FINAL
WATER QUALITY PROTECTION PROGRAM
FOR THE FLORIDA KEYS NATIONAL MARINE SANCTUARY
PHASE H REPORT
U. S. Environmental Protection Agency
Oceans and Coastal Protection Division
Contract No. 68-C2-0134
Work Assignment I
February 1993

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PREPARED BY
Continental Shelf Assoc. Inc.
759 Parkway Street
Jupiter, FL 33477-4567
Battelle Ocean Sciences
397 Washington Street
Duxbury, MA 02332
Lindahl, Browning, Ferrari & Hellstrom, Inc.
10 Central Parkway, Suite 420
Stuart, FL 34994
Battelle Pacific Northwest Division
Washington Operations, Suite 900
370 L'Enfant Promenade, SW
Washington, DC 20024-2115
Battelle Seattle Research Center
4000 N.E. 41st Street
Seattle, WA 98105-5428

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CONTENTS
GENERAL INTRODUCTION
Task 2
INSTITUTIONAL AND AGENCY MANAGEMENT INVENTORY
Tasks 3 and 4
ENGINEERING, MANAGEMENT, AND INSTITUTIONAL OPTIONS
Task 5
FUNDING SOURCES
Task 6
MONITORING PROGRAM
Task 7
UESEARCH PROGRAM
Task 8
PUBLIC EDUCATION AND OUTREACH PROGRAM

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GENERAL INTRODUCTION
CONTENTS
1.0 LEGISLATIVE MANDATE AND PURPOSE		1-1
2.0 BACKGROUND		1-1
3.0 REPORT FORMAT 		1-3
4.0 REFERENCE 		1-3
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GENERAL INTRODUCTION
1.0 LEGISLATIVE MANDATE AND PURPOSE
The Florida Keys National Marine Sanctuary (FKNMS) was created with the signing of HR5909 [Public Law
101-605, Florida Keys National Marine Sanctuary and Protection Act (FKNMSP Act)] on 16 November 1990.
Included in the FKNMS are 2800 square nautical miles of nearshore waters extending from just south of Miami to
the Dry Tortugas. The Environmental Protection Agency (EPA) and the State of Florida have been directed to
develop a Water Quality Protection Program for the FKNMS. This program will be considered by the National
Oceanic and Atmospheric Administration (NOAA) for inclusion in the comprehensive management plan that will
be prepared to guide the use of the FKNMS.
The purpose of the Water Quality Protection Program is to "recommend priority corrective actions and compliance
schedules addressing point and nonpoint sources of pollution to restore and maintain the chemical, physical, and
biological integrity of the Sanctuary, including restoration and maintenance of a balanced, indigenous population
of corals, shellfish, fish and wildlife, and recreational activities in and on the water" (FKNMSP Act). In addition
to corrective actions, the Act also requires development of a comprehensive water quality monitoring program, a
research plan, and provision of opportunities for public participation in all aspects of developing and implementing
the program.
The FKNMS is the first marine sanctuary to have a Water Quality Protection Program. The establishment of such
a program recognizes the critical role of water quality in maintaining Sanctuary resources. The ecological integrity
of Sanctuary ecosystems is dependent on the maintenance of outstanding water quality, including high water clarity,
low or undetectable nutrient levels (especially in the case of coral reefs), low concentrations of xenobiotics, and
variations in other water quality parameters within the tolerance limits of Sanctuary biota.
Although the Water Quality Protection Program focuses on water quality and environmental problems, the economic
impacts of deteriorating water quality must also be considered when evaluating the cost of options for reducing
pollution. The habitats of the Sanctuary and adjacent areas, including Florida Bay and the Everglades, support an
abundance of fish and wildlife, sustain enormously valuable commercial and recreational fisheries, and attract
anglers, divers, naturalists, and other tourists from all over the world. Thus, the economy of the Florida Keys is
tied directly to resources that depend on the maintenance of Sanctuary habitats and water quality. The variety and
magnitude of recent ecological problems in the Sanctuary and adjacent areas (e.g., Florida Bay) as reviewed in the
Phase I report (EPA 1992) indicate that something is wrong and existing management actions are not adequate
to prevent continuing environmental degradation. That is, there is a significant "cost of doing nothing."
Socioeconomic aspects of all recommended corrective actions that are eventually included in NOAA's management
plan for the Sanctuary will be analyzed as part of the Environmental Impact Statement for the management plan and
are not discussed further here.
2.0 BACKGROUND
The Water Quality Protection Program has been developed in two phases. During Phase I, information on the status
of the Sanctuary's natural environment was compiled and synthesized (EPA 1992). Priority problems were
identified through this literature review and by developing consensus among twhniral experts and other participants
in technical workshops. Building on this informatioh base, Phase II focused on three goals:
•	Developing options for corrective action
•	Developing a water quality monitoring program and associated research program
•	Developing a public education and outreach program
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Phase II included seven main tasks, as outlined below, to address these three goals. Other ta*lrg involved
development of a Work/Quality Assurance Project Plan for Phase II and preparation, review, and revision of tnis
Phase II report.
DEVELOPING OPTIONS FOR CORRECTIVE ACTION
•	Task 2 — Institutional and Agency Management Inventory
Identify institutions and agencies with jurisdiction affecting water quality in the FKNMS.
•	Task 3 — Management/Institutional and Agency Options
Based on the institutional and agency management inventory (Task 2) and suggestions from agency
personnel, develop a comprehensive range of management and institutional options to reduce water
pollution and improve the existing regulatory/management system.
•	Task 4 — Engineering Options
Develop a comprehensive range of engineering options to reduce water pollution.
•	Task 5 — Funding Sources
Identify and evaluate potential funding sources for implementing corrective actions identified in
Tasks 3 and 4.
DEVELOPING MONITORING AND RESEARCH PROGRAMS
•	Task 6 — Monitoring Program
Develop a comprehensive water quality monitoring program to monitor the status of water quality
and biotic resources, determine the effectiveness of pollution controls, and redirect the Water
Quality Protection Program if necessary.
•	Task 7 — Research Program
Develop a research program to complement the Monitoring Program (Task 6) by identifying
cause/effect relationships involving pollutants, transport pathways, and biological communities.
DEVELOPING PUBLIC EDUCATION AND OUTREACH PROGRAM
•	Task 8 — Public Education and Outreach Program
Develop a public education and outreach program to promote public awareness of water quality
issues.
Separate draft reports were prepared for each Phase II task listed above, with the exception of Tasks 3 and 4 which
were combined into one report. During the preparation of draft task reports, two EPA/State of Florida workshops
were held to discuss preliminary findings and receive input from tซrhnirปl experts and the public: a
Monitoring/Research Workshop (July 1992) and an Engineering/Management Options Workshop (August 1992).
Following the workshops, draft task reports were prepared and reviewed by EPA, NOAA, and the State of Florida.
The draft reports were then revised and combined into this draft Phase II report, which will be circulated for public
comment and revised as necessary. Findings from Phases I and II will be incorporated into the Water Quality
Protection Program Document, which is the final report for this project
Options for corrective action, monitoring and research programs, and a public education and outreach program
developed during Phase II will be considered by NOAA for inclusion in the comprehensive management plan for
the FKNMS, which will address many other management concerns in addition to water quality. The comprehensive
range of options included in the Tasks 3 and 4 rcpo;t will be evaluated according to a set of specific factors and
objective criteria. This evaluation process will result in the development of the recommended priority corrective
actions that will be included in the Water Quality Protection Program Document. Therefore, the options presented
in the Phase II report should not be regarded as recommended or approved courses of action. Some may seem
obviously beneficial and innocuous, whereas others may be so expensive or controversial that they would never be
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implemented. Environmental and socioeconomic impacts of all options that are eventually incorporated into
NOAA's management alternatives will be evaluated in an Environmental Impact Statement.
3.0 REPORT FORMAT
The Phase II report is divided into separate reports corresponding to the tasks listed above (except Tasks 3 and 4,
which were combined). Appendices are provided following each task report rather than at the end of the document.
Because of the phased nature of this project, the Phase II report contains relatively few literature citations. An
extensive literature review was conducted for Phase I. Readers should consult EPA (1992), herein cited as the
"Phase I report" for further information.
4.0 REFERENCE
EPA. 1992. Water Quality Protection Program for the Florida Keys National Marine Sanctuary: Phase I Report.
Final report submitted to the Environmental Protection Agency under Work Assignment 3-225, Contract
No. 68-C8-0105. Continental Shelf Associates, Inc., Jupiter, FL and Battelle Ocean Sciences,
Duxbury, MA.
