tallahassee's wetland delineation in consultation with the Florida Department of
Environmental Regulation (FDEP) and the U.S. Army corps of Engineers (COE).
However, the USEPA understands from the City that these corridors could be
changed (since the configuration of proposed spray areas could be changed from
those depicted in Fig. ES-5 and 4-2) by local decision-makers during their local
alternatives selection process. The USEPA recommends, however, that if
Alternative 1 is implemented, appropriate and effective wildlife corridors should
be included in the final configuration.

(Speaker #7: Dan Hendrickson)

Thank you for attending and participating in the Public Hearing.

You are correct in noting that the alternative that would expand the Southwest
(Alternative 1A) haB not been selected by USEPA as the preferred
^erSat^e^ter^iV" 1 ha®.beei* ¦•lected. AS such, sprayfields (Alternate
n	Na^Aon Forest are not proposed in this FEISS (or

DEISS). However, the Alternative 1A aspect of expanding the Thomas P. Smith
Wastewater Treatment Plant facility is still proposed in Alternative 1, although
sprayfields are proposed as an Eastern Expansion and a Western Expansion area of
the existing SE Sprayfield. It is USEPA's understanding from the City that the

Eastern	ProP°"8 near-future construction in the

Eastern Expansion Area and at the T.P. smith facility since acquisition of and
construction at the Western Expansion Area appears unlikely at this time.

In regard to your concern about the terms "mitigative measures- versus
"environmental protection measures," the USEPA aDDreciates vnnr	*

understands th. diff.r.nc. betwe.i the	^profch ?n

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reviewing proposed projects is environmental protection, i.e., impact avoidance,
reduction, and minimization. If impacts are unavoidable and the project is
justified, mitigation (i.e., compensation) for those impacts is appropriate, in
the DEISS, the measures listed at the end of the Executive Summary and in Chapter
4 should be, we agree, more correctly termed "environmental protection measures."
Therefore, appropriate language changes have been made in this FEISS.

Regarding your interest in maintaining contiguous wildlife corridors, such
corridors are to be left in the Eastern Expansion of the existing Southeast
Sprayfield, which the City of Tallahassee proposes for near-future construction.
The location of these corridors was based on the locations of sensitive
ecological areas, sinkholes, poorly-drained soil types, the city of Tallahassee's
proposed project site layout, and coordination with various State of Florida
agencies (See Figures ES-4, ES-5, 4-1, and 4-2 in this FEISS). Since the dates
of publication of the DEISS and the Public Hearing, the USEPA has coordinated
with the Florida Game and Fresh Water Fish Commission, the city of Tallahassee,
the Florida Department of Environmental Regulation (FDER) and the Florida
Department of Natural Resources (FDNR) (Note: FDER and FDNR have since become the
Florida Department of Environmental Protection (FDEP), effective July 1, 1993)
to help finalize the locations of the wildlife corridors. Coordination with
these parties involved participation in a field survey of the proposed Eastern
Expansion site of the existing Southeast Sprayfield on January 23, 1991 to help
identify sensitive ecological areas and delineate the wildlife corridors.
Preliminary corridor locations were subsequently confirmed by the City based on
the City of Tallahassee's wetland delineation in consultation with the Florida
Department of Environmental Regulation (FDEP) and the U.S. Army Corps of
Engineers (COE). However, the USEPA understands from the city that these
corridors could be changed (since the configuration of proposed spray areas could
be changed from those depicted in Fig. ES-5 and 4-2) by local decision-makers
during their local alternatives selection process. The USEPA recommends,
however, that if Alternative 1 is implemented, appropriate and effective wildlife
corridors should be included in the final configuration.

your referenced first concern involved incorporating information from the local
comprehensive plan (comp plan) into the EIS supplement process to make the
recommendations compatible with the plan. The local comprehensive plan is titled
"Tallahassee-Leon County 2010 Comprehensive Plan." The plan was adopted by the
City commission and the county Board of Commissioners on July 16, 1990. A review
by the Florida Department of community Affairs found the plan not in compliance,
subsequently, each commission negotiated compliance agreements with the
Department of Community Affairs. These compliance agreements include remedial
actions which bring the comprehensive plan into compliance. Each commission is
required to formally amend the plan in accordance with the compliance Agreement.

USEPA's preferred Alternative 1 consists of:

1.	Expand T.P. Smith Plant by 7.5 mgd.

2.	Expand Southeast Sprayfield by 7.5 mgd.

3.	Provide 3.0 mgd of golf course irrigation from Lake Bradford Road Treatment
Plant.

The draft Comprehensive Plan Sewer Element includes the following:

1.	Expand T.P. Smith Plant by 7.5 mgd by 1995.

2.	Expand Southeast Sprayfield by 7.5 mgd by 1995.

The Comprehensive Plan does not include the 3.0 mgd of golf course irrigation.
However, it does include a policy to "complete a study examining the feasibility
of alternative waste disposal methods." This study is expected to include
alternative effluent disposal techniques. It is USEPA's understanding that the
city does not anticipate near-future spray irrigation of golf courses. Since the
draft Comprehensive Plan is basically consistent with the FEISS, the
Comprehensive Plan was not incorporated into the FEISS.

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Your referenced second concern dealt with the concept that the northern part of
the county should support its own sewage treatment. Please refer above to the
related responses to Speakers #2 (Gray) and #3 (Brown). The USEPA understands
from the City that the northeast is the next likely area for potential treatment
plant construction.

Finally, in regard to your referenced third concern involving potential
groundwater contamination from sludge deposit fields near the airport, please
refer below to the related concern and response for speaker #9 (Leek).

(Speaker #8: Mildred Hall)

Thank you for attending and participating in the Public Hearing.

In response to your question if a dye study had been conducted to demonstrate
filtration rates in the northern and southern parts of Leon County, a dye study
using Rhodamine B was performed at the Southwest Sprayfield by USGS around 1975.
The work was unpublished as none of the dye was detected in the groundwater.
This result was more a function of dye absorption onto soil particles with
subsequent biological breakdown than a function of filtration capacity. Dye
tracer studies are often unsuccessful in getting approved tracer dyes to move
through soils.

A tracer study is not the appropriate vehicle to ascertain the filtration
capacity of soils. The term "filtration rate" implies volume per unit time, as
opposed to contaminant removal capacity. A standard soil hydraulic infiltration
test would better measure filtration rate. Please refer above to related
responses to Speaker #3 (Gray) regarding soil permeability concerns.

In response to your concern about odors, considerable effort is made to operate
all city of Tallahassee treatment facilities in a manner that will prevent the
formation of odorous compounds. The city of Tallahassee has not received any
odor complaints from area residents regarding the Lake Bradford Road treatment
plant. The secondarily-treated effluent produced by the City of Tallahassee is
comparable in odor to the water in area lakes. However, should you or your
neighbors consider odor from treatment plants or irrigation sites to be a
problem, the city of Tallahassee may be contacted regarding any substantiated
complaints.

in regard to your concern about the complexity of the DEISS, the document is and
must remain a technical document. As such, it will be too complicated and
technical for some readers (and perhaps not detailed enough for others).
However, through the NEPA process, a public hearing was held, a 45-day public
comment period for the DEISS was provided, and a 30-day public comment for the
this feiss is being provided, so that adequate time for clarification should
exist. We believe the Executive Summary, for example, is a readable synopsis
that can be generally understood by the layman.

(Speaker #9 [Repeat speaker #4]: Elmer Leek)

Thank you again for attending and participating in the Public Hearing and
providing associated written comments.

in regard to your concern for sewage sludge fields near the Tallahassee airport
affecting the lake water quality in the National Forest near your residence and
your interest in water quality testing of the lakes near your residence, we
believe your concerns are shared by the USEPA, the State of Florida, and Leon
County. In addition to the USEPA (Mr. Roosevelt Childress, chief of storm Water
and Municipal Unit: 404/347-2391; x3012), you may wish to discuss your concerns
with the State of Florida, Department of Environmental Protection (FDEP) or the
Leon County Health Department. Specifically within the FDEP, further information
may be available from the Ground Water Quality Monitoring Section (Mr. Rick
copeland: 904/488-3601), the Bureau of Surface Water Management (Ms. Vivian
Garfein: 904/488-6221), and/or the Health and Rehabilitative Services, Office of
Environment and Health (904/488-4070).

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Currently, at the issuance of this FEISS, the Citv of	~ ¦ a. •

Grade 1 quality sludge, as defined in chapter 17-7 Part tv
Administrative Code. (The City's current State of Florida ooeration
remain applicable until such time as the state reissues a n«w	P®rmit will

Chapter 17-640.) At this quality, there is no c^u!at!ve SSL? ^L! Pursuant to
sludge which can be applied to a site. However heaw mai-aia „ 5 ?®ount of
annual applications of nitrogen and solids are limited by the^*' "S
groundwater contamination.	Q Dy the atatute to avoid

It is the usepa-s understanding from the FDEP that the city sludge field near the
municipal airport is in compliance with the State's	the

criterion (500 pounds of nitrogen per acre per year: 500 lbs/N/al/Jr)?PHo^i«n
the sludge field is apparently at capacity based on FDEP nitroqen leJ£l
determinations. Continued use of the sludoe fielH	nitrogen level

nitrogen application is planned due to the	«CUlarly 9"ater

Sprayfield, should be evaluated in light of the fact that*SE

requirements^6	r~iB in —Stlte^Fltrida

field^^he'le\l9sr°aUredltested^Sirteilyj^ith^esult"reported*to th^FDEP ^Sata
from groundwater monitoring wells have shown some nii-rn™n	j F°EP. Pftf

have been addressed and corrected for areas outside tin aludoa	which

line. Apparently the FDEP believes that the siuSgf tieiS ?s
outside the property line based on the nitroaen nar»mflfor \ in compliance

City, the compliance wells located down-gradient in the Floridan Aquifer'from the
airport sludge field have shown no violations of drinkina water
quality of the groundwater in the compliance well.

demonstrate that the airport sludge field is not causing nitrifieation"^'

lakes via groundwater contamination. in addition there i* «« if	area

runoff from the sludge field to any lakes. Also!"Snoff	k.nown surface

field does not appear to enter sinkholes directly because thlra a.irport slud9®

runoff. A review of the .oils survey for	£££!

sand as the only soil type present. Kershaw sand has a Dermeabilitv of

than 20 inches per hour. The City and USGS have monitofed area Skholfs that

contain standing water. There is no evidence that effluent irrigationorsludge

land spreading has influenced any of the monitored sinkholes Further

information on this matter may be obtainable from the Northwest District of fdep

in Pensacola, Florida (Mr. Alan Johnson, ProgramSnist?ator of wI?er
Facilities: 904/444-8380).	* Administrator of water

aPr5S?S™ SLr?vy.f"„ld„«Xpan*io°	the City must make

(iisnnaal/reuap activitv flflSoriaLn uitw?6	t'le current and proposed

S?r"id^UKs^iI^urS^th the SE Afield, as well as £, other

Note: In addition to the coordination discussed in this Chapter 5, two
additional -informal" (outside NEPA DEISS comment period) comment letters are
included and addressed in this FEISS. These letters were received from the Leon
County Board of County Commissioners dated July 15, 1992, and from the.City of
Tallahassee dated October 27, 1992, and are appended to the "Project Updates
Summary" chapter, which follows the "Executive Summary" of this FEISS.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IV

J4S COURT LA NO STRICT
ATLANTA, OCORCIA J01«3

NOV 1 5 19^0

Mr. John Gray
Route 16, Box 8055
Tallahassee, FL 32310

RE: Soils Letter Referenced in Tallahassee Public Hearing Comments
Dear Mr. Gray:

As you recall, you provided verbal comments at the public hearing for
the Tallahassee-Leon County Wastewater Management Draft Environmental
Impact Statement Supplement (DEISS) on August 9, 1990* in Tallahassee,
Florida. In your comments, you referenced a soils letter that you
sent to EPA. Unfortunately, we have no record of your letter in our
files. Therefore, we request that you resubmit your letter to us
within ten days of the date of this letter. Your letter will be
useful in the preparation of our response to your public hearing
comments.

Thank you for attending and participating in the public hearing. We
look forward to receiving your resubmittal.

Sincerely,

Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch

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CHAPTER 6

UST OF PREPARERS

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CHAPTER 6 LIST OF PREPARERS

U.S. Environmental Protection Agency, Region IV

Heinz J. Mueller/Robert C. Cooper/

Robert B. Howard

Christian M. Hoberg
Cory w. Berish, Ph.D.

Maryann S. Gerber

Gannett Fleming Environmental Engineers, Inc.
Thomas M. Rachford, P.E., Ph.D.

Albert T. Bain
Marintha K. Bower, P.E.

Mark A. Malarich
Xiaoqing Wu
Leif Rowles
Cy Whitson
Steven B. Deck
Sally Holbert

ERM - Southeast, Inc.