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TASK 2 — INSTITUTIONAL AND AGENCY MANAGEMENT INVENTORY
CONTENTS
Acronyms	 iv
1.0 INTRODUCTION		2-1
2.0 LIST OF INSTmJTIONS AND AGENCIES WITH JURISDICTION FOR WATER
QUALITY IN THE FLORIDA KEYS NATIONAL MARINE SANCTUARY		2-2
3.0 INVENTORY OF INSTITUTIONS AND AGENCIES WITH JURISDICTION
AND RESOURCES RELATIVE TO WATER QUALITY		2-3
3.1	FEDERAL		24
3.1.1	U.S. Environmental Protection Agency		2-4
3.1.2	U.S. Coast Guard		2-20
3.1.3	National Oceanic and Atmospheric Administration		2-22
3.1.4	U.S. Army Corps of Engineers 		2-23
3.1.5	U.S. Fish and Wildlife Service		2-25
3.2	STATE 		2-27
3.2.1	Florida Department of Agriculture		2-27
3.2.2	Florida Department of Community Affairs		2-28
3.2.3	Florida Department of Environmental Regulation		2-34
3.2.4	Florida Department of Health and Rehabilitative Services 		2-49
3.2.5	Florida Department of Natural Resources 		2-50
3.3	REGIONAL 		2-54
3.3.1	Florida Keys Aqueduct Authority		2-54
3.3.2	South Florida Water Management District		2-55
3.4	LOCAL		2-57
3.4.1	Monroe County		2-57
3.4.2	City of Key West		2-61
3.4.3	City of Key Colony Beach 		2-65
3.4.4	City of Layton	_		2-69
4.0 REFERENCES 		2-72
APPENDIX
A List of Agencies and People Contacted and Interviewed
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ACRONYMS
ACCC
Areas of Critical County Concern
ACSC
Areas of Critical State Concern
CERCLA
Comprehensive Environmental Response, Compensation and Liability Act of 1980
CFR
Code of Federal Regulations
CWA
Gean Water Act (Federal Water Pollution Control Act of 1972)
CZARA
Coastal Zone Act Reauthorization Amendments of 1990
CZMA
Zone Management Act
CZMP
Coastal Zone Management Program
DRI
Developments of Regional Impact
EIS
Environmental Impact Statement
EPA
U.S. Environmental Protection Agency
FAC
Florida Administrative Code
FDCA
Florida Department of Community Affairs
FDER
Florida Department of Environmental Regulation
FDHRS
Florida Department of Health and Rehabilitative Services
FDNR
Florida Department of Natural Resources
FKAA
Florida Keys Aqueduct Authority
FKNMS
Florida Keys National Marine Sanctuary
FMP
Florida Marine Patrol
FMRI
Florida Marine Research Institute
FS
Florida Statutes
FWS
U.S. Fish and Wildlife Service
FY
fiscal year
GIS
Geographic Information System
GMS
Groundwater Monitoring Systerr
KML
Keys Marine Lab
MOA
Memorandum of Agreement
MOU
Memorandum of Understanding
MPRSA
Marine Protection, Research, a:' Sanctuaries Act
NMFS
National Marine Fisheries Serv, >
NOAA
National Oceanic and Atmosph; c Administration
NPDES
National Pollutant Discharge El: unation System
NPS
nonpoint source
OFW
Outstanding Florida Waters
OPM
Office of Policy and Managed .t
ORC
Objections, Recommendations, ind Comments
OSDS
on-site sewage disposal system
RAMS
Regulatory Analysis Management System
RCRA
Resource Conservation and Recovery Act of 1976
RPC
Regional Planning Council
SARA
Superiund Amendments and Reauthorization Act of 1986
SFRL
South Florida Regional Laboratory
SFWMD
South Florida Water Management District
TMDL
Total Maximum Daily Load
UIC
Underground Injection Control
USACE
U.S. Army Corps of Engineers
USCG
U.S. Coast Guard
UST
Underground Storage Tank
WQBEL
Water Quality Based Effluent Limitation
WQPP
Water Quality Protection Plan
WWTP
wastewater treatment plant
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TASK 2 - INSTITUTIONAL AND AGENCY MANAGEMENT INVENTORY
1.0 INTRODUCTION
Task 2 involved two objectives. The first objective was to identify and list the federal, state, regional, and local
institutions and agencies with jurisdiction over activities that affect water quality in the FKNMS. Hie second
objective was to provide an inventory of institution and agency programs, authorities, and resources that currently
exist relative to water quality. This information will serve as background information that will be used in Task 3
of Phase II. This background information was used subsequently in Task 3 to develop a comprehensive range of
management and institutional options to address water quality problems.
Information pertinent to Task 2 was collected through various means. Relevant literature, legislative laws, agency
administrative rules, and Memorandums of Agreement and Understanding (MOAs and MOUs) between various
agencies were reviewed. Key regulatory agencies at federal, state, regional, and local levels of government were,
identified, and specific contacts within those agencies were established. Survey questionnaires concerning program
functions were developed and mailed to key individuals associated with specific water quality regulatory programs.
Individuals within identified programs were interviewed either in person or via telephone (see Appendix A following
Task 2 text).
Section 2.0 of this report provides a list of institutions and agencies with jurisdiction for water quality in the
FKNMS. The list includes institutions and agencies at federal, state, regional, and local levels. Relevant
regulations and programs are also listed under each institution and agency. The programs that have been inventoried
are those that were related to one of the pollution sources identified in Phase I. Those pollution sources are as
follows.
•	Dredge and fill activities
•	Hazardous materials/waste
•	Industrial discharges
•	Landfills
•	Live-aboard vessels
•	Marinas
•	Oil spills
•	Pesticides
•	South Florida Water Management District (SFWMD) canals
•	Stormwater runoff
•	Wastewater treatment
Section 3.0 of this report describes all specific regulations and programs by institutions and agencies with
jurisdiction and resources relative to water quality in the FKNMS. For each institution and agency, the following
aspects are discussed:
•	Program Responsibilities;
•	Authority (implementing authority that enables the agency to assume regulatory responsibility);
•	Objectives (objectives of the regulation or program);
•	Jurisdiction (jurisdictional coverage);
•	Operation (how the program operates);
•	Funding;
•	Staffing; and
•	Tracking (the means used by agencies to track progress or compliance).
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2.0 LIST OF INSTITUTIONS AND AGENCIES WITH JURISDICTION FOR
WATER QUALITY IN THE FLORIDA KEYS NATIONAL MARINE SANCTUARY
Many government agencies have responsibilities over activities that potentially produce direct or indirect water
quality impacts in the FKNMS. The following is a list of federal, state, regional, and local agencies and existing
management tools (regulations or programs) that relate to water quality in the FKNMS.
I. FEDERAL
(A)	U.S. Environmental Protection Agency
(1)	Florida Keys National Marine Sanctuary Program
(2)	Gulf of Mexico
(3)	Section 404, Dredge and Fill
(4)	National Pollutant Discharge Elimination System (NPDES) — Domestic and Industrial
Wastewater
(5)	NPDES — Stormwater Discharges
(6)	Federal Facilities — NPDES and Resource Conservation and Recovery Act (RCRA)
(7)	Ocean Discharge
(8)	Nonpoint Source Management Programs
(9)	Ocean Dumping
(10)	Undergroun- ejection Control
(11)	Marine Sar on Devices
(12)	Resource C nervation and Recovery Act (RCRA)
(13)	Compreher s Environmental Response, Compensation and Liability Act (CERCLA;
Superfund)
(14)	Undergrouu Storage Tanks
(B)	U.S. Coast Guard
(1)	Oil and Ha? Jous Substance Spills
(2)	Marine San :ion Devices
(C)	National Oceanic 1 Atmospheric Administration
(1)	Florida Key National Marine Sanctuary Program
(2)	Coastal Zc; Management Act
(D)	U.S. Army Corps f Engineers
(1) Section 404 Dredge and Fill
(E)	U.S. Fish and Wi< life Service
(1)	Fish and W llife Coordination Act
(2)	Endangered pecies Act of 1973
II. STATE
(A)	Department of A	culture
(1) Mosquito -	trol
(B)	Department of G	n unity Affairs
(1)	Areas of Cr zai State Concern
(2)	Developmet of Regional Impact
(3)	Local Compr "tensive Planning
(4)	Coastal Zone Management
(C)	Department of Environmental Regulation
(1)	Florida Keys National Marine Sanctuary Program
(2)	Domestic Wastewater
(3)	Industrial Wastewater
(4)	Point Source Evaluation
(5)	Wastewater Facilities Regulation and Permitting
(6)	Underground Injection Control
(7)	Water Quality Standards
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(8)	Ambient Monitoring
(9)	Stormwater Management
(10)	Wetland Resource Utilization Permitting (Dredge and Fill)
(11)	Solid Waste Management
(12)	Storage Tank Regulation
(13)	Emergency Response Program
(14)	Local Government Comprehensive Plan Review
(D)	Department of Health and Rehabilitative Services
(1)	On-site Sewage Disposal
(E)	Department of Natural Resources
(1)	Administration of National Marine Sanctuaries
(2)	Environmental Crimes Program
(3)	Submerged Lands and Preserves
(4)	Florida Marine Research Institute
HI. REGIONAL
(A)	Florida Keys Aqueduct Authority
(1) Wastewater
(B)	South Florida Water Management District
(1)	Wetland Regulation
(2)	Stormwater Management
IV. LOCAL
(A)	Monroe County
(1)	Comprehensive Plan
(2)	Land Development Regulations
(B)	City of Key West
(1)	Comprehensive Plan
(2)	Land Development Regulations
(3)	Wastewater Treatment
(C)	City of Key Colony Beach
(1)	Comprehensive Plan
(2)	Land Development Regulations
(3)	Wastewater Treatment
(D)	City of Layton
(1)	Comprehensive Plan
(2)	Land Development Regulations
3.0 INVENTORY OF INSTITUTIONS AND AGENCIES WITH JURISDICTION
AND RESOURCES RELATIVE TO WATER QUALITY
This section of the report provides an inventory of institutions and agencies along with their specific regulations and
programs relative to water quality in the FKNM$. For each institution and agency, the following aspects are
discussed.