Glenn Taylor
Frank Gheesling

Heather Good
Jim Orr
Hap Reed

Eshelman
Martinson

chief, Environmental
Policy Section

Current Project Monitor

Prior Project Monitor

Previous Project Monitor

Program Manager
Project Director
Environmental Engineer
Environmental Engineer
Environmental Engineer
Environmental Engineer
Biologist/Ecologist
Environmental Scientist
Environmental scientist

Program Manager

Project Director, Env.
Scientist

Land Use Planner

Biologist/Ecologist

Hater Resource
Specialist/Geologist/
Soil Scientist

Institutional Analyst

Institutional Analyst

6-1

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APPENDIX A

ALTERNATIVE WASTEWATER
CONVEYANCE CONFIGURATIONS

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APPENDIX A ALTERNATIVE WASTEWATER CONVEYANCE CONFIGURATION

Section A-l Treatment South

This conveyance component assumes that treatment would take place at
the existing LBR Plant and T. P. Smith Facility. The elements of this component
are presented below:

1.	construct a pump station west of Ox Bottom Lake to service the
area between Meridian Road (FL 155) and Thomasville Road (U.S.
319) . Run a force main along Ox Bottom Road and connect it to
the existing interceptor south of Lake Killearn.

2.	Expand the Northeast Pump station to service the Lake
Killearn development area.

3.	Construct a force main along Centerville Road (U.S. 151) from
the Northeast pump station to Capital circle, N.E. (U.S. 319).
Continue the force main along Capital circle, N.E./S.E./S.W.
to the T. P. Smith Facility.

4.	construct a pump station southeast of Buck Lake to service
Buck Lake development area. Run a force main along Buck Lake
Road to Capital Circle, N.E. to join with a proposed force
main leading to T.^ P. smith Facility.

5.	Construct two pump stations, force mains, and interceptors to
service the proposed Southeast Lake Jackson area development.
Run a force main to the existing interceptor leading to Pump
Station No. 22.

6.	Construct a gravity relief sewer from the Capital circle,
N.E./ Lonnbladh Road intersection to existing Pump Station No.
22 to alleviate surcharge conditions.

7.	Construct a pump station north of the Federal correctional
Institute with a force main leading to a proposed force main
along Capital circle, N.E.

8.	construct a relief force main from the expanded Pump Station
No. 22 to a proposed pump station north of the Federal
Correctional Institute.

9.	construct a pump station along Perry Highway (U.S. 27) in the
Lafayette area to serve the area east of capital circle, N.E./
S.E., between the railroad and St. Augustine Road. Construct
a force main along Perry Highway to Capital Circle, N.E./S.E.
to join with a proposed force main leading to T. P. Smith
Facility.

10.	Construct a gravity relief sewer parallel to the existing
gravity sewer serving the central inner city area near Florida
A&M university to alleviate surcharge conditions entering the
LBR Plant.

11.	Construct a gravity relief sewer along the existing gravity
sewer tributary to the Springhill Road pump station to handle
projected flows from Springhill Road service Area.

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12.	Construct a pump station off Monroe street (U.S. 27), south of
the 1-10 interchange. Construct a force main to the existing
interceptor leading to Pump station No. 36.

13.	Construct two pump stations to serve the development along the
Megginnis Arm of Lake Jackson, construct a force main to the
existing Pump station No. 43, directly south of the Monroe
Street/I-10 Interchange.

14.	Construct two gravity interceptors running north to south:
one west of Old Brainbridge Road (FL 157) and the other along
capital Circle, N.w. (FL 263) to serve the proposed
development in the western portion of Tallahassee, north of
New Quincy Highway (U.S. 90).

15.	Construct a pump station adjacent to Capital Circle, N.W. near
Gum Road to transport sewage collected by the two interceptors
noted in Item No. 14. Construct a force main along Capital
Circle, S.W. to the T. P. Smith Facility.

16.	Construct two pump stations in series along Capital Circle,
s.w. near the Tallahassee Municipal Airport. construct a
force main and interceptor to the existing Pumping Station No.
12 off LBR Plant near Black Swamp.

17.	Expand Pump station No. 12 and construct a new force main to
parallel the existing force main along LBR Plant and leading
to the Springhill Road Pump station.

18.	Expand Springhill Road Pump Station.

(Note: Also see descriptions of Alternative 1 in this FEISS, including
the "Project Updates summary" chapter.)

Section A-2 Treatment North and South

This conveyance component assumes that treatment would be located at
the existing LBR Plant and the T. P. smith Facility and that a new ne plant would
be constructed in the northeast area of Tallahassee. The elements of this
component include elements 1, 2, 5, 6, and 10 through 18 of the Treatment South
conveyance component described in the previous section. in addition, this
component contains elements to convey flows to the new NE plant which include:

1.	Construct the force main from the expanded Northeast Pump
Station, south to the proposed NE Plant north of 1-10.

2.	Construct a pump station along perry Highway (U.S. 27) in the
Lafayette area to serve the area east of Capital circle,
N.E./S.E. between the railroad and St. Augustine Road.
Construct a force main along Perry Highway to Capital circle,
N.E./S.E. Continue the force main north on Capital circle,
N.E. to the proposed pump station north of the Federal
correctional institute.

3.	Construct a pump station north of the Federal Correctional
institute to serve the proposed development south of Mahan
Drive (U.S. 90) and east of Capital Circle, N.E. Construct a
force main along Capital circle, N.E. to Mahan Drive, east on
Mahan Drive, north on Edenfield to Miccosukee Road (FL 146),
and north on Miccosukee Road to the proposed NE Plant.

4.	construct a pump station southeast of Buck Lake to serve the
Buck Lake development area, construct a force main north to
Mahan Drive to join with the proposed force main leading to
the proposed NE Plant.

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APPENDIX B

ALTERNATIVE WASTEWATER
TREATMENT CONFIGURATIONS

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APPENDIX B ALTERNATIVE WASTEWATER TREATMENT FACILITIES

Section B-l Lake Bradford Road Wastewater Treatment Plant

The LBR Plant improvements of component Tl were proposed in the City MSP.
The improvements are to increase the facility's influent flow to match its design
capacity of 4.5 mgd and to install equipment which will reduce the volume of
sludge produced. The items included in the improvement are as follows:

•	Modify influent diversion structure to allow higher flows at night.

•	Add equipment to make bar screen and grit chamber operation
automatic.

•	Add flow equalization tank to store excess flow to be pumped through
plant at night.

•	Upgrade influent pump station for peak flow of 6.75 mgd with two
pumps operating and third pump for standby.

•	Add sludge thickener.

•	Upgrade effluent pump station to match effluent pumps.

•	Expand sewer division headquarters.

Section B-2 T.P. Smith Wastewater Treatment Facility

The TPS Plant expansion of component T2 was also proposed in the City MSP.
This expansion increases the design flow from 20 mgd to 27.5 mgd and includes
improvements recommended by the operation and maintenance staff. The items
included in the expansion are as follows:

•	Add new 27.5 mgd headwords with grit and screening removal and odor
control.

•	7.5 mgd activated sludge expansion with Biological Nutrient Removal.

•	Add new anaerobic digester.

•	Expand sludge thickening unit with blending tank and odor control.

•	Add new building for operations center and shop.

The expansion, along with the upgrading of the LBR Plant, is to accommodate
all sewage flows generated, including flows from the Northeast service area.
Conveying untreated flows from the Northeast could present special problems as
discussed previously in Section 2.3.2. Since expanding an existing plant, in
this case the TPS Plant, is much lower in costs and environmental impacts than
the construction of a new plant, the additional costs incurred for conveying
untreated sewage over a long distance are balanced by the cost savings of not
building a new treatment facility. This would not have been the case with a
proposed Southeast Treatment Plant which would have included both the additional
conveyance costs and the costs of a new facility.

(Note: The City of Tallahassee has completed an expansion of the T.P. Smith
Plant from a design capacity of 20.0 mgd to 27.5 mgd in January 1993).

Section B-3 Northeast Wastewater Treatment Facility

The NE Plant construction of component T3 includes facilities to treat 5.2
mgd using conventional activated sludge units with chlorination, anaerobic
digestion and mechanical dewatering. The level of treatment to be reached is
secondary. The phosphorus removal option includes the replacement of the
conventional activated sludge aeration system with a biological phosphorus
removal activated sludge system.

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APPENDIX C

ALTERNATIVE WASTEWATER
DISPOSAL FACILITIES

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APPENDIX C ALTERNATIVE WASTEWATER DISPOSAL FACILITIES

This appendix summarizes various alternative wastewater disposal
facilities. The permitting guidance outlined for the alternatives presented is
very general and is not intended to be used to make final decisions on the
applicability of the NPDES or sludge regulations, site specific conditions are
always important factors in making these determinations.

Section C-l SE Agricultural spray Irrigation

The expansion of the City's existing SE Sprayfield is proposed as part of
the preferred alternative (Alternative 1: See Chapter 4). Both an Eastern
Expansion area and a Western Expansion area are proposed in Alternative 1;
however, the USEPA understands from the City that the City only proposes near-
future construction for the Eastern Expansion area.

East of the existing SE Sprayfield is an area of land owned by the St.
Joseph Land and Development Company that is approximately 1,830 total acres in
size. The topography and soils on this proposed site, which is the disposal
component Dl, are significantly different from the existing SE Sprayfield. The
proposed site is traversed by two drainage features and another low-lying
drainage area is located on the common border between the proposed and existing
sprayfields. Due to a high water table and slow drainage characteristics, the
soil within the drainageways are not suitable for spray irrigation of wastewater.

The Florida criteria for land application of domestic wastewater residual
(treated effluent) establishes application rates based on the nitrogen
requirements of the site vegetation. The analysis procedure in Chapter 6, USEPA
"Process Design Manual for Land Application of Municipal sludge," may be used to
justify higher application rates. Application rates established for the
alternative wastewater disposal facilities are based on existing agricultural
spray irrigation operations, nitrogen requirements of vegetation, water-tolerance
of crops, soil permeability, and water table depth. In general, irrigation rates
should not exceed State of Florida permit conditions. The City's existing SE
sprayfield is permitted for 3.16 inches of wastewater effluent per week.

Based on the 1981 Soil survey (USDS [SCS], USES) the soils of the Eastern
Expansion Area sprayfield site proposed by the City are dominated by Ortega Sand,
Kershaw sand with a 0-5% slope, Talquin Fine Sand, Chipley Fine Sand and Kershaw
Sand with a 5-8% slope, respectively (Fig. 4-1). of these, only the Kershaw
sands are classified in the Soils Survey as favorable for septic tank absorption
fields (classified as "slight," i.e., having favorable soil properties for the
activity).

Of the portions of the proposed Eastern Expansion Area sprayfield proposed
for irrigation, irrigation areas associated with and adjacent to Areas A, B, and
D (see Figure 4-2 in Chapter 4.0 of this FEISS) primarily contain Kershaw Sands
while irrigation areas associated with and adjacent to Areas C and E primarily
contain Ortega Sand. As indicated, Kershaw Sands are considered suitable soil
types for septic tank absorption fields while Ortega Sand would not be favorable
due to poor filtration capabilities (too well-drained sands).

Because of the filtration limitations of the Ortega sand in the proposed
irrigation areas associated with and adjacent to Areas C and E as well as some
unfavorable soils interspersed in irrigation areas associated with and adjacent
to Areas A, B and D, the USEPA recommends reduced irrigation application
(inches/week) in these areas. If monitoring exhibits compliance with State of
Florida groundwater quality standards and monitoring is conducted to the
satisfaction of the State of Florida, additional application can be tried if
commensurate with groundwater quality compliance. Groundwater monitoring is also
essential since the entire Eastern Expansion Area lies in the Woodville Karst

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Plain, i.e., Karstic geology that is subject to water dissolution and collapse
(sinkholes). In any areas of collapse, irrigation should be stopped immediately
in those areas and the state of Florida notified. The USEPA recommends that no
effluent be sprayed in a reasonable surrounding area of the existing sinkhole
depressional area located within the proposed fixed head irrigation area adjacent
to Area D, as well as any other potentially discovered sinkhole areas (See Fig.
4-1). The USEPA further recommends that the state of Florida consider the
existing soil characteristics and Karstic conditions of the proposed Eastern
Expansion Area in their permitting decision for the City's proposed sprayfield
expansion.

Although the Western Expansion area of preferred Alternative 1 is not, as
indicated above, proposed by the city for near-future construction, it may be
noted that this area is characterized by Kershaw Sands based on the Leon County
soil survey (USDA [SCS] and USFS, 1981). As indicated above, the Kershaw Sands
have excellent drainage and filtration characteristics.

An analysis by the city's consultant revealed that approximately 909 acres
would be available for irrigation at the proposed Eastern Expansion area of the
existing SE Sprayfield. It is expected that 414 acres would be in center pivots
and 495 acres would be irrigated by fixed-head sprinklers. Application at a
uniform rate of 2 inches per week would dispose of 7.0 mgd. Application of 2.5
and 3 inches per week would result in the disposal of 8.8 and 10.5 mgd,
respectively. This effluent flow assumes total utilization of the available land
area. The type of application system can affect the utilization of the available
land and, therefore, the amount of water treated, and would need to be considered
during final design.

The proposed vegetation management activity on the Eastern Expansion Area
is an agricultural crop rotation similar to the existing SE Sprayfield.
Vegetation management on the agricultural based system currently operated by the
city has been carried out by the Pascuna Florida Corporation for several years.
This farm management system has operated satisfactorily and no changes are
recommended by evaluations performed for the EIS Supplement, interviews with the
manager of the SE Sprayfield operations indicated that a particular land area
would be managed under one of two crop rotation schedules. The first is a three-
crop per year rotation of corn, soy beans, and annual rye grass, while the second
rotation schedule would include soy beans, canola, and annual rye grass.

The crops may only be used as animal feed and/or as processed human food
to the extent consistent with chapter 17-610 F.A.C. Utilization of the crops is
not intended for direct human consumption. Each land management area of the
existing sprayfield has the crop rotation schedule switched each year. The
facilities and equipment required to utilize the proposed SE Sprayfield expansion
are minimized due to its close proximity to the existing SE Sprayfield. in
general, the following would be required:

•	Effluent holding pond and pump station at the proposed SE
Sprayfield expansion site,

t Effluent irrigation equipment,

•	Farm equipment and facilities, and

•	Groundwater monitoring wells.

Aspects of effluent disposal through agricultural spray irrigation at the
proposed expansion of the City's existing SE Sprayfield would be subject to NPDES
permitting if point source storm water discharges to waters of the United States
exist during the construction of the Alternative 1 sites and from the treatment
plants actually treating the spray irrigation effluent.

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Pursuant to the existing NPDES permitting program (40 CFR Parts 122 and
124) and to the "NPDES Permit Application Regulations for Storm Hater Discharges"
(55 FR 47990 dated November 16, 1990), an NPDES permit is required for point
source storm water discharges to waters of the United States from the facility
actually treating domestic wastewater. This provision applies to domestic
wastewater treatment facilities that have design flows of at least 1.0 mgd. The
NPDES storm water regulations of November 16, 1990, also require that point
source storm water discharges to waters of the United States from all
construction activities (including the initial clearing, until revegetated, of
spray irrigation sites) disturbing a total of five or more acres must be
permitted under the NPDES program. The permit application deadline for these
discharges is 90 days prior to commencement of construction. Construction
activities needing NPDES permit coverage can be made through a general permit
recently issued by EPA/Region XV.

Relevant to NPDES permitting for Alternative 1, application for an NPDES
permit would need to be made by the City for point source storm water discharges
to waters of the United States from regulated treatment facilities actually
treating domestic wastewater under the above-noted criteria. Application by the
City for a separate NPDES permit would also be needed by the above-noted deadline
for point source storm water discharges to waters of the United States for all
construction sites associated with and actually involving the effluent land
application site (including the initial clearing, until revegetated, of the
proposed Eastern Expansion area of the SE sprayfield and the proposed Western
Expansion area (if implemented) of Alternative 1) disturbing a total of five or
more acres of land. These permit requirements would be relevant for Alternative
1 as well as any existing unpermitted city sites.

Storm water point source discharges to waters of the United States from the
operation (spray irrigation) of non-agricultural/non-silvicultural land
application sites (such as golf courses, rights-of-way, and landscape areas)
receiving domestic wastewater treated to the quality Required by chapter 17-610
F.A.c. for the land application of reclaimed water are not required to be covered
by NPDES permits, unless the USEPA specifically requires a facility to submit an
application on a case-by-case basis. Therefore, no NPDES permit is needed for
the operation of such land application sites for the City's proposed project (if
storm water point source discharges exist to waters of the United States for such
sites) unless specifically requested by the USEPA. However, dedicated discharges
of reclaimed water, without land application, are required to be covered by NPDES
permits. It may also be noted that storm water discharges from the land
application of wastewater effluent on agricultural and silvicultural sites are
exempt from the NPDES permitting program if the sites are consistent with 40 CFR
Part 122.3(e), so that the operation of such sites for Alternative 1 would not
require an NPDES permit if consistent with 40 CFR 122.3(e). Therefore, no NPDES
permit would be needed by the City for the operation of the four golf courses (if
implemented) proposed in Alternative 1, as well as any similar existing City
application sites (if such storm water point source discharges to waters of the
United states exist at these sites). Additionally, since the land application
of wastewater effluent on agricultural sites is exempt from the NPDES permitting
program, the operation of the Eastern Expansion of the SE Sprayfield and the
Western Expansion thereof (if implemented) proposed in Alternative 1, as well as
any existing city application sites such as the SE sprayfield (if such storm
water point source discharges to waters of the United states exist at these
sites), would not require an NPDES permit if these sites are consistent with 40
CFR 122.3(e).

Included in the proposed spray irrigation of wastewater effluent in the
preferred Alternative 1 is the generation of and land application of wastewater
sludge. Section 405(d) of the clean Water Act requires that the disposal or
reuse of sewage sludge be regulated. This regulatory activity is to be
accomplished through the utilization of permits based upon technical federal
regulatory standards. The USEPA established federal sludge disposal/reuse

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standards which were promulgated in the Federal Register at 40 CFR 503 on
February 19, 1993. in general, these standards must be complied with by all
treatment works treating domestic sewage by February 19, 1994. violation of
these standards would be a violation of the Clean Water Act. It is anticipated
that current and proposed sludge disposal/reuse activities would be regulated
through an NPDES permit, where applicable, or through issuance of a "Sludge-Only"
permit. This federal permitting activity would be issued by the USEPA/Region IV
until program authorization is given to the state of Florida. Therefore, the
newly promulgated federal regulations are in addition to the State of Florida
sludge disposal/reuse regulations. Relative to Alternative 1, the City must also
make application for a Sludge Only permit for the current and proposed sludge
disposal/reuse activity associated with the SE Sprayfield and the Alternative 1
proposal, as well as any other City sludge disposal/reuse practice. These
federal regulations are in addition to the state of Florida sludge disposal/reuse
regulations.

Section C-2 NE Agricultural Spray Irrigation

To evaluate land treatment northeast of the City for component D2, land
areas generally outside of the development areas were chosen.

It appears from the 1981 Soil Survey of Leon County, Florida (USDA [SCS] and
USFS, 1981) that the northern part of Leon County is generally less suitable for
septic tank and spray irrigation wastewater disposal than the southern part.
This is not to say, however, that favorable soils for septic tanks and spray
irrigation do not exist in both northern and southern areas of Leon County or
that unfavorable soils do not exist in southern Leon County. However, the USEPA
understands that the Leon County Public Works Department apparently conducted a
spray irrigation site assessment in 1989 and determined that more acreage would
be needed to dispose the same quantity of effluent in the selected northern
alternative sites than in the selected southern alternative sites due to soil
types. This suggests a slower percolation rate at the northern sites.

This trend also generally agrees with Table 2-9 of this FEISS. when the
acreage predicted to be required for agricultural spray irrigation in the SE
(component Dl) is compared to agricultural spray irrigation in the NE (component
D2), the average acreage needed per effluent flow (mgd) is much greater in the
NE (430 acres/mgd) than in the SE (188 acres/mgd). The same trend also exists
for the NE forest irrigation site (component D4: 524 acres/mgd) compared to the
SE forest irrigation site (component D3: 197 acres/mgd). (This trend, however,
is not true in every instance since the artificial wetlands with RXBs disposal
in the SE (components Dll and D16) are predicted to require the same amount of
acreage as in the NE (components 012 and D17), i.e., Ill acres/mgd). For Table
2-9, the maximum application rate was used to estimate acreages and was based on
the soils in the 1981 Leon County Soil Survey at the given sites. However, the
USEPA recommends that soil percolation testing be conducted at any site proposed
for irrigation be implementation to determine actual soil percolation rates.

Based on the "General Soil Map" for Leon County in the 1981 Soil Survey, Leon
County is dominated by three soil associations: the Orangeburg-Lucy-Norfolk
association in the northern part of Leon County and the Kershaw-Ortega-Alpin and
the Dorovan-Talquin-Chipley associations in the southern part of Leon County.
The Orangeburg-Lucy-Norfolk soils and the Kershaw-Ortega-Alpin soils are
generally well-drained while the Dorovan-Talquin-Chipley soils are generally not
well-drained, specifically, the 1981 Soil Survey classifies the Orangeburg-Lucy-
Norfolk soils as "well drained soils" and the Kershaw-Ortega-Alpin soils as
"excessively drained and moderately well drained soils," while the Dorovan-
Talquin-Chipley soils are considered "somewhat poorly drained to very poorly
drained soils." Of the two well-drained soil associations, the depths of these
sandy associations differ significantly: the Orangeburg-Lucy-Norfolk soils are
sandy to only 20-inch depths with loam below, compared to sandy 20-40 inches deep
with loam below or are loamy throughout (Note: "loam" is a soil type that is

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defined in the 1981 Soil Survey as a mix of clay (7-27%), silt (28-50%), and sand
(<52%) particles.) By contrast, the Kershaw-ortega-Alpin soils are sandy to 80
inches or more, with some having loamy layers (lamellae) below 45-inch depths.

Regarding the suitabilities of these soil associations for septic tank
absorption fields, Table 11 of the 1981 Soil Survey presents the "restrictive
soil features" of existing soil types. All listed Orangeburg, Lucy and Norfolk
soil types are classified as "moderate: percs slowly" and/or "moderate: wetness,"
with "moderate" being defined as having unfavorable soil properties for the given
activity. The Kershaw soils are classified as "slight" which is defined as soil
properties generally favorable for the activity, oretega and Alpin soils are
classified as "severe: poor filter," with "severe" being defined as soil
properties very unfavorable for the activity. The Dorovan, Talquin and Chipley
soils are classified as "severe: wetness" or "severe: floods, wetness." These
classifications indicate that only the Kershaw soils have properties favorable
for septic tank absorption field infiltration while the others do not adequately
drain or drain too well and therefore do not provide proper filtration (i.e.,
adsorption of inorganics (metals), microbes, etc.).

considering the restrictive characteristics of the limiting soils and the
intermingled pattern of soil type occurrence, an initial application rate of
approximately 0.75 inches per week may be reasonable. However, actual soil
percolation testing should be provided at specific sites before any alternative
site is implemented.

The managed vegetation of the alternative NE Sprayfield would be an
agricultural crop rotation similar to that proposed for the Eastern Expansion of
the SE sprayfield (Refer to section c-1 above). Equipment and facilities
required for an agricultural crop is also similar to that described for the
proposed Eastern Expansion Area. However, it may be necessary to add some farm
management items since the existing farm management facilities at the SE
Sprayfield are not nearby to allow sharing.

The need for NPDES permitting for effluent disposal for this alternative
would be as described in Section C-1. The need for sludge permitting would also
be as described in section c-1. other federal, state and local permitting may
also be involved for this disposal method.

Section C-3 SE and NE Forest Spray Irrigation

An alternative to the management of an agricultural crop system at the
proposed SE and the alternative NE Sprayfields would be the establishment of a
forested system as presented in components D3 and D4. In general, forested spray
irrigation has excellent revenue-producing potential, high water-using potential,
and good nitrogen-consumption potential. The City proposes to try forest spray
irrigation on a demonstration project basis for the preferred alternative
(Alternative 1: Refer to Chapter 4) for an undetermined number of acres of the
proposed Eastern Expansion area adjacent to the city's SE Sprayfield. Forest
irrigation is being successfully used at 66 sites in the southeast, including 31
in Florida.

Vegetation management is important on a forested land treatment site, but
the intensity of management is much lower than required on a crop system. The
forested vegetation type most suited to a spray irrigation system is one that
grows well in the Leon County area and is tolerant of high moisture levels. A
fast growing southern yellow pine species such as slash pine would be well suited
for planting in the sprayfields. other species to be considered include loblolly
pine, sand pine, and pond (swamp) pine. Initial planting practices determine the
long-term viability of the trees in a spray irrigation system. To increase the
survival and viability of a newly planted stand, seedling bedding should be
considered as a part of planting.

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Forested spray irrigation systems require less vegetation management than
annual crops. Normally, when a system is installed in an area with an existing
tree stand, the existing stand can be used for treatment until harvesting. After
harvesting is complete and planting is finished, irrigation levels will need to
be reduced until crown closure occurs, approximately four to five years, so that
the root systems can become established. Once crown closure occurs, normally no
further timber stand maintenance is required until harvesting which may be 20 to
30 years depending on the product to be harvested, either pulp chips or saw
timber.

Harvesting s The periodic tree harvest and planting are important to the
operational efficiency of the spray irrigation system. To maximize nutrient
removal from the site, some type of whole tree harvesting is required. Whole
tree harvesting removes the entire standing tree (stem, branches, and leaves) so
that 100% of the nitrogen accumulated in the above-ground biomass is removed,
in addition, some whole tree harvests have utilized coarse root material. For
trees not of construction quality, it is recommended that they be skidded to a
central point at the site, then chipped and blown into a trailer. Most pulp
mills accept whole tree chips and chips can be used as a fuel/energy source.