•	Program Responsibilities;
•	Authority (implementing authority that enables the agency to assume regulatory responsibility);
•	Objectives (objectives of the regulation or program);
•	Jurisdiction (jurisdictional coverage);
•	Operation (how the program operates);
•	Funding;
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•	Staffing; and
•	Tracking (the means used by agencies to track progress or compliance).
3.1 FEDERAL
3.1.1 U.S. Environmental Protection Agency
3.1.1.1 FLORIDA KEYS NATIONAL MARINE SANCTUARY PROGRAM
PROGRAM RESPONSIBILITIES: EPA and the State of Florida have joint responsibility for preparing a Water
Quality Protection Plan (WQPP) for the FKNMS. EPA's primary role is to coordinate the overall work program,
review and comment on all work products, serve as liaison with all federal agencies and the Florida Department
of Environmental Regulation (FDER), and implement effective intergovernmental coordination and public
participation.
AUTHORITY: Legislative authority for general authorization of National Marine Sanctuaries is set out in Title III
of the Marine Protection, Research, and Sanctuaries Act (as amended). More specifically, the Florida Keys
National Marine Sanctuary Program has been authorized by Public Law 101-60S, Florida Keys National Marine
Sanctuary and Protection Act.
OBJECTIVE(S): Three objectives are set out in the Florida Keys National Marine Sanctuary and Protection Act
as follows:
•	To protect the resources of the Florida Keys;
•	To educate and interpret for the public regarding the Florida Keys marine environs: ;nt; and
•	To manage human use in the FKNMS consistent with the Act.
Further, Title III of the National Marine Sanctuaries Act (as amended) contains additional obje ives that are as
follows:
•	To provide authority for comprehensive and coordinated conservation and managemer of those marine
areas that will complement the existing regulatory authorities; and
•	To support, promote, and coordinate scientific research of those marine waters.
More specifically, the purposes of the WQPP will be to
1.	recommend priority corrective actions and compliance schedules addressing point and onpoint sources
of pollution;
2.	assign responsibilities for the implementation of the program;
3.	address legal, institutional, and management issues and recommend changes;
4.	establish a comprehensive water quality program;
5.	provide adequate opportunity for public participation; and
6.	identify funding mechanisms to implement the WQPP.
JURISDICTION: The FKNMS Program has jurisdiction seaward of the mean high tide line to the outer limits of
the FKNMS as defined in the Florida Keys National Marine Sanctuary and Protection Act.
OPERATION: The EPA Region IV Project Manager and the FDER Florida Keys Coordinator are responsible for
seeing that the WQPP for the FKNMS is produced in a timely fashion. The work effort includes administering and
monitoring the consulting team contracted to prepare a draft WQPP. Project management also includes expediting
technical information exchange and coordinating meetings between the consultant and technical staff of EPA. The
EPA Project Manager will be involved in scheduling all public and technical work sessions.
FUNDING: In 1991, $100,000 was appropriated for the Florida Keys under the Near Coastal Waters Program.
In addition, $200,000 was provided through EPA Headquarters from the Clean Water Act, Section 104(b)(3).
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ondkig for 1992 is being provided via Congressional ซdd-on in the amount of $625,000. Additionally, $50,000
was transferred from EPA Headquarters Gulf of Mexico Program to fund a demonstration project at Bahia Honda
State Park, and $37,500 of Near Coastal Waters Program funding was awarded for an alternative sewage treatment
system near Marathon. All EPA administrative costs related to the FKNMS are funded out of the Region IV EPA
operating budget.
STAFFING: There is one EPA staff member located in the Region IV Coastal Planning Unit who works full time
as the Florida Keys Project Manager.
TRACKING: Tracking of program performance is based on milestones and work products set out in the work
program. Frequent communication between the EPA Project Manager, FDER Florida Keys Coordinator, and other
involved resource agencies and consultants occurs to ensure that the WQPP being prepared results in an acceptable
product. The WQPP will identify how compliance will be monitored.
3.1.1.2 GULF OF MEXICO
PROGRAM RESPONSIBILITIES: The EPA has primary responsibility for the Gulf of Mexico Program. The
program focuses on assessing and characterizing environmental characteristics of the Gulf of Mexico, developing
Action Agendas that identify needed corrective actions, and the ways and means to accomplish the recommended
actions. Further, an important element of the program is the development and implementation of measures that can
improve coordination and cooperation among the various states bordering the Gulf. Another major component of
the program is public awareness. Through this program, the staff sponsors and organizes programs and symposiums
that raise the level of awareness of issues impacting the Gulf of Mexico.
AUTHORITY: This program was established in 1988 through an EPA Region IV initiative. It has continued as
an initiative program: however, there are several legislative bills pending that, if passed, would formally establish
the Gulf of Mexico Program. They include the Gulf of Mexico Commission Act of 1992 sponsored by Senator
Bentsen of Texas; the Gulf of Mexico Preservation Act sponsored by Senator Gramm of Texas, as well as House
of Representative Bill #5249 sponsored by Representatives Ireland and Goss, both of Florida, and House of
Representative Bill #5441 sponsored by the Sunbelt Caucus.
OBJECTIVE (S):
*	To provide a mechanism for addressing complex problems in the Gulf of Mexico that cross state,
federal, international, and jurisdictional lines;
" To provide better coordination and collaboration among federal, state, and local programs affecting
the Gulf;
*	To provide a forum for affected user groups, public and private educational institutions, and the
general public to participate in the "solution" process;
*	To establish interagency protocols, standards, and/or MOUs that will improve cooperation and
minimise duplication among various levels of government;
*	To ensure that uses and economic growth of the Gulf are managed in an environmentally sound
manner,
*	To identify and address environmental issues before irreversible damage or high cost prevents their
repair,
*	To improve communication and cooperation through participation in decisionmaking, and work toward
consensus on technical solutions; and
*	To collect ail other previously evaluated data and information on the Gulf of Mexico to improve the
decision-making process.
JURISDICTION: The geographical boundaries of the program include all waters of the United States within the
Gulf of Mexico, which includes the coastal waters of Florida, Alabama, Mississippi, Louisiana, and Texas. In
terms of the FKNMS, it includes the coastal counties of Dade and Monroe.
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OPERATION: EPA Headquarters in Washington, D.C. has lead'administrative responsibility. Both Regions IV
and VI have regional program offices headed by the regional coordinators. The Program Office is located in Stenms
Space Center in Mississippi. The organization consists of a Policy Review Board, a Technical Steering Committee,
and a Citizen Advisory Committee. In addition, there are a series of specialized work groups (e.g., habitat
degradation, nutrient enrichment, toxic substances and pesticides, and data and information transfer).
Since the program was established in 1988, a variety of activities has been undertaken. They have included such
things as environmental characterization studies and management action plans. The program has also held a Gulf
Symposium, established citizen networks, and developed a database system known as the Gulf of Mexico Program
Electronic Bulletin Board.
The program is currently focused on developing Action Agendas for the Gulf in the following areas related to water
quality issues:
•	Nutrient Enrichment
•	Marine Debris
•	Public Health
•	Toxics/Pesticides
•	Living Aquatic Resources
•	Freshwater Inflow
FUNDING: Being an initiative program, funding comes from the EPA operating budget; thus, the amount is
dependent upon annual Congressional appropriations for EPA, and ultimately is contingent upon the level of priority
EPA places on the program. Historically, there has been a steady increase in funding. In 1988, the program
received $500,000. By 1992, funding had increased to $1,400,000.
STAFFING: Staff for this program is located at four EPA locations: Headquarters - Washington, D.C., Region
IV - Atlanta, Georgia; Region VI • Dallas, Texas; and the Stennis Space Center - Mississippi. Staff at Headquarters
and Regions IV and VI have one specific person assigned to the program. Additional assistance is provided by other
EPA-based programs that exist at those locations. The field operation located at the Stennis Space Center has eight
professionals with support staff. In terms of staff, the field office includes a director, a technical director, a senior
scientist, an administrative assistant and three project officers.
TRACKING: EPA is presently reviewing the success of the program's initial five-year strategy. Success may be
difficult to judge, because no quantifiable objectives were originally set. The strategy for the next five years will
be more quantifiable in terms of achievements. Examples may include number of acres of habitat restored or how
well actions have lead to compliance with objectives of the program.
3.1.1 J SECTION 404, DREDGE AND FILL
PROGRAM RESPONSIBILITIES: The EPA Region IV Wetlands Regulatory Section staff has the responsibility
to review and comment on all dredge and fill permit applications, and take enforcement actions on unpermitted
discharges. In addition, the Region has the authority to fund Advance Identification of Wetland studies.
AUTHORITY: Legislative authority for regulating dredge and fill activities is derived from the Federal Water
Pollution Control Act of 1972 and subsequent amendments, commonly known as the Clean Water Act (CWA).
Section 404 of the CWA created a permit program to regulate the discharge of dredge and fill material into
navigable waters of the United States and adjacent wetlands. Primary responsibility for the program has been
delegated to the U.S. Army Corps of Engineers (USACE). However, EPA has been assigned certain authority
under Section 404 that enables the agency to review and comment on the impact of proposed dredge and fill
activities on municipal water supplies, shellfish beds and fishery areas, wildlife, and recreational areas. Further,
the law provides EPA with enforcement powers and veto of unacceptable reviews under Section 404(c). These
enforcement powers are set out in Section 309 of the CWA.