Harvesting can be carried out by one of two methods: contract harvesting
with local harvesting companies, or providing the necessary equipment and
training for a City—employed crew, communication with the USDA FS personnel in
Tallahassee concerning harvesting practices revealed several factors to be
considered in a harvesting plan. A timber cruise prior to harvest to determine
bid volumes costs the USDA FS approximately $10 per 1,000 board feet for sizable
blocks of land (in 1989 dollars). A timber cruise on smaller parcels of land
could cost 50 percent more.

Local harvesting companies are prepared for whole tree harvesting
operations; however, harvesting constraints would reduce the bid price from these
companies. Harvesting constraints would be necessary due to the land treatment
goals of the system. Typical constraints on a harvesting contract would be
limiting inclement weather access to reduce site damage, and a contractual
agreement detailing responsibility for damage to sprinklers and associated
piping. Experienced USDA FS personnel indicated that moderate restrictions on
a harvesting activity can reduce the stumpage price by more than 50 percent.
Recent bid prices (in 1989 dollars) were $150 per 1,000 board feet for saw timer
and $30 per 100 cubic feet for pulpwood. A 50 percent or greater reduction in
these prices would significantly reduce the return on the timber product.

The other harvesting alternative would be to equip a city crew so that
harvesting could be managed under conditions which might minimize the possibility
of site disturbance and damage to the irrigation system. A capital investment
for harvesting equipment and an ongoing operation and maintenance (O&M) cost
would be necessary to provide harvesting capabilities for a City-staffed crew.
A harvesting operation can involve several pieces of equipment such as: a feller-
buncher, skidder, chipper, chip hauling vans, and a tractor rig for moving the
chip vans from the site to the wood processing plant.

Irrigation System: The general design parameters recommended for this
alternative include the following:

•	Buried, solid-set sprinklers with sprinkler and pipe spacing to
be 60 feet and 80 feet, respectively. This represents 9.138
sprinklers per acre.

•	Nozzle pressure to be between 55 and 70 psi.

•	Nozzle openings to be between 1/4 and 3/8 inch, depending on
spacing, pressure, radius of throw, and gallons per minute

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application rate. Note, no stream straightener mechanism should
be used.

•	Last filtering/screening treatment unit should ensure that the
largest particle in the wastewater is less than 1/3 of the
diameter of the sprinkler nozzle.

•	storage shall be provided for a maximum of 7 days of flow.

The application rates for this system depend on the age of the tree stands.
Generally, the system is hydraulically limited, not nitrogen limited. For an
existing, mature forest, the application rate can be as high as 3 inches per week
(the same as that for a crop system) without damaging the trees. For new forest
areas, the application rate should be about 50 percent of the peak rate, or lJj
inches per week. Currently, the FDER is concerned about the rate of 3 inches per
week being too high and subsequently contaminating groundwaters. Therefore, for
this alternative, the land area requirements were derived based on an application
rate of 2 inches per week for mature plots of trees and Hi inches per week for
newly planted plots of trees. It is recommended though that all irrigation
equipment be specified and designed to handle the higher rate of 3 inches per
week to allow for possible irrigation at that rate if it is considered no
potential threat to the groundwater quality.

It should be noted that the lower rate of 1>j inches per week is generally
recommended until crown closure occurs which can take four to five years.
Assuming that the rate to be used on the mature stands is only 2 inches per week
and that a growth of herbaceous vegetation will be allowed, it is considered safe
to use the lJj inches per week for only two years on a "new" plot.

Other items to be considered in the design of this irrigation system
include:

•	Buried main lines and laterals should have drain valves to drain
lines after applications are complete.

•	screening of the stored water is required to	avoid nozzle
clogging from debris that may fall into the	storage pond
(screening to catch particles that are greater	than 1/3 the
diameter of the nozzle).

Operations: A buried, solid-set sprinkler distribution system was
recommended because it would not interfere with forest management activities
including thinning, harvesting, and replanting. The sprinkler risers should be
high enough to raise the sprinklers above most of the understory vegetation, but
not greater that 5 feet above ground level. it is also recommended that low
trajectory sprinklers be used so that water is not thrown into the tree canopies.
The site preparation tasks consists of clearing a 10-foot wide path for each
buried lateral, construction must be carefully done to avoid excessive damage
to trees and soils. After construction, the disturbed area must be mulched or
seeded. During operation, a 5-foot radius area around each sprinkler should be
kept clear to provide for better distribution and more convenient observation of
sprinkler operation.

Forest crop management practices consist of maintaining existing forest
stands, harvesting, and reforestation. The specific tasks depend on the tree
species, age and structure of stands, method of reproduction, the terrain, and
the type of equipment and techniques used by local harvesters. The application
rate of wastewater is generally not limited by a forest's nitrogen uptake and
storage abilities. Therefore, the management practices should be designed to
optimize the nitrogen uptake. Generally, the nitrogen uptake is slow during the
initial growth stage and should be supplemented by establishing a growth of
understory vegetation and restricting the wastewater loading rate. Following the

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initial growth stage, the nutrient uptake increases and remains constant until
maturity. At maturity, the rate decreases, and therefore the trees should be
harvested. Generally, maturity of southern pines is reached at 20 to 25 years,
but harvesting can be done on a more frequent cycle.

If the selected irrigation area consists of an existing, uneven-aged
forest, the desired forest composition, structure, and vigor should be achieved
through thinning and selective harvesting. This practice optimizes the nutrient
storage and promotes reproduction growth of an understory. Recommended tree
density, in light of the irrigation process is approximately 450 to 500 stems per
acre. Thinning is usually done initially to enable construction of the
distribution system, but then should only be done once every 10 years or so to
minimize soil and site damage. Therefore, for this operation, it is recommended
that thinning be done for uneven-aged forests at the time of harvesting the
mature, marketable trees (every 10 years for a given plot). If the selected
irrigation area consists of an even-aged forest, the practice is to clear-cut the
forest at harvest age and regenerate a stand by planting seedlings. Of course,
the total irrigation area may consist of both uneven- and even-aged forests.
These forests should be divided into plots and managed accordingly.

During reforestation, maintenance could include controlling but not
eliminating the herbaceous vegetation. As stated previously, this vegetation
acts as a supplemental nitrogen sink for young forests, but if left unattended,
it could shade out the desirable forest species. If the herbaceous vegetation
is eliminated, then the wastewater application rate must be reduced during the
establishment period. Generally, the establishment period is considered the
period required for crown closure to occur which is approximately four to five
years. After crown closure has occurred for a given plot, it is recommended that
the herbaceous vegetation of the understory be harvested and removed from the
site. This is necessary to prevent the decaying vegetation from adding to the
nitrogen supply of the system.

Land Area Requirements: Land area requirements consist of acreage for the
field area, buffer zones, wastewater storage area, and area for pre-application
treatment facilities (includes screening and filtering if not done at the
treatment plant), buildings, roads, and future expansion.

The field area of the irrigation system is that portion of the land
application site to which wastewater is actually applied, including necessary
dikes, ditches, and berms.

It is recommended that the entire land application site include a buffer
zone around its perimeter. This zone is primarily for control of public access,
aesthetics, and public health protection. The buffer area is recommended to be
from 100 to 400 feet wide (depending on adjacent land uses). In general, it
should be managed as a multi-storied forest canopy by maintaining mature, tall
trees on the inside edge of the buffer next to the irrigated field area. Trees
of moderate height and with full, dense canopies should then be used beneath the
tall, inside canopy and out to the outside edge of the buffer. Evergreen species
are preferred for year-round operations.

The storage of wastewater during wet-weather conditions is essential to
avoid surface runoff due to rainfall, it is recommended that the storage pond
be designed for 7 days of storage.

The need for npdes permitting for this alternative would be as described
in Section C-l. The need for sludge permitting would also be as described in
C-l. Other federal, state and local permitting may also be involved for
this disposal method.

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Section C-4 Power Plant Cooling Water

Under alternative component D5, an average of 3.0 mgd of effluent from the
TPS Plant would be used for power plant cooling make-up water to the existing
A.B. Hopkins Generating station cooling towers. To implement this alternative
component, the level of treatment at the TPS Plant would have to be upgraded
beyond the current secondary treatment levels to include filtration and high-
level disinfection. Phosphorus removal would also be required to meet the power
plant's discharge requirement of 1.65 mg/1 as total P.

The treated effluent would be conveyed via a new force main that would have
to be constructed from the treatment plant due west to a power line right-of-way,
then northwest to the power plant, following various power line rights-of-way.
There would have to be a storage facility constructed at the power plant to store
approximately three million gallons (approximately one day's required flow).

It is estimated that the cooling tower blowdown would be less than 1.0 mgd.
Therefore, a modification of the existing NPDES permit for the Hopkins Plant
would be required if the blowdown were to continue to be discharged to a
tributary of Lake Talquin. Alternatively, other methods of disposal could be
investigated.

The need for NPDES and sludge permitting for this alternative, in addition
to the above NPDES permit modification, relate to the storm water and sludge
permitting requirements as described in Section C-l (although there would be no
spray irrigation). other federal, state and local permitting may also be
involved for this disposal method.

Section C-5 Golf course irrigation

under alternative component D6, 3.0 mgd of treated wastewater from either
the TPS Plant or the LBR Plant would be used to irrigate four (4) existing local
golf courses in the Tallahassee area. The selected golf courses would bet

•	Florida State University Golf Course,

•	Jake Gaither Golf Course,

•	Capital City Country Club, and

•	Hilaman Municipal Golf Course.

The preferred alternative (Alternative 1: See Chapter 4 and section c-l)
includes golf course irrigation at these four golf courses.

It is estimated that each golf course would use an average of 0.75 mgd of
effluent and storage of several days' flow could be accommodated in existing
ponds at the golf courses. The existing irrigation systems at the courses would
be used to distribute the reclaimed water. (Update: The USEPA understands from
the city that results from a recent (11/93), essentially final city feasibility
study regarding irrigation of the proposed golf courses and other public access
areas indicates an application rate of 0.6-0.7 inches per week (i.e., 1 mgd)).

To implement this alternative component, the level of treatment at the
discharging treatment facility would have to be upgraded beyond the current
secondary treatment levels to include filtration and high-level disinfection.
It should be noted that, without plant modification, it may be more difficult to
provide the required additional treatment at the LBR Plant than the TPS Plant due
to the age of the facility and space limitations.

A force main would have to be constructed to convey the treated effluent
to the various golf courses. If using LBR Plant effluent, there would be a
slight reduction in pipeline lengths and it would not be necessary to pump
effluent to the TPS Plant and the SE Sprayfield on a regular basis. The existing
pipeline between the LBR Plant and TPS Plant would provide an alternative

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effluent disposal route in the event that treatment levels would fall below the
requirements for use on the golf courses or rainfall was so great that additional
irrigation could not be handled at the golf courses. In any case, the force main
could be tapped at other locations in the future, such as cemeteries, parks, and
school grounds. In addition, the nutrient value of the treated effluent may
allow a reduction in the application of commercial fertilizers at the irrigated
sites.

Golf course spray irrigation has the potential for causing a localized
increase in airborne pathogens carried via aerosols. Proper treatment of
wastewaters prior to spray irrigation and selective operation times should
minimize this impact (However, although it is generally documented (Crook, 1990;
Asano et al., 1992) that wastewater treatment methods can remove significant
numbers of pathogens and non—pathogenic bacteria typically associated with sewage
wastewater, not all may be killed by disinfection. In the case of pathogens such
as viruses, the surviving numbers could potentially be hazardous from a human
health perspective since even a small number of viruses can be infectious.)

The USEPA understands from the City of Tallahassee that fecal coliform
levels are monitored by the City before effluent is spray irrigated on
sprayfields and after irrigation via groundwater monitoring. The usepa also
understands from the City that the water quality limits for fecal coliform levels
used by the City for effluent prior to sprayfield irrigation is the state of
Florida standards defining "secondary treatment" of wastewater, i.e., <200
organisms per 100 ml of effluent. Although there are no USEPA or federal
standards for fecal conforms for spray irrigated effluent, this criterion is
consistent with USEPA guidance from the Requirements Memorandum #79-3 dated
November 15, 1978 of the former construction Grants Program (USEPA, 1978). The
concepts of this memorandum were incorporated in a USEPA Technology Transfer
manual entitled "Land Treatment of Municipal Wastewater" (USEPA No. 625-1-81-013)
(USEPA, 1981). The 200 counts/100 ml of effluent criterion is uSEPA's fecal
coliform criterion for bathing (swimming) waters. It is presumed that water
considered safe enough for swimming (which could include incidental drinking)
would be .adequate for irrigation of sprayfields, particularly with vegetated
buffers. In the absence of federal standards regarding acceptable remaining
levels of fecal coliforms in sprayed effluent, the USEPA recommends that the
State of Florida the use, at a minimum, the above federal guidance (USEPA, 1981)
to help protect public health and the environment during their permitting
decision for effluent sprayfields in addition to any appropriate state of Florida
regulations (Chapter 17-640 F.A.C.) for public access areas.

The application of wastewater to golf courses and other public access areas
(unrestricted access urban irrigation areas), which would provide greater public
exposure than application on agricultural or forest sprayfields, would require
additional treatment for suspended solids removal and high-level disinfection
under state of Florida regulations, compliance with these regulations should
greatly reduce the health risks associated with aerosols at golf courses.
Irrigation of golf courses using wastewater effluent is also not an uncommon
practice since, 84 golf courses in Florida were being irrigated with wastewater
in 1991. in addition, golf course spray irrigation would require, per FDER
stipulation, that an alternate disposal method (e.g., Rapid Infiltration Basin
(RIB) system; alternate sprayfield) be made available as a back-up. It is the
USEPA's understanding from the City that such a contingency does not presently
exist for the preferred Alternative 1, which proposes golf course irrigation as
part of the effluent disposal.

storm water point source discharges to waters of the United States from the
operation (spray irrigation) of non-agricultural/non-silvicultural land
application sites (such as golf courses, rights-of-way, and landscape areas)
receiving domestic wastewater treated to the quality required by Chapter 17-610
F.A.C. for the land application of reclaimed water are not required to be covered
by NPDES permits, unless the USEPA specifically requires a facility to submit an

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application on a case-by-case basis. Therefore, no NPDES permit is needed for
the operation of such land application sites (if storm water point source
discharges exist to waters of the United States for such sites) unless
specifically requested by the USEPA. However, dedicated discharges of reclaimed
water, without land application, are required to be covered by NPDES permits.

Related to wastewater effluent disposal through golf course spray
irrigation is the generation of and land application of wastewater sludge. The
need for sludge permitting would be as described in Section c-1. other federal,
state and local permitting may also be involved for this disposal method.

Section C-6 Golf Course and State Ornamental Garden Irrigation

Under alternative components D7 and D8, 0.5 mgd of treated wastewater from
the alternate NE Plant would be used to irrigate the Killearn Golf Course and
Country Club in northeast Leon County.

Existing ponds at the golf course could be used to provide approximately
one day's worth of storage (0.5 mgd). The existing golf course irrigation system
would be used to distribute the treated effluent.

Component 08 provides for disposal of an additional 0.5 mgd of treated
wastewater from the NE Plant to irrigate the Alfred B. Maclay.State Gardens in
north central Leon County. Reclaimed water is known to have adverse effects on
some vegetation (azaleas and some tree species); therefore, an evaluation of the
plant species at the state Gardens would have to be made to determine acceptable
irrigation areas. A storage facility would have to be constructed at the state
Gardens, but the existing irrigation systems would be used to distribute the
treated effluent.

It is generally documented (Crook, 1990; Asano et al., 1992) that
wastewater treatment methods can remove significant numbers of pathogens and
non-pathogenic bacteria typically associated with sewage wastewater. However,
not all may be killed by disinfection, in the case of pathogens such as viruses,
the surviving numbers could potentially be hazardous from a human health
perspective since even a small number of viruses can be infectious. As indicated
above in Section C-5, a secondary level of treatment with filtration and
high-level disinfection would have to be provided to meet FDER requirements for
this type of reuse in public access areas, i.e., unrestricted access urban
irrigation areas. As a back-up, an alternate disposal method to golf course
irrigation would also need to be made available. These criteria would apply for
the irrigation of golf courses and would likely also apply for the irrigation of
state gardens (subject to the FDER), as they would presumably also be considered
unrestricted access urban irrigation areas by the state of Florida.

The need for NPDES permitting for this alternative would be as described
in section C-5, since golf course and state ornamental garden spray irrigation
sites are considered non-agricultural/non-silvicultural land application sites.
The need for sludge permitting would be as described in Section C-1. Other
federal, state and local permitting may also be involved for this disposal
method.

Section c-7 Power Line Right-of-Way Irrigation

Under alternative component D9, an average of 2.0 mgd of treated effluent
from the TPS Plant would be used to irrigate power line right-of-way areas south
of the treatment facility. To implement this alternative, the level of treatment
at the TPS Plant would have to be upgraded beyond the current secondary treatment
levels to include filtration and high-level disinfection.

It is assumed that an average application rate of 2.0 inches per week could
be maintained and that the power line right-of-way areas have an average width

c-ll

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of 100 feet. Therefore, approximately 26.67 miles of right-of-way would be
required to provide enough area to dispose 2.0 mgd of treated effluent. Solid
set (buried) sprinklers would be used and no storage would be required. It is
expected that the maintenance costs associated with the right-of-way areas would
increase due to the need to mow the irrigated areas more frequently.

Power line rights-of-way would presumably be considered public access reuse
areas (unrestricted access urban irrigation) by the state of Florida. As such,
special precautions in terms of effluent quality and possibly disposal method
back-up would be necessary (subject to the FDER) for irrigation of these areas
as described above in Section C-5 and C-6.

The need for NPDES permitting for this alternative would be as described
in Section C-5, since power line rights-of-way are considered non-agricultural/
non-silvicultural land application sites. The need for sludge permitting would
be as described in Section C-l. Other federal, state and local permitting may
also be involved for this disposal method.

Section C-8 Existing Sludge Disposal Field irrigation

Under alternative component D10, an average of 3.9 mgd treated effluent
from the TPS Plant would be sprayed on the existing sludge disposal fields around
the Tallahassee airport. No additional treatment would have to be provided
beyond the current secondary treatment level and basic disinfection.

it is the usepa's understanding from the FDER that the City sludge field
near the municipal airport is in compliance with the state's nitrogen application
criterion (500 pounds of nitrogen per acre per year: 500 lbs/N/ac/yr). However,
the sludge field is apparently at capacity based on FDER nitrogen level
determinations. Continued use of the sludge field, particularly given the
proposed additional effluent application on the sludge field, should be evaluated
in light of the fact that the field is at capacity. The sludge field must remain
in compliance with the State of Florida requirements.

A force main would convey the treated effluent due west from the TPS Plant
to the southwest area of the airport land for distribution to the sludge fields.
The application rate is assumed to be 2.0 inches per week. Center pivot
sprinklers would be used and storage facilities would not be required.

The effluent quality from the TPS Plant would meet FDER requirements for
this type of land application. Minimal site preparation would be required;
however, an evaluation would have to be made of the possible adverse effects that
spray irrigation may have on airport activities and adequate buffer zones would
have to be established. Also, if the irrigation was to be used to produce crops,
then coordination of the sludge disposal activities and imposition of
agricultural restrictions and crop use (to the extent consistent with Chapter 17-
640 F.A.C.) would have to be considered, while this method of effluent disposal
is practiced in other areas, regulatory acceptance of the Tallahassee area is not
completely known, although water quality aspects of the airport sludge field were
discussed by Speaker #4/9 during the USEPA Public Hearing on August 9, 1990
(Refer to chapter 5).

Groundwater monitoring ^ may be required to track the potential leachate
contamination due to the combination of sludge and effluent disposal on the same
lands.

This effluent disposal method would be subject to NPDES permitting if
sludge fields are not utilized for beneficial use (such as for agriculture to the
extent consistent with chapter 17-640 F.A.c.) and if point source storm water
discharges to waters of the United States exist at the irrigation site(s) of this
alternative. in such instances, the need for such permitting would be as

C-12

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described in Section c-1. other federal, state and local permitting may also be
involved for this disposal method.

This effluent disposal method would not be subject to the storm water
requirements of NPDES permitting if the sludge fields are utilized for beneficial
use such as agriculture. The NPDES regulations exempt from storm water
permitting, lands utilizing sludge in a beneficial manner that are not within the
confines of the facility and are in compliance with Section 405(d) of the Clean
Water Act.

•

In either case of beneficial or non-beneficial use, however, the need for
sludge permitting for sludge disposal/reuse at existing and proposed sludge
fields would be as described in Section C-1.

section C-9 Rapid Infiltration Basins (ribs)

under alternative components Dll and 012, treated effluent would be
conveyed via force main to RIBs in an area south of Tram Road and east of the
existing SE Sprayfield or to the NE disposal sites. it is expected that the
secondary treatment level and basic disinfection would be reasonably adequate
from a public health viewpoint. However, additional nitrogen removal would most
likely be required to prevent groundwater contamination. These components could
be combined with components D16 and D17, the artificial wetlands. Effluent from
the wetlands disposal components, which has a higher quality than effluent
directly discharged from secondary treatment facilities, could be directed to
RIBs for final disposal.

It is assumed that an average application rate of 10.0 inches per week
could be maintained and no storage would be required. Also, the RIBs would be
constructed as small, one-acre cells which will roughly double the total land
requirement when the buffer areas and access roadways are incorporated.
Extensive groundwater monitoring would be required along with careful
consideration of sinkhole activity in the area to prevent "short circuiting" of
the infiltration system.

Effluent disposal through the RIB method would, by itself, not be subject
to NPDES permitting if the RIBs do not drain as a point source discharge into
waters of the United States. However, pursuant to the existing NPDES permitting
program (40 CFR Parts 122 and 124) and to the "NPDES Permit Application
Regulations for Storm water Discharges" (55 FR 47990 dated November 16, 1990),
an NPDES permit is required for any associated point source storm water
discharges to waters of the United states, as described in Section C-1. However,
if the RIBs do drain as a point source discharge into waters of the United
States, an NPDES permit would be required for such discharges pursuant to the
existing NPDES permitting program (40 CFR Parts 122 and 124) in addition to
requirements for any point source discharges of storm water from the site to
waters of the United states. Other federal, state and local permitting may also
be involved for this disposal method.

Related to wastewater effluent disposal through the use of RIBs is the
generation of and land application of wastewater sludge. The need for sludge
permitting would be as described in section c-1.

Section C-10 Landscape Irrigation and Disposal in Percolation

Ponds (Redistribution)

Under alternative component D13, 1.5 mgd of treated wastewater from the TPS
Plant would be used for landscape irrigation of residential or other land in the
eastern area of the City and could also be discharged into small percolation
ponds for disposal. A 15-mile force main from the TPS Plant would parallel
Capital circle to Centerville Road, then parallel Centerville Road in a northeast
direction to interstate 10. To implement this alternative, effluent at the TPS

C-13

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Plant would have to be upgraded beyond the current secondary level to include
filtration and high level disinfection.

specific irrigation and percolation areas have not been identified, and it
has been assumed that approximately 100,000 gpd of wastewater would be used per
mile of pipeline. The force main would be tapped at various locations along its
route. A 1.5-mgd covered storage tank would be provided.

The upgraded effluent would need to meet FDER requirements for unrestricted
access urban irrigation and should not present any significant health risks. The
use of treated effluent for irrigation would replace existing and future
withdrawal of groundwater, thus conserving groundwater resources.

The need for NPDES permitting for effluent disposal through landscape spray
irrigation would be as described in Section c-5, since landscape irrigation sites
are considered non-agricultural/non-silvicultural land application sites. Other
federal, state and local permitting may also be involved for this disposal
method.

in regard to disposal in percolation ponds, if the ponds drain as a point
source discharge to waters of the United States, an npdes permit would be needed
for such discharges pursuant to the existing NPDES permitting oroqram <40 CFR
Parts 122 and 124) as described below in Section c-11.

Related to wastewater effluent disposal through the use of the landscape
irrigation and percolation pond method is the generation of and land application
of wastewater sludge. The need for sludge permitting would be as described in
Section C-l.

section C-11 Point Source Discharge to Surface Waters

The disposal of treated wastewater by discharge to surface waters is the
most common method currently used in the United states. it involves piping
treated wastewater (effluent) from the wastewater treatment facility to a
suitable body of water. This may include a creek, canal, stream, river, pond or
lake, it may also include various locations in the ocean such as bays, inlets,
channels or offshore waters. Regardless of the surface water feature chosen, th4
receiving water must be of a quality and volume to render the effluent/receiving
water mixture acceptable to established water quality standards and criteria
in addition, the effluent must meet the standards and criteria that describe the
use classification for the receiving water.

The FDER and the USEPA actively regulate the discharge of effluent to

SS&'.SU* ChaDtar Sf )\\

^	Chapter 403 of the Florida statutes sets forth surface water

qUality 8tand«ds by which surface water discharges are

Me hvdraalic-1 Lv conntete^Vo^K County area many of the surface waterbodies
nyaraulically conn®ctsd to th€ oroundw&tar /a « iinUkAia«\ tfu^

further regulated by FDER through chapter 376 of the Florida statutes' Dieooeal

aL thaU^An^^t^.id=,3"1.ViiCt,i0n*1

statute. ,^aBea^and^^rePr.a ^rvatfiorTjlct^ Sfo	V?

Department of natural Resources (TOUR). (Hot., Effective Jul? * 1993 thi°FDH»
S^ltti™?™" "or«*"iMd to	t^orida Department

in the'wunaon^slou^-Lake'^iuneon'aurfac^water^iystwn'^currentlv^ J?

major permitted effluent discharge, tc.urflc.lawr'. i	^ere "* nc

County area and none are probably likely Dartieulari« i ^ Tallahassee-Leon

disposal in the Florida jurisdictional*^^ "thi*Gu^ o'f Kco hasher

C-14

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previously been considered as an alternative for Tallahassee-Leon County.

The alternative component D14 provides options for effluent disposal by
discharge to surface waters as listed below.