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In addition to the CWA, dredge and fill permit applicants must also adhere to the federal idministrative rules in the
Code of Federal Regulations (CFR). Those rules that pertain to Section 404 permits are as follows:
•	33 CFR Parts 320-330;
•	40 CFR Part 122 — Administered Permit Programs: The National Pollutant Discharge Elimination
System;
•	40 CFR Part 124 — Procedures for Decisionmaking;
•	40 CFR Part 230 — Guidelines for Disposal Sites for Dredge and Fill Materials; and
•	40 CFR Part 231 — Procedures for Section 404(c) "veto" of USACE permit.
Further clarification of USACE's and EPA's dredge and fill responsibilities have been defined in three MOAs.
They address enforcement, mitigation, and jurisdiction.
OBJECTIVE(S): To restore and maintain the chemical, physical, and biological integrity of waters of the United
States through the control of discharges of dredge and fill material.
JURISDICTION: Section 404 jurisdiction extends throughout the Florida Keys and FKNMS. Whether a Section
404 dredge and fill permit is required depends on if the activity will take place in "navigable waters" (waters of
the United States, including adjacent wetlands). "Waters of the United States" is defined in 40 CFR 122.2,
Definitions. The USACE and EPA have a MOA regarding jurisdictional determination. In practice, the USACE
generally makes the determination.
OPERATION: While the USACE has primary permitting and enforcement responsibility for Section 404 permits,
EPA has statutory enforcement authority to deal with discharges of dredge and fill material where no permit has
been obtained. The USACE has similar authority for situations in which Section 404 permits have been issued and
their conditions violated. Both the USACE and EPA have authority to seek civil or administrative remedies for
unauthorized discharges into wetlands. In addition, EPA can pursue criminal action in its enforcement areas.
Under Section 404(c), the EPA can "veto" permits that have already been USACE-approved if the activity will have
an unacceptable adverse effect on municipal water supplies, shellfish beds and fishery areas, wildlife, or recreational
areas. In reality, EPA has exercised this veto action only 11 times, nationwide, since the CWA was enacted in
1972.
The MOAs between EPA and USACE are to facilitate coordination. Generally, they address procedural matters
regarding permitting and enforcement. Significant MOAs between the USACE and EPA address the issue of
mitigation and define enforcement referrals between the Jacksonville office and EPA Region IV.
Due to the presence of extensive wetland vegetation and low-lying topography throughout the Florida Keys, the
USACE has extensive Section 404 jurisdiction. Therefore, a large percentage of Section 404 permit applications
reviewed in south Florida are in the Florida Keys (D. Powell, EPA Region IV, personal communication, 1992).
In Federal WetUutds Regulation in Florida Keys: Net Losses in a Special Place, the author, Ross Bumaman,
reviewed 96 permits in 1989 and 158 in 1990. On average, statewide, there are between 1,000 and 1,500 dredge
and fill permit applications filed annually.
EPA Region IV operates under the premise that intertidal wetlands can stabilize shorelines and sequester nutrients
and sediments found in upland runoff (Odum et al. 1982, Odum and Mclvor 1990, and Adamus et ai 1991).
Wetlands also retain heavy metals and organic pesticides, and can detoxify the latter (Adamus et aL 1991). These
ecosystem functions, particularly shoreline stabilization, nutrient removal, and sediment trapping, are performed
by wetlands in the Keys. These processes result in reduction of turbidity and nutrient loading in FKNMS waters,
providing direct benefits to water quality.
In recognition of these benefits, EPA Region IV is funding an Advance Identification of Wetlands project in the
Florida Keys, in cooperation with the USACE, FWS, National Aeronautics and Space Administration, FDNR,
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Florida Game and Fresh Water Fish Commission, and Monroe County. This project will improve implementation
of the provisions of Section 404 by providing a basis for testing dredge and fill impacts against the 404(b)(1)
disposal site guidelines.
FUNDING: Staff costs for this program are funded from the general Region IV EPA operating budget.
STAFFING: The Wetlands Regulatory Section in EPA has the responsibility for reviewing and commenting on all
Section 404 permit applications and enforcement. One person is responsible for the Florida Keys, as well as nine
other south Florida counties. The present staffing level makes it nearly impossible to provide the level of attention
to each permit application that will ensure the objectives of the program are achieved.
TRACKING: Generally, no extensive tracking occurs. Only when EPA recommends denial or when a permit
application is appealed through the Section 404(c) appeal process does any sort of tracking occur. The USACE is
required to formally submit a response to EPA indicating how they have addressed the EPA comments.
3.1.1.4 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM - DOMESTIC AND
INDUSTRIAL WASTEWATER
PROGRAM RESPONSIBILITIES: The Water Permits and Enforcement Branch of EPA has responsibility for
permitting domestic and industrial facilities that discharge wastewater into the oceans, territorial seas, or marine
waters of the United States, and enforcing all of these permits.
AUTHORITY: Legislative authority for regulating point source discharges is derived from the CWA.
In addition to the CWA, point source dischargers must also adhere to the following CFRs:
•	40 CFR Part 121 — State Certification of Activities Requiring a Federal License or Permit;
•	40 CFR Part 122 — Administered Permit Programs: The National Pollutant Discharge Elimination
System;
•	40 CFR Part 124 — Procedures for Decisionmaking;
•	40 CFR Part 125 — Criteria and Standards for the National Pollutant Discharge Elimination System;
•	40 CFR Part 129 — Toxic Pollutant Effluent Standards;
•	40 CFR Part 131 — Water Quality Standards; and
•	40 CFR Part 136 — Guidelines Establishing Test Procedures for the Analysis of Pollutants.
OBJECTIVE(S): To restore and maintain the chemical, physical, and biological -itegrity of the nation's waters.
JURISDICTION: The scope of this program encompasses all areas within the Florida Keys and the FKNMS.
OPERATION: Domestic and industrial NPDES permits are required of all surface water dischargers. Because
Florida has not been delegated program responsibilities by EPA, the EPA Region IV Water Permits and
Enforcement Branch handles all permitting and enforcement activities in Florida, including the Florida Keys. (When
an EPA program is delegated to a state, it means that EPA no longer has primacy for regulating or permitting;
however, EPA retains oversight responsibility for the delegated program.) Florida is in the process of petitioning
to become a delegated state. Even though Florida is not a delegated state. Region IV coordinates its NPDES
permitting and enforcement efforts with the Bureau of Wastewater Facilities Regulation of the FDER.
When the EPA NPDES Permits Section prepares a draft NPDES permit, a copy of the permit is sent to the Bureau
of Wastewater Facilities Regulation for comment. This is in accordance with the 401 Certification process that is
detailed in 40 CFR Part 121. This activity is undertaken to ensure that the proposed NPDES permit will be
consistent with State of Florida water quality standards and other concerns of the state. The state has 60 days in
which to comment. An MOU between the State of Florida and EPA delineates the responsibilities of both agencies
regarding permitting. The importance of coordination is underscored by the fact that, at this point in time, the State
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of Florida also requires NPDES permitted wastewater facilities to receive a permit from the state as well. If Florida
becomes a delegated state, this duplication in permitting will be eliminated.
Over the past several years, there has been a decline in the number of NPDES facilities permitted in the Florida
Keys. Over the past three years, 20 permits have been processed for wastewater facilities in the Florida Keys.
Because it is the goal of the state to eliminate surface water discharges, an increase in the number of first-time
permit applications most likely will not occur in the future. Until all surface water discharges are eliminated in the
Florida Keys, there will continue to be some level of NPDES permitting activity because NPDES permits must be
renewed every five years.
Coordination of enforcement activities also takes place between EPA and FDER. Annually, EPA and FDER
develop what commonly is known as the "Inspection Commitments List" for NPDES permitted surface water
dischargers. This list identifies which NPDES permitted wastewater treatment facilities will be inspected and the
date of the inspections. This is done to avoid EPA inspecting a facility one week and FDER inspecting the same
wastewater facility the succeeding week. Sometimes inspections are conducted at the same time. When joint
inspections do not occur, EPA and FDER try to maintain a six-month interval between their individual site
inspection visits to make the inspection process less burdensome on the permit holder.
All major dischargers (e.g., power plants. City of Key West wastewater treatment plant [WWTP]) are inspected
annually. Minor facilities are visited every five years. Although EPA and FDER coordinate inspections, the
facility operators do not know when an inspection will occur.
FUNDING: The NPDES permitting and enforcement staffs are funded from the Region IV EPA operating budget.
STAFFING: The Water Permits and Enforcement Branch is separated into two sections. One processes permits
and the other enforces the approved permits. Staffing in the Permit Section varies depending upon the number of
permit applications received. The Enforcement Section has four individuals assigned to cover Broward, Dade, and
Monroe Counties.
TRACKING: Once permits are issued, permittees must file monthly or quarterly Discharge Monitoring Reports.
Data from the Discharge Monitoring Reports are entered into EPA's computerized tracking program known as
Permit Compliance Systems. This database contains all types of information on each permittee such as previous
enforcement actions, water quality effluent parameters, and permit conditions. Field inspections are also conducted
to determine permit compliance. The information generated is used to support enforcement actions, and as input
in the permit renewal process.
3.1.1.5 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM - STORMWATER
DISCHARGES
PROGRAM RESPONSIBILITIES: The Water Permits and Enforcement Branch of EPA has responsibility for
permitting and enforcing stormwater discharges from a variety of industrial operations as defined in 40 CFR Part
123, as well as stormwater discharges from large and medium municipal separate storm sewer systems.
AUTHORITY: Legislative authority for regulating stormwater discharges is derived from Section 402(p) of the
CWA. In addition to the CWA, point source dischargers must also adhere to the federal administrative rules (i.e.,
CFR). Those that pertain include the following:
•	40 CFR Part 121 — State Certification of Activities Requiring a Federal License or Permit;
•	40 CFR Part 122 — Administered Permit Programs: The National Pollutant Discharge Elimination
System;
•	40 CFR Part 124 — Procedures for Decisionmaking;
•	40 CFR Part 125 — Criteria and Standards for the National Pollutant Discharge Elimination System:
•	40 CFR Part 129 — Toxic Pollutant Effluent Standards;
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•	40 CFR Part 131 — Water Quality Standards; and
•	40 CFR Part 136 — Guidelines Establishing Test Procedures for the Analysis of Pollutants.
OBJECTIVE(S): To restore and maintain the chemical, physical, and biological integrity of the nation's waters.
JURISDICTION: The scope of this program encompasses all areas within the Florida Keys and the FKNMS.
OPERATION: This is a relatively new program. Final regulations for the program were published November 16,
1990. Only separate stormwater facilities are regulated under this program. Combined sanitary and stormwater
systems that discharge into surface waters of the United States are already required to operate under an NPDES
permit No permits have been issued by the Region IV office at this time. Since the enactment of the
administrative rules pertaining to separate stormwater facilities, all industrial and municipal dischargers subject to
these rules have been preparing their applications for "Permit to Discharge Storm Water Discharges Associated with
Industrial Activity." These applications must be submitted by the fail of 1992 to EPA.
To date, no municipal stormwater NPDES application has been submitted or is expected to be submitted to EPA
from any jurisdiction in the Florida Keys. According to the Final Rule dated November 16, 1990, only those
incorporated places having a population of 100,000 or more are required to prepare a stormwater application. There
have been no modifications made to the Final Rule adopted in 1990. However, Section 402(p)(2)(E) of the CWA
allows the EPA Administrator or a state to require a stormwater discharger to obtain an NPDES stormwater permit
regardless of population size if the discharge contributes to a violation of a water quality standard or is a significant
contributor of pollutants to waters of the United States.
NPDES stormwater permits are required for activities associated with indu .trial uses. Those activities that are
defined as industrial uses are described in 40 CFR 122.26. Permits may ; applied for in one of three ways:
through an individual permit, through a group permit, and through a notice if intent to be covered by a general
permit. Relative to the Florida Keys, this aspect of the program has particu ;r relevance to marinas. Only those
marinac that are involved in vehicle (boat) maintenance activities (includi • vehicle rehabilitation, mechanical
repairs, painting, fueling and lubrication) or equipment cleaning operations a ; considered industrial activities. As
such, they are required to apply for a NPDES stormwater permit. Those • annas that are engaged primarily in
retail sale of fuel and lubricating oils or that primarily provide sports or r ;reation services or products are not
required to apply for a NPDES stormwater permit.
FUNDING: Staff positions are funded out of the general Region IV EPA c /crating budget.
STAFFING: There are six people in the Storm Water and Municipal Uni dedicated to permitting. Enforcement
of the permits will be handled by the NPDES Enforcement Section. ~ sere are four individuals who conduct
compliance inspections in Broward, Dade, and Monroe counties. No incruise in staffing is anticipated at this time.
As the program matures, staffing needs will focus more on enforcement than permitting, because the stormwater
permits will be general permits covering large numbers of facilities in one permit. However, regardless of whether
a permit has 1 or SO facilities, enforcement is done on a facility-by-facility basis.
TRACKING: Monitoring results will be submitted in Discharge Monitoring Reports similar to those used for
monitoring NPDES domestic and industrial wastewater discharge facilities. Compliance with the permits will be
the responsibility of the NPDES Enforcement Section. It is anticipated that this program will also input monitoring
information into EPA's Permit Compliance Systems computerized database. Site inspections will also be conducted
to determine compliance with permit conditions.
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3.1.1.6 FEDERAL FACILITIES - NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
AND RESOURCE CONSERVATION RECOVERY ACT
PROGRAM RESPONSIBILITIES: The Federal Activities Branch has permitting and enforcement responsibilities
for all federal wastewater facilities that discharge to surface waters. In addition, the branch is responsible for
permitting RCRA activities at federal facilities; however, enforcement of RCRA permits is the responsibility of the
RCRA Permitting and Compliance Branch located in the Waste Management Division of EPA.
AUTHORITY: Legislative authority for the performed by this branch is derived from the following public
laws:
•	CWA; and
•	RCRA.
Further, Executive Order 12088 describes the federal facilities compliance strategy that must be adhered to by
federal agencies.
OBJECTIVE(S):
CWA objectives:
•	To restore and maintain the chemical, physical, and biological integrity of the nation's waters;
•	To provide for the protection and propagation of fish, shellfish, and wildlife, and to provide for
recreation in and on the water; and
•	To ensure federal compliance with applicable pollution control standards.
RCRA objectives:
•	To protect human health and environment;
•	To conserve valuable material and energy resources; and
•	To encourage recycling, reuse, and treatment of hazardous wastes.
JURISDICTION: Program jurisdiction extends throughout the Florida Keys and the FKNMS.
OPERATION: Staff members are not located in the Water Management Division or the Waste Management
Division, but in the Federal Activities Branch of the Office of Policy and Management (OPM). The OPM is a
separate division within EPA.
Permits for wastewater and RCRA projects are prepared by permit writers in the Federal Activities Branch. Prior
to finalization, the permits are circulated to either the NPDES Permits Section or the RCRA Permits Section, as
appropriate, for review and comment. Upon receipt of these comments and those from the federal installations
seeking the permits, the permits are finalized. Once the permit is issued, only wastewater permits are enforced by
the Federal Activities Branch. The individual with RCRA responsibilities within the branch monitors for violations
only. All enforcement actions are taken by the RCRA Compliance Section located in the Waste Management
Division.
FUNDING: The Federal Activities Branch staff is funded out of the Region IV EPA operating budget.
STAFFING: There are five	staff members assigned to the Region IV Federal Activities Branch. There
is no one person assigned to either the Florida Keys or the State of Florida. The staff is responsible for writing
all wastewater and RCRA permits as well as enforcing wastewater permits or monitoring RCRA violations in eight
states. One individual has responsibility for wastewater and another for RCRA-related activities. The other staff
members are assigned responsibility for coordinating activities that involve the Tennessee Valley Authority, National
Aeronautic and Space Administration, and Department of Energy.
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TRACKING: All federal wastewater facilities submit monthly Discbarge Monitoring Reports to the NPDES
coordinator within the Branch. The RCRA coordinator in the Federal Activities Branch submits monthly federal
facility compliance reports to the RCRA Permitting and Compliance Branch. In addition, the Federal Activities
Branch staff makes on-site inspections annually.
3.1.1.7 OCEAN DISCHARGE
PROGRAM RESPONSIBILITIES: The Ocean Discharge Program is housed within the Wetlands, Oceans and
Watersheds Branch of EPA. The program involves establishing bioassessment criteria for the discharge of point
source pollutants into the marine environment, meaning the oceans, territorial sea, or contiguous zone. This
program is implemented through the NPDES permitting program which requires applicants to develop monitoring
programs to measure degradation of the marine environment.
AUTHORITY: Legislative authority for point source ocean discharge regulation is contained in Section 403(c) of
the CWA. In addition to the CWA, ocean dischargers must also adhere to the federal administrative rules in the
CFR as follows:
• 40 CFR Part 125 — Criteria and Standards for the National Pollutant Discharge Elimination System.
Subpart M — Ocean Discharge Criteria.
OBJECTIVE(S): To ensure that ocean outfalls cause no "unreasonable degradation" of the marine environment.
Unreasonable degradation is defined as significant adverse changes in ecosystem diversity, productivity, and stability
of the biological community within the area of discharge and surrounding biological community (40 CFR Part 12S,
Subpart M).
JURISDICTION: The only surface water dischargers that are under ;e jurisdiction of this program are those
whose discharge point occurs seaward of the "baseline" (mean low tide iark). "Baseline" has been delineated by
the federal State Department. The only surface water discharger in the KNMS that falls under the jurisdiction of
this program is the City of Key West WWTP.
OPERATION: The ocean discharge program is an integral part of te NPDES permitting process for ocean
discharges. While the program does contain a provision that no discharge permit be issued until it is established
that the discharge will not harm the receiving waters, in reality, the program operates somewhat differently.
Certainly, new dischargers must meet that provision. However, there ..re a number of existing situations where
sewage treatment plants are operating under an existing NPDES permit. :ke the City of Key West WWTP, that was
approved prior to 1980, the date when Section 403(c) was added to me CWA legislation. However, there is a
"reopener clause" in the CWA that provides EPA with an opportunity to address a situation where a sewage
treatment plant is creating severe environmental damage. Thus when an NPDES permit is being reviewed, EPA
can add new provisions to the applicant's NPDES permit based on new information derived as a result of the 403(c)
monitoring study.
Staff in the Coastal Planning Section supports the NPDES Permits Section by reviewing required NPDES monitoring
programs that are prepared for the purpose of assessing the impacts on the surrounding biological communities.