•	construct a gravity/pressure pipeline from the treatment plant(s)
to one or more of the selected surface waters.

•	Dispose effluent in one of several local stream/lake
systems.

•	Dispose effluent in one of two major rivers: the St. Marks River
and ochlockonne River.

•	Dispose effluent in the Florida jurisdictional waters of the Gulf
of Mexico.

The location of the outfall lines would follow existing rights-of-way such
as roads or power lines whenever possible. The point of discharge should be
selected to maximize effluent dispersal and dilution.

Effluent point source discharges to waters of the United States would be
subject to NPDES permitting. Pursuant to the existing NPDES permitting program
(40 CFR Parts 122 and 124), an NPDES permit is required for point source
discharges to waters of the United States. In addition, pursuant to the "NPDES
Permit Application Regulations for Storm Water Discharges" (55 FR 47990 dated
November 16, 1990), requirements for any storm water point source discharges from
the site to waters of the United States would also need to be met in the permit,
as described in Section C-l. Other federal, state and local permitting may also
be involved for this disposal method.

Related to wastewater effluent disposal through point source discharges to
waters of the united States is the generation of and land application of
wastewater sludge. The need for sludge permitting would be as described in
Section C-l.

Section c-12 Deep Well Injection

Disposal of treated wastewater effluent by deep well injection, as
presented in component D15, involves the drilling of a well(s) and pumping the
effluent into a suitable geological formation. Depending upon the effluent flow
rate and the permeability/transmissivity of the receiving geologic formation,
several wells may be required at different locations. The receiving formation
must also be of a use classification that is compatible with the effluent
quality.

The USEPA/Region IV has delegated (1983) the Deep Well Injection Program
to the State of Florida (FDER) for Florida projects. The FDER, through Chapters
403 and 376 of the Florida Statutes, has the primary and broadest control over
groundwater quality. The Northwest Water Management District (WMD) has authority
over consumptive use of groundwater as provided in Chapter 373 of the Florida
Statutes. There is also a provision in Chapter 373 that allows local governments
to establish regulations equal to or more stringent than the FDER's regulations.

The FDER chairs a Technical Advisory Committee (TAC) that reviews and
provides recommendations for applications for Class I facility deep well
injections in Florida. In addition to the FDER, the TAC consists of
representatives of the USEPA/Region IV, WMD and the United States Geological
Survey (USGS), and also includes a local public health representative. The FDER
has the option to accept or refuse the recommendation(s) of the TAC members.

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The USEPA (1978) reported that no acceptable geologic formations were
located at practical depths in the Tallahassee-Leon County area. Concern still
exists as to whether the confining layers of the Floridan Aquifer are continuous
enough to protect this potable water aquifer. other potentially suitable
geological formations located below the Floridan Aquifer would be at depths
ranging from 3,500 to 5,000 feet. Apparently, there have been no attempts to
investigate the suitability of the geologic formations at this depth range,
although such depths could be feasible even though more expensive. A test well
drilled in 1977 in Gainesville, Florida showed little potential for water
disposal and the project was terminated. Also, the USGA (1979), in cooperation
with the FDER, has started that Area XI, which includes Leon County, "...is the
least suitable in Florida for waste injection."

The alternative component elements for effluent disposal by deep well
injection are as follows:

Install a test well to a depth necessary to identify a geologic
formation suitable for the injection of effluent volumes and quality
proposed by Tallahassee-Leon County.

Construct a gravity/pressure pipeline from the treatment plant(s) to
one or more well locations.

Construct the necessary number of wells to the specifications
determined by the test well, and construct the necessary surface
facilities.

The location of deep well injection facilities is mostly determined by the
effluent volumes and the permeability/transmissivity of the receiving geologic
formations. Any deep well injection receiving formation must also be vertically
isolated from freshwater zones, i.e., potential drinking water sources (<10,000
mg/1 of total dissolved solids: TDS), by an appropriate confining formation.
Wells should also logically be located near the treatment facilities to reduce
piping (costs) to the extent feasible.

Effluent disposal through this alternative would, by itself, not be subject
to NPDES permitting. However, pursuant to the "NPDES Permit Application
Regulations for Storm Water Discharges" (55 FR 47990 dated November 16, 1990),
an NPDES permit is required for any associated point source storm water
discharges to waters of the United States from the site as described in Section
C-l. Other federal, state and local permitting may also be involved for this
disposal method.

If a deep well facility has to have a discharge to surface waters during
Mechanical Integrity Tests (MIT) or in the event that the deep well injection
procedure fails, it would also be advisable to apply for an NPDES permit for
emergency discharges into waters of the United States (the need for such a permit
would be as described above in Section C-ll). An NPDES permit would not be
needed if the MIT and contingency plan discharges would not be point source
discharges to waters of the United States, unless a storm water permit would be
needed (see Section C-l).

Related to wastewater effluent disposal through deep well injection is the
generation of and land application of wastewater sludge. The need for sludge
permitting would be as described in Section c-l.

Section C-13 Artificial (Constructed) Wetlands

The criteria used to develop this component were taken from the USEPA
Design Manual entitled "Constructed Wetlands and Aquatic Plant Systems for
Municipal Wastewater Treatment."

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This alternative component considers the wastewater treatment capabilities
of artificial (constructed) wetlands. Wetlands can remove significant amounts
of Biochemical Oxygen Demand (BOD), suspended solids, nutrients, metals and
bacteria from wastewater. Their treatment efficiency is dependent upon several
variables, including:

Artificial wetlands have the same pollutant removal capabilities as natural
wetlands, without many of the potentially negative impacts. Negative aspects of
using natural wetlands can include disruption to wildlife, increased mosquito
breeding, odor generation and nutrient and sediment flushing. These aspects can
be controlled more easily in a constructed system.

There are two major types of artificial wetlands: free-water surface and
subsurface flow. The key difference is that free-water surface systems are
flooded and utilize submerged or floating vegetation while subsurface flow
systems are filled with a gravelly media and the water is kept below the surface
of the media to support emergent vegetation. The artificial wetland system
considered for this component is subsurface flow.

Subsurface flow systems are basically horizontal trickling filters with an
extensive root system in the media. These systems were developed in west Germany
and have been successfully used in Europe. Use in the United States has been
more limited. Therefore, in regions where constructed wetlands have not been
successfully tried, a pilot program should be considered prior to any full-scale
construction to more accurately predict the actual pollutant removal efficiency
of the full-scale system for the specific region.

Although still a relatively new wastewater disposal method in the United
States, constructed wetlands have shown increasing reliability in the United
states, other examples of functioning constructed wetlands are found in Orlando
(Florida), Mississippi, California, Kentucky and Alabama (the Tennessee Valley
Authority (TVA) operates facilities in Kentucky and Alabama, and possibly other
areas). The facility in Orlando has been functional for several years and
consists of marsh (bulrush and cattail) wetlands. Forested (bottomland hardwood)
wetlands were tried but were unsuccessful.

The sizing and design of a wetland treatment system is dependent upon the
type of treatment desired. A wetland can be designed to remove primarily BOD,
suspended solids and metals, or it can be changed to provide more nutrient
removal. Nutrient removal is achieved primarily through vegetative uptake and
sequestering in plant tissues. Nutrient removal efficiency is a function of the
contact time between the wastewater and the plant root systems and the period of
time between plant harvests. The usepa Design Manual suggests that a detention
time of 5-7 days is needed to produce an effluent with nitrogen (as TKN) less
than 10 mg/1. BOD and suspended solids removal can be achieved with shorter
detention times. This may change for any final design, based upon the actual
method of discharge and the regulatory discharge limits.

Influent is distributed to the system through a slotted pipe which is
placed on top of a coarse stone discharge area. From there, the wastewater flows
through a 30-inch deep gravelly sand mixture (maximum 10% of particles with 8 mm
diameter) that is planted with bulrushes, an herbaceous wetland species (Juncus)
that grows in clumps. The media is lined with an artificial or compacted clay
liner with a permeability of 1x10"® meters/second. The entire system has a slope



wetland type
Vegetation

Filtration media (soil)
Influent characteristics
Wastewater flow
Temperature
Detention time

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of 1.5 percent from the influent end to the discharge point. Discharge is
through another coarse stone filter and slotted collection pipe.

The wetland facility can be divided into multiple cells to provide better
O&M characteristics. Higher temperatures and biological activity in the summer
should allow for the use of only selected cells, permitting harvesting and
maintenance of other cells. The areas set aside for wetland facilities must
include an area to allow for harvesting and maintenance functions between the
individual wetlands. As stated above, this component is designed to be planted
with bulrushes. An alternative to the use of bulrushes is the design of a more
complex wetland that includes the use of more diverse vegetation. This
vegetation can include cattails, reeds, and woody, long-lived plants including
wetland trees and shrubs. The more diverse the vegetation, the less dependent
the wetland's removal efficiency is on one particular plant species.

Discharge from the wetlands can be through one of four methods. The first
method involves elimination of the effluent collection pipe discussed previously
and allowing sheet flow into a natural wetland or stream. The second method
involves collecting the effluent in a pipe and discharging it as a point source
into a stream. The third alternative is pipe collection and discharge into rapid
infiltration basins. This provides groundwater recharge and removes the surface
discharge. The fourth alternative is pipe collection and spray irrigation.
Under this alternative the wetlands provide additional treatment capacity and the
stream discharge is eliminated. The drawback to this alternative is the large
total land requirement.

Treatment efficiency of artificial wetlands varies. However, the USEPA
Manual lists the BOD and suspended solids percent reductions for two subsurface
flow wetland systems in Maryland and Australia. The average BOD removal
efficiency of these two systems is 78 percent. Suspended solids removal averages
82 percent. Nitrogen removal is said to range from 25 to 85 percent for
constructed wetlands. Given the 7-day detention time used here, an estimate of
50 percent nitrogen removal could be expected. Phosphorus removal is typically
less than nitrogen removal. The National Space Technology Lab studies conducted
in the late 1970 's have reported phosphorus removal in the range of 28 to 57
percent.

Effluent disposal through the artificial (constructed) wetlands method need
not, by itself, be subject to NPDES permitting if the wetlands do not drain as
a point source discharge into waters of the United States. However, pursuant to
the "NPDES Permit Application Regulations for Storm Hater Discharges" (55 FR
47990 dated November 16, 1990), an NPDES permit is required for any associated
point source storm water discharges to waters of the United States as described
in Section c—1. if the constructed wetlands do drain as a point source discharge
into waters of the United States, an NPDES permit would be required for such
discharges plus requirements for any discharges to waters of the United states
of storm water from the site, as described in Section c-11. Other federal, state
and local permitting may also be involved for this disposal method.

Related to wastewater effluent disposal through the use of artificial
(constructed) wetlands is the generation of and land application of wastewater
sludge. The need for sludge permitting would be as described in Section c-1.

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APPENDIX D

ALTERNATIVE SLUDGE
TREATMENT AND DISPOSAL
FACILITIES

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APPENDIX D ALTERNATIVE SLUDGE TREATMENT AND DISPOSAL FACILITIES

Section D-l Land Spreading

Solids generated during wastewater treatment are stabilized by
aerobic and anaerobic digestion, thickened to reduce the volume of sludge, and
disposed by land application. The city currently disposes the majority of its
sludge by landspreading it in liquid form on land the City owns around the
municipal airport. This sludge field is apparently currently at capacity, based
on FDER nitrogen determinations. The remainder of the sludge is dewatered on
belt filter presses and applied to land around the T. P. Smith Facility or on the
sprayfield adjacent to the T. P. Smith Facility. Total land available for sludge
application is currently 806 acres.

Based on operating experience at the T. P. Smith Facility and LBR
Plant, the City generates approximately 0.36 dry tons of sludge per mgd of
wastewater treated. The stabilized sludge total nitrogen content has averaged
approximately 6.1 percent. Future sludge production is estimated to be 4,070 dry
tons per year with a resulting total land requirement of 1,210 acres for the
planning year 2 010. The City would have to obtain additional acreage for
landspreading (currently has a total of 806 acres) to handle the projected sludge
production levels. For the purposes of developing this alternative component,
it was assumed that the City would continue to use the land around the T. P.
Smith Facility and SW Sprayfield for dewatered sludge disposal and an expanded
airport site for liquid sludge disposal. sludge generated at any proposed
wastewater treatment plant (e.g., NE Plant) would be disposed in liquid form on
land adjacent to the effluent disposal site.

Section D-2 Pelletization

An alternative sludge handling and disposal option considered for the
County area is the use of the heat drying/pelletization process. The process of
heat drying dewatered sludge involves exposing the sludge to hot gases, thereby
producing a dried sludge containing 10 percent or less moisture content. The
final product resulting from heat drying is a small sludge pellet or bead that
has been sold in portions of the United States as a soil conditioner and
supplemental soil nutrient source.

The fertilizer value of the sludge pellet would be approximately the
same as the dewatered sludge, but conveyance, transportation and application of
the pellets would be easier. The overall mass and volume reduction achieved
through pelletizing would reduce the number of truck trips from the treatment
plant to the land application sites. The area required for on- or off-site final
product storage would also be less than the dewatered sludge. However, the land
area required for final disposal of the pellets is the same as that required for
dewatered or liquid sludge.