Region IV has oversight responsibility in delegated states. Because Florida is not a delegated state, EPA administers
the 403(c) ocean discharge program in Florida.
The Region IV office coordinates with the FDER I^PDES coordinator as well as with the applicant. Once a draft
monitoring plan is initially drafted, both the state and applicant have an opportunity to review and comment. Based
on the responses, the initial monitoring plan is modified. The approved plan then becomes a part of the approved
NPDES permit. Coordination is essential with the Water Permits and Enforcement Branch, because they have
responsibility for writing the NPDES permit as well as enforcing it. While there is no ocean discharge monitoring
program in place in the Florida Keys, Region IV staff has been working with the City of Key West. The city
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submitted a proposed monitoring program two years ago as part of its NPDES permit application package. EPA
staff recently prepared a revised program and met with city officials to discuss the proposed program suggested by
EPA.
FUNDING: Funding for ocean discharge coordination and research activities in Region rv has been relatively stable
over the past three years: 1990 — $200 thousand; 1991 — $200 thousand; 1992 — $190 thousand. However, in
1993 a significant reduction in appropriated funds for the program is anticipated. The expected funding level will
probably be in the range of $80-100 thousand. No specific funds are allocated to the Florida Keys. The source
of funds come from EPA headquarters, Section 104(B)(3) of the CWA. EPA Region IV staff costs are funded out
of the general Region IV EPA operating budget.
STAFFING: One technical staff person in Region IV has responsibility for coordinating the ocean discharge
program in the six coastal states within the region. Approximately 3051 of the individual's time involves work in
the Florida Keys. Although not prerequisite, individuals in this program should have a background in marine
biology/ecology and/or oceanography.
TRACKING: Ocean discharge monitoring plans are based on a case-by-case situation. Generally, the monitoring
plan describes the various sampling methodologies to be used to gather information. Once completed, the data are
evaluated using various statistical techniques to determine if the discharges affect marine communities and natural
coastal habitats. Also, there is an internal EPA administrative MOU that directs the Enforcement Section of the
Water Permits and Enforcement Branch to notify the ocean outfall coordinator of all enforcement actions. This
enables the ocean discharge coordinator an opportunity to recommend modifications to the permit.
3.1.1.8 NONPOINT SOURCE MANAGEMENT PROGRAMS
PROGRAM RESPONSIBILITIES: Fhis is a nonregulatory program that directs states to develop nonpoint source
management programs. The Nonpc at Source (NPS) Program staff provides administrative oversight on state
management plans to ensure that the 'squirements of Section 319 of the CWA are met; administers the agency's
nonpoint source grant program; and ,-rovides technical assistance to the states upon request.
AUTHORITY: There is no legislative authority for regulating nonpoint source discharges; it is a nonregulatory
program contained in Section 319 of ihe CWA. There are no federal administrative rules for the nonpoint source
program codified in the CFR.
However, Section 6217 of the Coastal Zone Act Reauthorization Amendments (CZARA) of 1990 requires all states
with federally-approved Coastal Zone Management Programs (CZMP) to develop a Coastal Nonpoint Pollution
Control Program. A set of "economically'' achievable management measures that, to the greatest degree possible,
lead to a contaminant reduction in nonpoint sources of pollution is to be a part of each program.
OBJECTIVE(S): To control and abate nonpoint source pollution, through voluntary measures.
JURISDICTION: The scope of this program encompasses all areas within the Florida Keys and the FKNMS.
OPERATION: The Nonpoint Source Program is assigned to the Watershed Unit in the Wetlands, Oceans and
Watersheds Branch of EPA Region IV. llie EPA 'nonpoint source staff has three primary duties: overseeing all
state NPS programs in Region IV; administering the Section 319(h) grants program that is used to implement
individual state nonpoint programs; and assisting states in the development and implementation of nonpoint source
management programs.
In Florida, the EPA staff coordinates its efforts with the FDER, Bureau of Surface Water Management, Nonpoint
Source Management Section. Generally, EPA staff has no direct contact with local governments in the Florida
Keys.
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A new program which may impact state nonpoint source programs is Section 6217 of the 1990 CZARA. Section
6217 requires states with an approved coastal zone management program to develop and submit a Coastal Nonpoint
Pollution Control Program to EPA and NOAA for approval. Guidance to implement Section 6217(g) of the 19SZ
CZARA is under promulgation. This program identifies quantitative estimates of pollution reduction for each
measure, and any necessary monitoring techniques that assess the success of the measures in reducing pollution loads
and improving water quality. Local governments will also be required to identify, develop, and implement pollution
control measures. Failure of the State to comply with the federal mandate may jeopardize up to 30% of their
funding under Section 306 of the Coastal Zone Management Act (CZMA) and Section 319 of the CWA. The
State's and EPA's bioassessment efforts should serve as the basis of setting standards that can provide quantitative
and/or narrative standards for not only, water quality, but for marine habitats also.
FUNDING: Funds for the Section 319 Nonpoint Source Management Programs are appropriated annually by the
United States Congress.
EPA Region IV receives an annual grant allocation for Section 319(h). Of this annual grant allocation, 50% of the
funds are set aside to provide each state with a base amount to implement its programs. The other 50% is
competitive money. The amount of competitive funds a state receives depends upon whether its proposed work plan
for the ensuing year includes projects that attempt to control particularly difficult or serious nonpoint source
pollution problems or projects that provide innovative methods or practices for controlling nonpoint source pollution.
Region IV awards Section 319(h) grants to states with EPA-approved NPS management programs based on
approvable workplans and competitive projects.
Over the past three years, Florida has received increased allocations. In 1990, the state receiver 1,294,000; in
1991, $1,479,000; and in 1992, Sl.520,000. Continued increases will depend upon how well Flon a can compete
for the discretionary portion of the gTant program.
STAFFING: There is only one person assigned full time to the Nonpoint Source Management Pre am in Region
IV, which covers eight states. The U.S. Soil Conservation Service and the U.S. Forest Service hav me individual
each assigned to the Region IV Watershed Unit responsible for NPS pollution. It is recognized thai: >m a nonpoint
source perspective, especially in the South, any effective water quality improvement must be link 1 to land uses
such as agricultural and forestry practices.
TRACKING: The work products resulting from the Section 319(h) grant program provide one met >d of tracking
program compliance. The other method occurs by evaluating the progress the state makes towari implementing
its nonpoint source management plan.
3.1.1.9 OCEAN DUMPING
PROGRAM RESPONSIBILITIES: The Coastal Regulatory Unit within the Wetlands, Oceans Watersheds
Branch administers the Ocean Dumping Program. There are two aspects to the program: the site designation
process and the issuance of ocean dumping permits. The staff coordinates and interacts with all other EPA technical
personnel involved in the site designation process. The staff also reviews and comments on proposed USACE ocean
dumping permits.
AUTHORITY: Legislative authority establishing the Ocean Dumping Program is derived from Title I — Marine
Protection, Research, and Sanctuaries Act ([MPRSA] as amended).
In addition, the program parameters are described in further detail in the provisions of 40 CFR 220 Subpart H —
Ocean Dumping.

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OBJECTTVE(S):
•	To regulate the dumping of all types of materials into ocean water;
*	To prevent or strictly limit dumping into ocean waters of any material that would adversely affect
human health, welfare, or amenities, or the marine environment, ecological systems or economic
potentialities.
JURISDICTION: All ocean waters of the United States are subject to the requirements imposed by the Ocean
Dumping Program.
OPERATION: For a site to be designated for ocean dumping, it will require extensive study and evaluation. An
Environmental Impact Statement (HIS) must be prepared. Because the designation process is the responsibility of
EPA, EPA prepares the EIS internally. The process is complex and lengthy. Few sites are left to be designated.
There was a site designated within close proximity to Key West; however, the designation was removed because
it was never used. The designated site nearest to the Florida Keys is located in waters offshore of Miami.
Generally, ocean dumping permits are sought by a federal government agency such as the U.S. Navy or port
authorities looking for a site to dump dredge material generated from harbor maintenance or harbor deepening
projects. The USACE is the responsible agency in the permitting process only for dredged material, otherwise EPA
has the lead. EPA reviews and comments on proposed permits for ocean dumping. In seeking an ocean dumping
permit, the material the applicant seeks to discharge at one of the designated dump sites must undergo stringent
testing for toxicity in sediments. Testing for mercury, radionuclides, and other potential toxic contaminants is
required. There is a Testing Manual that identifies acceptable detection limits. Dredge material that cause a 20%
mortality rate as compared to the reference sediment will not be allowed to be disposed of at the disposal site.
Before any permit is issued from the USACE, the USACE issues a public notice for comments. It is at this time
that EPA receives an opportunity to review and comment. EPA comments are based on the criteria set out in 40
CFR 22C — Subsection H. Permits generally have a life of three to five years before the permit needs to be
renewed, though this is not fixed.
FUNDIN G: Staff positions are funded out of the EPA Region IV operating budget.
STAFFING: The program is administered by two individuals at EPA Region IV. They are responsible for six
coastal states in the region.
TRACKING: Tracking occurs during the enforcement phase of the ocean dumping by the USACE.
3.1.1.10 UNDERGROUND INJECTION CONTROL
PROGRAM RESPONSIBILITIES: The EPA Underground Injection Control (UIC) staff has the responsibility
of regulating and/or assisting states in managing the injection of fluids into wells so as to prevent endangering
drinking water sources. Federal staff has regulatory functions as well as oversight duties in states that have been
delegated UIC responsibilities.
AUTHORITY: Legislative authority for UIC is enabled under the Safe Drinking Water Act, Part C.
The rules under which the section functions are incorporated within the CFR as follows:
•	40 CFR Part 124 — Procedures for Decisionmaking;
•	40 CFR Part 144 - UIC Program;
•	40 CFR Part 145 — State UIC Program Requirements; and
•	40 CFR Part 146 — UIC: Criteria & Standards.
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OBJECTTVE(S): To protect the underground sources of drinking water from contamination.
JURISDICTION: The scope of this program encompasses all areas within the FKNMS. This area, like all others
in the United States, is subject to the provisions and regulations promulgated as a resuli of -ie Safe Drinking Water
Act.
OPERATION: Florida has been delegated UIC program responsibility by EPA. The responsibilities are set out
in an MOU. The Region IV UIC Section has oversight responsibility. Florida has authority to regulate Class I
(hazardous waste injected below lowermost formation which is within 0.25 mile of a well used for potable water
needs), Class m (minerals), Class IV (hazardous or radioactive waste injected above a formation which is within
0.25 mile of a well used for potable water needs), and Class V (40 CFR Part 146.5 defines Class V injection wells
as those not included in Class I, II, III, or IV). There are 16 types of Class V injection wells. EPA retains
regulatory responsibility for Class II wells (oil and natural gas).
Region IV personnel make periodic visits to FDER headquarters in Tallahassee to monitor program performance.
If requested by the state, EPA UIC staff will provide technical advice during the permitting process. EPA is a
member of the FDER Technical Advisory Committee that reviews design and construction programs, primarily for
Class I wells. A complete compliance and tracking component is required as part of Florida's EPA-approved UIC
program.
FUNDING: The Region IV UIC program administration costs are funded from the Region IV EPA operating budget
that is funded annually through Congressional appropriations.
The Florida UIC program has received approximate:
state appropriates to operate its UIC program. The f<
budget.
STAFFING: The Region IV UIC Section has 20 si
are devoted annually to the Florida program. The b:
Florida.
TRACKING: The UIC program is tracked in r
responsible for the UIC program. Generally, these \
from time to time, EPA staff does visit FDER distr
must submit quarterly compliance reports to FDER c
reports indicate that the district is not making progr
EPA staff works closely with FDER staff to correct
3.1.1.11 MARINE SANITATION DEVICES
' $200,000 annually from EPA to supplement the funds the
?ral funds amount to approximately 10% of the total Florida
members. Approximately two to three man-years of time
of that time is spent dealing with injection wells in southern
ways. One method involves meeting with FDER staff
s occur at the FDER headquarters in Tallahassee; however,
offices. Also, those permitted to operate an injection well
.ict offices that subsequently are submitted to EPA. If these
toward achieving the goals of the annual grant work plan,
iy deficiency.
PROGRAM RESPONSIBILITIES: This program allows states to prohibit discharge of any sewage from all
vessels; however, prior to enacting such a regulation or program, the state must first submit an application to EPA
for approval. EPA has no enforcement powers requiring vessels to have such sanitation devices. Enforcement is
in the domain of the U.S. Coast Guard (USCG).
AUTHORITY: Legislative authority giving EPA the responsibility for approving a state's prohibition on discharging
waste from all vessels is enabled under Section 312 of the CWA.
Administrative rule 40 CFR Part 140 describes the standards for marine sanitation devices.
OBJECTIVE(S): To prevent the discharge of untreated or inadequately treated sewage into or upon navigable
waters from new and existing vessels.
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JURISDICTION: The scope of this program extends throughout the FKNMS.
OPERATION: If a state desires to prohibit sewage discharge from all vessels within its state waters, it must petition
EPA for approval. Petitions may be initiated by private interest groups as well as by government entities but are
forwarded to EPA via the Governor's office. Approval is contingent upon the application justifying the prohibition
of discharge. The availability of pumpout facilities is the most important criteria in deciding whether or not to
approve the petition. There has been only one application submitted and approved in Region IV, Destin Harbor
in northern Florida. In addition to reviewing petitions, of which there have been only a few, the most time is spent
on answering questions and providing the public with information about the program.
FUNDING: No funding is specifically earmarked for this program. The time that staff spends administering the
program is absorbed in the general operating budget of EPA. Funding is appropriated annually by Congress.
STAFFING: Presently, the individual handling the Ocean Discharge Program serves as an information coordinator
for marine sanitation devices.
TRACKING: No tracking of program performance occurs.
3.1.1.12 RESOURCE CONSERVATION AND RECOVERY ACT
PROGRAM RESPONSIBILITIES: Key program responsibilities involve the management and tracking of
hazardous wastes from generator to transporter to treatment, storage, and disposal. In addition, other
responsibilities include developing solid waste management plans; preparing guidelines for solid waste management;
prohibiting open dumping; and encouraging recycling, reuse, and resource conservation and recovery systems. The
RCRA staff also manages the cleanup of contaminated sites; however, unlike the Superfund program, the RCRA
program deals with only active sites rather than inactive or uncontrolled sites that fall under CERCLA jurisdiction.
AUTHORITY: Legislative authority for the tasks performed by this section are enabled under the following laws:
•	RCRA; and
•	Hazardous and Solid Waste Amendments of 1984.
The rules under which the section functions are delineated in 40 CFR Parts 261 and 262.
OBJECTIVE(S):
•	To protect human health and environment;
•	To conserve valuable material and energy resources; and
•	To encourage recycling, reuse, and treatment of hazardous wastes.
JURISDICTION: The scope of the program encompasses all areas within the Florida Keys and the FKNMS.
OPERATION: All defined RCRA activities must be permitted by EPA or a delegated state, whichever applies.
Also, federal facilities are not exempt from the provisions of RCRA. If the state is a designated RCRA state, it
can enforce RCRA on Federal Reservations with the exception of RCRA corrective actions. Corrective actions are
handled by EPA.
All federal facilities with RCRA activities related to corrective action are permitted by EPA in an unauthorized state.
The Federal Facilities Branch located in EPA's Waste Management Division is responsible for monitoring corrective
action permits for violations. Enforcement of violations is handled by the RCRA Federal Facilities Branch. Within
the Florida Keys, the Boca Chica Naval Air Station is seeking an open-burning and detonation permit from the EPA.
EPA sends draft corrective action permits to states for comment.
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Florida is a delegated state for the RCRA base program; therefore, it has a significant role in permitting and
managing RCRA base program activities of federal and non-federal facilities. The RCRA function in Florida is
housed in the Division of Waste Management of the FDER. While Florida has permitting and enforcement
capability, EPA has oversight responsibility.
FUNDING: Region IV RCRA program staff positions are funded out of the general EPA Region IV operating
budget.
The State of Florida receives approximately $2 million annually to implement the hazardous waste RCRA work
plan. Grant funds have remained relatively stable over the past few years.
STAFFING: In EPA Region IV one person is assigned to Florida from the RCRA Permits Section, as well as an
individual in the Federal Facilities Branch who is responsible for the Boca Chica Naval Air Station.
TRACKING: Two types of tracking occur in the RCRA program. One occurs as a result of EPA's state oversight
responsibilities. An individual within the RCRA Permitting and Compliance Branch is assigned the responsibility
of coordinating and monitoring the Florida program. Secondly, FDER must submit quarterly reports to Region IV
that describe the status of all ongoing RCRA projects in the state. Also, EPA staff receives copies of all
correspondence that occurs between the Florida solid/hazardous waste management staff and the various active
projects.
3.1.1.13 COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT
PROGRAM RESPONSIBILITIES: Program responsibilities include identifying sites where hazardous substances
have been or might have been released into the environment; ensuring that the sites are cleaned up by responsible
parties or the government; evaluating damages to natural resources; and developing claim procedures for parties
who have cleaned up sites or spent money to restore natural resources. This program focuses on remediation of
inactive sites.
AUTHORITY: Legislative authority for the program is enabled under the following public laws:
•	CERCLA; and
•	Superfund Amendments and Reauthorization Act (SARA).
OBJECTIVE(S):
•	To identify sites where hazardous substances have been, or might have been, released into the
environment;
•	To ensure that the sites are cleaned up by responsible parties or the government;
•	To evaluate damages to natural resources; and
•	To create a claims procedure for parties who have cleaned up sites or spent money to restore natural
resources.
JURISDICTION: The scope of this program encompasses all areas within the Florida Keys and the FKNMS. This
area, like all others in the United States, is subject to the provisions and regulations promulgated as a result of
CERCLA and SARA.
OPERATION: The Region IV Superfund staff coordinates its efforts with FDER. While there are 30 Superfund
sites in south Florida, there are none in the Florida Keys; therefore, this particular EPA program is not relevant
to the FKNMS program. Federal installations that handle and dispose of hazardous materials like those used at Boca
Chica Naval Air Station are managed under the RCRA program. The Naval Air Station is still an active facility;
therefore, its activities are managed by the RCRA Section.
FUNDING: The Superfund staff costs are funded out of the Region IV operating budget.
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STAFFING: There are 10 staff members assigned responsibility for administering the Sup:rfund program south
of Orlando.
TRACKING: Remediated sites are monitored every five years to evaluate continued effectiveness of the remedial
action.