The heat drying sludge process considered for the Leon County area
is the direct rotary dryer unit system. Mechanically dewatered sludge at 2 0
percent total solids content is added to a mixer and blended with previously-
dried sludge. The blended sludge is then fed to a rotary dryer. The number of
dryers needed depends on the volume of sludge produced. Each dryer would be a
3-in-l drum design, 12.5 feet in diameter and 42 feet long, within the dryer,
the sludge moves forward through a center cylinder, then back through an
intermediate cylinder and forward through another cylinder toward a fan on the
discharge end. Heated air would be provided by a furnace which would burn
natural gas, fuel oil, or other fuels such as digester gas, wood, or coal.
Typical dryer inlet temperatures would be 800° F and sludge outlet temperatures
would be about 180° F. Although the sludge temperature is too low to destroy
organic matter, the process does reduce the level of pathogens present in the
sludge, thus allowing the pellets to be sold without restriction as to pathogens.

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After passing through the rotary dryer, the sludge is introduced to
a product sizing cyclone separator where entrained solids are removed from the
offgas. The spent gases then go through an air pollution control system for
deodorization and particulate removal. Facilities required for the pelletization
process include the feed sludge/recycled dried sludge mixing system, furnaces,
rotary dryers, product sizing devices, product storage silo, odor and fugitive
dust controls, and a separate building to house the process.

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APPENDIX E
GLOSSARY

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APPENDIX E GLOSSARY

Aerosols - A suspension of colloidal solid or liquid particles in air and gas,
having small diameters ranging from 0.01 to 50 microns.

Area Systems - Wastewater Management facilities with design average daily flows
less than 500,000 gpd. FDER refers to these facilities as Type XI (flows between
100,000 and 500,000 gpd) and Type in (flows between 2,000 and 100,000 gpd).

Bedrock - The more or less solid rock that underlies the soil and other
unconsolidated material or that is exposed at the surface. it may be soft,
medium or hard and have a smooth or irregular surface.

Biochemical Oxygen Demand - Measure of the concentration of organic impurities
in wastewater. The amount of oxygen required by bacteria while stabilizing
organic matter under aerobic conditions, expressed in mg/1, is determined
entirely by the availability of material in the wastewater to be used as
biological food, and by the amount of oxygen utilized by the microorganisms
during oxidation. Usually referred to as BOD.

BOP - See Biochemical Oxygen Demand.

Bonifav soil Series - USDA scs soil series with soils that are fine sand, nearly
level to gently sloping, and well drained.

Borings - Cylindrical samples of a soil profile used to determine infiltration
capacity.

Bulrushes - Members of the genus Scirpus and are perennial, grass-like herbs that
grow in clumps. They are capable of growing well in water that is 2 inches to
10 feet deep. Desirable temperatures are 61 to 81 °F and desirable pH range is
4 to 9.

Centralized (wastewater collection and treatment! Svatem - Refers to a system
with large regional facilities. The collection system would be a network of
pipes (generally servicing most customers of a given governmental jurisdiction)
that conveys flows from the sewage source to one or two major "centrally" located
facilities. Facility planning, construction, operation, and maintenance tasks
are normally the responsibility of a single government agency or authority.

channel - A natural or artificial watercourse with a definite bed and banks which
confine and conduct continuously or intermittently flowing water. See
••Watercourse" .

chemical Oxygen Demand - A measure of the oxygen equivalent of that portion of
organic matter that is susceptible to oxidation by a strong chemical oxidizing
agent. Usually referred to as COD.

COD - See chemical Oxygen Demand.

codv Scarp sandhills - A physiographic region characterized by dry, mostly low
sandhills over limestone, allowing moderately rapid recharge of surface water to
the Floridan Aquifer. It has small, circular lakes, but only two intermittent
channels. Native vegetation was longleaf pine - turkey oak forests, but is now
pine plantation.

confining Layer - A geological layer including low permeable soil, bedrock, and
water table, that prohibits the flow of liquid.

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Decentralized (wastewater collection and treatment) system - Refers to a system
with a multitude of facilities. The facilities generally include various
combinations of single-customer on-lot systems and small collection and treatment
systems (e.g., package plants) servicing a cluster of customers (e.g., a
residential subdivision, shopping center, industrial park, or office complex).
Facilities planning, construction, operations, and maintenance tasks are normally
the responsibility of the individual customers or a private entity.

Dothan Soil Series - USDA SCS soil series with soils that are loamy fine sand,
nearly level to sloping, and well drained.

Ecotone - The transition area between distinct habitat/community areas such as
wetlands, grasslands and forests.

Emergent Plants - Aquatic plants that are rooted in the sediment but whose
leaves are at or above the water surface. These wetland plants often have high
habitat value for wildlife and waterfowl, and can aid in pollutant uptake.

Erosion - The removal of soil particles or rock fragments of the land surface
by the action of running water, wind, ice, or other geological agents.

Eutrophication - The process of over-enrichment of waterbodies by nutrients
often typified by the presence of algal blooms.

Evapotranspiration - The combined loss of water from a given area and during a
specific period of time, by evaporation from the soil surface and by
transpiration from plants.

Faceville Soil Series - USDA SCS soil series with soils that are sandy loam,
strongly sloping on upland, and well drained.

Field Area - The "wetted area" where treatment/disposal occurs in a land
application system.

Floodplain - The nearby level land area situated on either side of a channel
which would be inundated temporarily by overflow waters caused by storm water
runoff.

Florida Department of Environmental Protection (FDEP) - The FDEP is the State
of Florida agency that regulates spray irrigation permitting for proposed
projects in Florida. Effective July 1, 1993, the Florida Department of
Environmental Regulation (FDER) and the Florida Department of Natural Resources
(FDNR) were reorganized to form the FDEP.

Fuquav Soil Series - USDA SCS soil series with soils that are fine sand, nearly
level to sloping, and well drained.

Groundwater	Recharge - Replenishment of existing natural underground water

supplies.

Heavy Metals - Metals, including nickel, manganese, lead, chromium, cadmium,
zinc, copper, iron and mercury, that exist in trace quantities in wastewater.
Some of these metals are necessary in trace amounts for the growth of biological
life. The presence of any of these metals in excessive quantities will interfere
with many beneficial uses of the water because of their toxicity.

Horizon, Soil - A layer of soil or soil material approximately parallel to the
land surface and differing from adjacent genetically-related layers in physical,
chemical, and biological properties or characteristics (e.g.. color, structure,
and texture) .

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Hydrogen Sulfide - A chemical compound formed from the decomposition of organic
matter containing sulfur or from the reduction of mineral sulfites and sulfates.
It is a colorless, inflammable, highly toxic gas having the characteristic odor
of rotten eggs.

Impervious Area - A surface which prevents the infiltration and percolation of
water into the ground.

Infiltration - The flow of a liquid into a substance through pores or other
openings, connoting flow into a soil in contradistinction to the word,
percolation, which connotes flow through a porous substance. The infiltration
capacity is expressed in terms of inches per hour.

Karst - The geologic condition in which limestone is dissolved by groundwater,
forming underground voids, and resulting in surface depressions, or sinkholes.
Karstic depressions with standing water have been referred to as "live" Karstic
depressions.

Kershaw Soil Series - USDA SCS soil series with soils that are sand, nearly
level to sloping, and excessively drained.

Leaching - The removal of soluble material from soil by percolating water.

Leefield Soil Series - USDA SCS soil series that loamy sand, nearly level, and
poorly drained.

Lucy Soil Series - USDA SCS soil series with soils that are fine sand, nearly
level to sloping, and well drained.

Marsh - Wetlands that are characterized by soft-stemmed herbaceous emergent
plants, such as cattails and pickerel weed, shallow marshes are those with up
to six inches of water; deep marshes have as much as two to three feet of water.
Seasonal fluctuations in the water level may occur. The Everglades is an example
of a vast expanse of marshland.

Mottling, soil - irregular spots of different colors that vary in number and
size. Mottling generally indicates poor aeration and impeded drainage.

Mounding - (1) Filling the area for the on-lot absorptions field with suitable
soil material (usually sand) to the level above the water table necessary to meet
local and state requirements. (2) The process in which an artificial water
table is created on top of a confining layer in the ground. Over a period of
time if the water can not drain properly, the top of the water table will
approach the ground surface and create ponding problems.

Mound System - See Mounding, first definition.

Nitrogen - Chemical element usually available as ammonium, nitrite, and nitrate
ions, and certain simple amines for the growth of plants and protista. A small
fraction of organic or total nitrogen in the soil is available at any time.
Excessive amounts of nitrogen in water (usually measured as nitrate nitrogen) can
be detrimental to the health of infants.

Nonpoint Source Pollution - Pollution that enters a water body from diffuse
origins in the watershed and does not result from discernible, confined, or
discrete conveyances.

Norfolk Soil Services - USDA SCS soil series with soils that are loamy fine
sand, gently sloping to moderately sloping, and well drained.

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National Pollutant Discharge Elimination System (NPDES) Permit - A permit issued,
as appropriate, by the USEPA or by a delegated state regulating the release of
pollutants from point sources into waters of the United States.

Nutrients - Substances necessary for growth of protista and plants in water.
Most important nutrients include nitrates and phosphates. Trace quantities of
other elements such as iron are also needed for biological growth. Excessive
amounts of nutrients results in the uncontrolled growth of plant matter such as
noxious algal blooms in surface waters.

Orangeburg soil Series - USDA SCS soil series with soils that are fine sandy
loam, nearly level to strongly sloping, and well drained.

organic Matter - Plant and animal residue in the soil in various stages of
decomposition.

Ortega Soil Series - USDA SCS soil series with soils that are sand, nearly level
to gently sloping, and moderately well drained.

Pathogens - Infectious microbes such as viruses, pathogenic bacteria, and
protozoans. Most numerous pathogens in wastewater are bacterial pathogenic
organisms. Those excreted by man can cause diseases of the gastrointestinal
tract, such as typhoid and paratyphoid fever, dysentery, diarrhea, and cholera,
usually the coliform group of organisms is used as an indication of the presence
in wastewater of feces and hence pathogenic organisms.

Perched Water Table - a type of unconfined aquifer in which the waterbody is
separated from the main groundwater by a relatively impermeable stratum.

percolation - The downward movement of water through the soil.

Permeability - The quality of the soil that enables water to move downward
through the profile. Permeability is measured as the number of inches per hour
that water moves downward through the saturated soil.

phosphorus - Inorganic element that is readily available in the form of
orthophosphate for the growth of plants and protista.

Ponding - Standing water on soils in closed depressions. Unless soils are
artificially drained, the water can be removed only by percolation or
evapotranspiration.

Rapid Infiltration (Basin) System (RlBi - A disposal technique that uses land
application of wastewater treatment plant effluent. It generally consists of a
constructed land area onto which water is applied (sprinkled or spread) to
relatively porous soil at rates far in excess of normal crop irrigation (loading
rates >4 inch/week).

Renovate - in the context of wastewaters this refers to the biological treatment
of the wastewater in a constructed facility or in a natural setting (such as
wetlands or soils) to restore them to a quality standard that allows reuse of the
water.

Runoff - The precipitation discharged into stream channels from an area. The
water that flows off the surface of the land without sinking into the soils is
called surface runoff. Water that enters the soil before reaching surface
streams is called groundwater runoff or seepage flow.

Secondary Treatment Level - Wastewater treatment to a level that will achieve
the effluent limitations specified in Chapter 17-6, Part 1, Section 17-6.060
(l)(a) of FDER Rules and Regulations.

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Sedimentation - The process by which solid material, both mineral and organic,
is accumulated, having been transported by wind or moving water and deposited by
gravity. Once this matter is deposited (or remains suspended in water), it is
usually referred to as "sediment".

senescence - The annual die-back of aquatic plants at the end of the growing
season.

series. soil - A group of soils that have profiles that are almost alike except
for differences in texture of the surface layer or the underlying material. All
the soils of a series have horizons that are similar in composition, thickness,
and arrangement.

sheetflow - Runoff which flows over the ground surface as a thin, even layer,
not concentrated in a channel.

silvicultural operations - The management of forested land in order to maximize
the growth, health, and marketability of timber.

sinkhole - A depression in the landscape where limestone has been dissolved.
See Karst. Sinkholes containing water may be known as "live" sinkholes.

Soil Strata - The various horizontal layers of sedimentary rock (soil).

St. Marks Lowlands - A physiographic province which includes the present
floodplain valley of the St. Marks River, it is marked by bottomland swamps of
the St. Marks River and its major tributaries. A portion of the St. Marks River,
below Cody Scarp, is made up primarily of groundwater flow.

storm water - Runoff and drainage from land surfaces resulting from
precipitation including snow or ice melt.

storm water Management - A program of controls and measures designed to regulate
the quantity and quality of storm water from a development and/or land
disturbance while promoting the protection and conservation of groundwater and
groundwater recharge.

swamp - Wetlands that unlike marshes, are dominated by woody plants such as
trees, and shrubs. swamp soils are saturated during the growing season, and
standing water (from a few inches to a foot) is not uncommon at certain times of
the year.

Tallahassee Red Hills - A physiographic region located in the northeastern
portion of Leon County. It is a clayhills region composed of a moderately thick
layer of sandy clay over limestones. It has substantial formation of sinkholes,
Karstic depressions and valleys formed partly from solution of underlying
limestone, and contains many lakes and seasonal streams and wetlands. Most of
the limestones represent the Floridan Aquifer.

Total Suspended Solids (TSS) - Solids either floating or suspended in water,
sewage, or other liquid wastes that are removable by filtering.

Watercourse - A stream of water, river, brook or creek; or a channel or ditch
for water, whether natural or manmade. See "Channel".

Watershed - The entire region or area drained by a river or other body of water,
whether natural or man-made.

Water Table - The upper surface of the free groundwater in a zone of saturation
(indicates the uppermost extent of groundwater); locus of points in soil water
at which hydraulic pressure is equal to atmospheric pressure.

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Wetlands - The regulatory definition of wetlands according to the U.S. Army
Corps of Engineers (33 CFR Section 328.3) and the USEPA (40 CFR Section 230.3)
is "...areas that are inundated or saturated with surface or ground water at a
frequency and duration sufficient to support, and that under normal circumstances
do support, a prevalence of vegetation typically adapted for life in saturated
soil conditions. Wetlands generally include swamps, marshes, bogs, and similar
areas."

Wetlands Dredge-and-Fill Permit - Section 404 (Clean Water Act) permits are
issued, as appropriate, by the U.S. Army corps of Engineers (COE) for the filling
of jurisdictional wetlands. Mitigation for such wetland fill may be a COE permit
condition. The USEPA independently reviews individual permit applications
(and some nationwide permit applications) and provides comments to the COE.

whole Tree Harvesting - Forest management harvesting operations that involves
the removal of the entire standing tree (stem, branches, leaves, and sometimes
roots).

Woodville Karst Plain - A physiographic region located in the southeastern
portion of the County near Woodville. it is a low plain consisting of sand a few
feet thick over limestone. The entire area is a high recharge area for the
Floridan Aquifer. It is currently composed of cypress swamps and pine
plantations.

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APPENDIX F
BIBLIOGRAPHY

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APPENDIX F

BIBLIOGRAPHY

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City of Tallahassee (City). Tallahassee-Leon County, Florida 201 Wastewater
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City of Tallahassee. City of Tallahassee Sewer Division. Personal
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Leon County. Public Works Department Water and Sewer Franchise Area Maps. 1989.

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Miami-Dade Water and Sewer Authority Department. Miami-Dade West Wellfield
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Penton, Daniel T. Final Report, Leon County Wastewater Management Program, A
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Report. May 1979.

U.S. Environmental Protection Agency (USEPA). Tallahassee-Leon County, Florida,
Environmental Impact Statement (EIS) . Draft Environmental Inventory Task Report.
July 1979.

U.S. Environmental Protection Agency (USEPA). Cost of Land Treatment Systems.
EPA 430/9-75-003. September 1979.

U.S. Environmental Protection Agency (USEPA). Process Design Manual for Sludge
Treatment and Disposal. EPA 625/1-79-011. September 1979.

U.S. Environmental Protection Agency (USEPA). Tallahassee-Leon County, Florida,
Environmental Impact statement (EIS). Draft Alternatives Development Task
Report. December 1979.

U.S. Environmental Protection Agency (USEPA). Wastewater irrigation at
Tallahassee, Florida. EPA 600/2-79-151. 1979.

U.S. Environmental Protection Agency (USEPA). Innovative and Alternative
Technology Assessment Manual. EPA 430/9-7 8-009. February 1980.

U.S. Environmental Protection Agency (USEPA). Design Manual - On-site Wastewater
Treatment and Disposal systems. Technology Transfer. October 1980.

U.S. Environmental Protection Agency (USEPA). Tallahassee-Leon county, Florida
EIS, Draft Environmental Monitoring Program - Segment II - Terrestrial Survey.
November, 1980.

U.S. Environmental Protection Agency (USEPA). Tallahassee-Leon County, Florida,
Environmental Impact statement. Draft Alternatives Evaluation Task Report,
Volumes I and II. January 1981.

U.S. Environmental Protection Agency (USEPA). Tallahassee-Leon County, Florida,
Environmental Impact statement. Draft Report. September 1981.

U.S. Environmental Protection Agency (USEPA). Process Design Manual for Land
Treatment of Municipal Wastewater. EPA 625/1-81/013. October 1981.

U.S. Environmental Protection Agency (USEPA). Construction Grants 1982 (CG-32).
EPA 430/9-81-020. July 1982.

U.S. Environmental Protection Agency (USEPA). Process Design Manual for Land
Application of Municipal Sludge. 1983.

F-3

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U.S. Environmental Protection Agency (USEPA). Tallahassee-Leon County, Florida,
Environmental impact statement. Final Report. 1983.

U.S. Environmental Protection Agency (USEPA). Handbook - Estimating Sludge
Management Costs at Municipal Wastewater Facilities. EPA 625/6-85-010. October
1985.

U.S. Environmental Protection Agency (USEPA). Design Manual - Phosphorus
Removal. EPA 625/1-87-001. September 1987.

U.S. Environmental Protection Agency (USEPA). Handbook Retrofitting POTW's for
Phosphorus Removal in the Chesapeake Bay Drainage Area. EPA 625/6-87/016.
September 1987.

U.S. Environmental Protection Agency (USEPA). Tallahassee-Leon County, Florida,
Environmental Impact Statement Supplement. Scoping Report. June 19 88.

U.S. Environmental Protection Agency (USEPA). Design Manual - Constructed
Wetlands and Aquatic Plant Systems for Municipal Wastewater Treatment. EPA
625/1-88/022. September 1988.

U.S. Environmental Protection Agency (USEPA). EPA Draft Environmental Impact
Statement - Durham-Eno River, North Carolina Wastewater Treatment Plant and
Service Area. EPA 904/9-89/001a. September 1989.

U.S. Environmental Protection Agency (USEPA) . EPA Environmental impact statement
- South Baldwin County, Alabama Wastewater Management. EPA 904/9/007a. November
1990.

U.S. Environmental Protection Agency (USEPA). EPA Manual: Guidelines for Water
Reuse. Technology Transfer. EPA/625/R-92/004. September 1992.

U.S. Environmental Protection Agency (USEPA). Code of Federal Regulations.
Federal Register; e.g., 40 CFR 503 [February 19, 1993]; 40 CFR 122 and 124;
55 FR 47990 [November 16, 1990].

U.S. Fish and wildlife Service (USFWS). Jacksonville, Florida. Conversation
with Dave Martin regarding endangered species. January 1991.

U.S. Fish and Wildlife Service (USFWS). Panama City, Florida. Conversation with
Jay Troxel regarding endangered faunal species and species of special concern for
Florida. January 1991.

U.S. Geological survey (USGS). Topographic Quadrangles of Study Area. 7.5
Minute Series. 1972.

U.S. Geological Survey (USGS); James A. Miller; in cooperation with the FDER.
Potential Subsurface Zones for Liquid-Waste Storage in Florida. Map. 1979.

U.S. Geological Survey (USGS). Wastewater Application by Spray Irrigation on A
Field Southeast of Tallahassee, Florida: Effects on Ground Water Quality and
Quantity, 1980-82. Water Resources Investigations Report 85-4006. 1980-1982.

U.S. Geological Survey (USGS). Hydrologic Data From An Area Southwest of
Tallahassee, Florida, where Municipal Wastewater Effluent is Applied by spray
Irrigation. Open-File Report 83-769. 1983.

U.S. Geological Survey (USGS) . Effects on Ground Water of Spray Irrigation Using
Treated Municipal Sewage Southwest of Tallahassee, Florida. Water Resources
Investigations Report 86-4109. 1986.

U.S. Geological Survey (USGS). Estimated Use of Water in the United States in
1985. U.S. Geological circular 1004. second printing. 1990.

F-4

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U.S. Geological survey (USGS). Hydrologic Environmental Effects of Sprayed
sewage Effluent, Tallahassee, Florida. Water Resources Investigations Report.
55-75.

Wuebbles, D.J. and J. Edmonds. A Primer on Greenhouse Gases. Washington,
D.C.:99 . 1988.

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PUBLIC NOTICE

March 9, 1994

U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET, NE
ATLANTA, GEORGIA 30365

The availability of the Final Environmental impact Statement supplement (FEISS)
entitled "Tallahassee-Leon County, Wastewater Management, Tallahassee, Leon
County, Florida" is being noticed in the Federal Register on March 18, 1994, by
the United States Environmental Protection Agency (USEPA), Region IV. The Draft
Environmental Impact statement Supplement (DEISS) was noticed at 55 FR 26751 on
June 29, 1990. After issuance of the DEISS, the USEPA held a Public Bearing on
August 9, 1990, at the City Commission Chambers in Tallahassee, Florida.

The City of Tallahassee presently has not requested any federal funds to
implement the 1988 city Master Sewer Plan (MSP), nor does the implementation of
the MSP as proposed otherwise constitute a "major Federal action" under Section
102(2) (C) of NEPA, and NEPA does not mandate that an EIS Supplement be prepared.
However, this discretionary USEPA EIS Supplement provides technical guidance to
the City of Tallahassee Sewer Division as well as other local decision-makers for
facility expansion planning, since no major federal action is currently planned,
the USEPA presently does not intend to prepare a Record of Decision (ROD) for
this EIS supplement. if, however, local decision-makers should ultimately
include federal involvement in the City MSP at the level of a "major Federal
action,- the EIS Supplement (the DEISS and this FEISS) will serve to meet the
requirements of NEPA (and an ROD would be prepared), unless a significant amount
of time has passed before project implementation and significant changes have
occurred in the project as proposed, in the impacts of the project, and/or in the
project area. After appropriate examination of such considerations, the need for
a supplemental EIS to update the present EIS Supplement could be determined.

Given the nine alternatives considered and the four alternatives (1, 2, 7 and 9)
selected for further study in the EIS Supplement, the USEPA finds Alternative 1
to be an acceptable alternative. Alternative 1 is a practical alternative that
represents a continuation of the city's successful agricultural spray irrigation
approach to the disposal of treated effluent through an expansion of the city's
SE Sprayfield, as well as the irrigation of existing golf courses. As such,
Alternative 1 was considered the preferred alternative for the EIS supplement.
However, the USEPA is not requiring the implementation of Alternative 1 since the
EIS Supplement is discretionary and there are no federal funds and no major
federal action proposed for Alternative 1 (or for Alternatives 2, 7 or 9) at this
time. Unless the proposed project becomes a major federal action, the selection
of an appropriate alternative for the City of Tallahassee wastewater management
would be a local decision.

Written comments on this FEISS will be accepted by the USEPA if postmarked by the
close of the 30-day public comment period on:

APRIL 18, 1994

Comments should be addressed to Heinz J. Mueller (FAB-4); chief. Environmental
Policy section; U.S. Environmental Protection Agency; Region IV; 345 Courtland
street, NE; Atlanta, Georgia 30365. Facsimile transmittals may be sent to the
USEPA at (404) 347-5206. Although all comment letters will be retained as part
of the project file, the USEPA may choose to not formally respond to comments
received since there is no major federal action and USEPA preparation of an ROD
is not planned at this time.

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One or two copies of the FEISS are available for public review at the following
library locations!

Leon County Public Library
1940 N. Monroe Street
Tallahassee, FL 32301
ATTNi Ms. Linda Barber
(904) 487-2665

Coleman Memorial Library
Florida A 6 M University
P.O. Box 78, Room 304C
Tallahassee, FL 32307
ATTN: Ms. M.B. Crump
(904) 599-3370

Robert Manning Strozier Library
Florida State University
Dirac science Library
Tallahassee, FL 32306-2047
ATTNi Ms. Sharon schwerzel
Bead, Dirac Science Library
(904) 644-5534

Robert Manning strozier Library
Florida state University
Documents Department
Tallahassee, FL 32306-2047
ATTN: Ms. Anne Gometz
(904) 644-2706

Distribution of the FEISS and/or this Public Notice by the USEPA/Region IV
included numerous federal and state agencies, environmental groups, congressional
representatives, and individuals. This distribution included ten (10) copies to
the State of Florida clearinghouse (Ms. Janice Hatter) and twelve (12) copies to
the U.S. Department of the Interior (DOI) clearinghouse (Ms. Lillian Stone) for
their internal distribution in addition, to the USEPA's selected state of Florida
&nd doi distributions.

The USEPA/Region IV has distributed essentially all printed copies of the FEISS,
•o that none are currently available from the USEPA. However, inquires regarding
the potential availability of any extra copies of the FEISS may be made to Chris
Boberg at (404) 347-3776, FAX (404) 347-5609, or the above USEPA/Region IV
address, conversely, any distributed copies that are unwanted may be returned
to the USEPA during or after the public comment period at the above address.
However, there is absolutely no obligation to return distributed copies.

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