3.1.1.14 UNDERGROUND STORAGE TANKS
PROGRAM RESPONSIBILITIES: This program is responsible for regulating underground storage tanks (UST)
to ensure that current and potential future drinking water sources are not contaminated by leaking tanks.
AUTHORITY: Legislative authority for the task performed by this section is enabled under the following public
law:
• RCRA Subtitle I, Regulation of Underground Storage Tanks.
The administrative rules under which the unit functions are incorporated within 40 CFR Parts 280 and 281,
Underground Storage Tank Regulations.
In addition, EPA has authorized the FDER through an MOA to implement the Underground Storage Tank Program
in accordance with 40 CFR Part 280.
OBJECTIVE(S): To prevent USTs from leaking, to locate existing USTs that are leaking, and to clean up those
that have been identified as having a leaking problem.
JURISDICTION: All USTs that exist within the FKNMS are subject to the rules and regulations of RCRA, Sub-
title I.
OPERATION: RCRA Subtitle I grants EPA primary authority for developing and enforcing the UST Program.
This program exempts all USTs larger than 110 gallons, tanl" storing very low concentrations of regulated
substances, and emergency backup tanks holding regulated substances for only a short period of time and
expeditiously emptied after use.
Within Florida, USTs are regulated by the FDER through an MOA with EPA. Nothing in the MOA restricts in
any way EPA's authority to fulfill its oversight and enforcement responsibilities under Subtitle I of RCRA. The
state is responsible for implementing the technical standards, corrective action requirements, and financial
responsibility requirements, as described in Part 280, Subparts A-H. This MOA is reviewed annually.
Modifications to the MOA may be made to ensure consistency with the state program modifications, and federal
regulatory changes, or upon request of either EPA or FDER.
FUNDING: Region IV UST program staff positions are funded in part with monies from the National Leaking
Underground Storage Tank Trust Fund and from the general EPA Region IV operating budget.
Annually, Florida receives grant funds from EPA Region (V to assist the state in meeting its responsibilities under
the MOA. The grant has averaged $160,000 annually
STAFFING: The Region IV staff has three key functions: providing overall program oversight, enforcing
compliance with the! program requirements, and administering grant fund programs. Because Florida has an
extensive program in place, Region IV staff focuses its attention on states with less sophisticated UST programs.
No staffing needs were identified.
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TRACKING: The FDER submits quarterly reports to Region IV that document the number of sites that had leaking
tanks that have been cleaned up, and the number of new sites where leaking tanks have been found. In addition,
Region IV staff meets approximately two to three times per year with FDER in its overs-"' t capacity.
3.1.2 U.S. Coast Guard
3.1.2.1 OIL AND HAZARDOUS SUBSTANCE SPILLS
PROGRAM RESPONSIBILITIES: The 7th USCG District Marine Safety Office staff is responsible for spill
contamination within navigable waters of the Florida Keys. As responsible agency, it is the first point of contact
for all spills taking place in coastal waters.
AUTHORITY: The USCG receives its legislative authority regarding oil spill response from the Section 311 of
theCWA.
OBJECTIVE(S): To ensure that the recovery and cleanup of oil and hazardous substances from the waters of the
United States is done as quickly and efficiently as possible to eliminate any long-term impact to the marine
environment.
JURISDICTION: The USCG has lead responsibility for oil spill response within or threatening the coastal zone
(tidal waters); EPA directs cleanup in nontidal waters. Therefore, the USCG is the responsible agency in the
FKNMS.
OPERATION: When a spill occurs, it becomes the primary duty of the responsible party to see that adequate
actions are taken to clean up the spill. If a spill is handled by the responsible party or its contractor, the USCG
assumes an oversight role. In that role, the USCG constantly monitors the effectiveness of the spill clean-up effort.
As long as the spill is being adequately cleaned up, the USCG will not become directly involved. However, should
the USCG determine that the effort is not being adequately handled, the USCG would assume responsibility and
activate proper clean-up procedures. The USCG would contract with one of the clean-up firms that is on the USCG
"Base Ordering Agreement" list. This list includes firms that have a successful spill clean-up history, proper
equipment, experience with preferred USCG record keeping procedures, and clean-up crews with adequate levels
of training.
If the spill occurs in open ocean waters or the scale of the spill is significant, the USCG activates the Gulf Coast
Strike Team out of Mobile, Alabama. This occurs because independent contractors do not have the type of
equipment necessary for large spills in open ocean waters. The Strike Team has skimmers and retrieval vessels
available for immediate response.
The USCG interacts closely with NOAA during spill clean-up operations. There is a NOAA Scientific Support
Coordinator located in Miami. This individual provides the USCG with information about the presence of sensitive
environmental resources in the vicinity of the spill or in the area of the projected trajectory. Modeling oil spill
trajectories is another support service NOAA provides to the USCG.
FUNDING: Administrative costs incurred in oil and hazardous substance spill erations are funded out of the
USCG operating budget. Federal funds are available to underwrite the cost of c..anup. They come from the Oil
Spill Liability Trust Fund. These costs are recoverable from the responsible party according to the CWA 31 l(b)( 10)
as amended by the Oil Pollution Act of 1990.
STAFFING: The Marine Safety Office has 10 individuals involved in marine pollution activities; however,
dependent upon the seriousness of the event, additional USCG staff may be assigned to the task.
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TRACKING: The USCG monitors spill clean-up operations of the responsible party or contractor as they are
ongoing.
3.1.2.2 MARINE SANITATION DEVICES
PROGRAM RESPONSIBILITIES: The USCG has the responsibility of governing the design, construction, and
installation of marine sanitation devices that either retain, dispose of, or discharge sewage. In addition, the USCG
is responsible for ensuring that vessels contain USCG-certified marine sanitation devices.
AUTHORITY: Legislative authority for this program set out in Section 312 of the CWA.
The following administrative rules regulate activities related to marine sanitation devices:
*	33 CFR Part 159 — Marine Sanitation Devices Certification Process; and
•	40 CFR Part 140 — Marine Sanitation Device Standard.
OBJECTTVE(S): To prevent the discharge of untreated or inadequately treated sewage into or upon navigable
waters from new and existing vessels equipped with installed toilets.
JURISDICTION: The scope of this program extends throughout the FKNMS.
OPERATION: Any individual or corporation that designs and builds a marin sanitation device must first submit
the device to the USCG for certification. Marine sanitation devices are des.^ned and operated to either retain,
dispose of, or discharge sewage. The USCG has the authority to ensure that ie device is working satisfactorily.
Generally, the USCG only enforces the marine sanitation device provisions c 40 CFR Part 140 if it has boarded
a vessel for some other reason, such as drug interdiction.
Section 312(f)(1) of the CWA gives the states the authority to regulate the der jn, manufacture, installation, or use
of any marine sanitation device on a "houseboat" if state standards enacted un ;r this section of the CWA are more
stringent than those set out in Section 312 of the CWA. However, Florid;} las never sought to regulate marine
sanitation devices. Houseboat is defined as "a vessel, which for a period of 
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3.1.3 National Oceanic and Atmospheric Administration
3.1J.1 FLORIDA KEYS NATIONAL MARINE SANCTUARY PROGRAM
PROGRAM RESPONSIBILITIES: NOAA has lead responsibility for preparing a comprehensive management plan
for the FKNMS. The program is to be prepared in accordance with the procedures specified in Sections 303 and
304 of the MPRSA.
While all national marine sanctuaries are required to prepare comprehensive management plans, the FKNMS
legislation recognized the overriding importance of water quality in the Florida Keys. Included in the legislation
is the requirement to prepare a WQPP for the FKNMS. While NOAA does not have the lead role in the
development of the WQPP, it will make a determination of whether or not the WQPP is consistent with the FKNMS
Comprehensive Management Plan. EPA and the Governor of the State of Florida have lead responsibility in
developing the WQPP for the FKNMS.
AUTHORITY: The FKNMS Program has been established based on the following public laws:
•	Title III — National Marine Sanctuaries Act (as amended); and
•	Public Law 101-605 — Florida Keys National Marine Sanctuary and Protection Act.
More specifically, the purposes of the WQPP will be to
. 1. recommend priority corrective actions and compliance schedules addressing point and nonpoint sources
of pollution;
2.	assign responsibilities for the implementation of the program;
3.	address legal, institutional, and management issues and recommend changes;
4.	establish a comprehensive water quality program;
5.	provide adequate opportunity for public participation; and
6.	identify funding mechanisms to implement the WQPP.
OBJECTIYE(S): Three objectives are set out in the Florida Keys National Marine Sanctuary and Protection Act
as follows:
•	To protect the resources of the Florida Keys;
•	To educate and interpret for the public regarding the Florida Keys marine environment; and
•	To manage human use in the sanctuary consistent with the Act.
Further, Title III — National Marine Sanctuaries Act (as amended) contains the following objectives:
•	To provide authority for comprehensive and coordinated conservation and management of those marine
areas that will complement the existing regulatory authorities; and
•	To support, promote, and coordinate scientific research of those marine waters.
JURISDICTION: The FKNMS area of jurisdiction extends seaward of the mean low tide line to the outer boundary
as defined in the Florida Keys National Marine Sanctuary and Protection Act.
OPERATION: NOAA has primary responsibility to prepare the comprehensive management plan for the FKNMS.
The WQPP prepared by EPA and the State of Florida is to be incorporated into the comprehensive management
plan. NOAA is participating in the development of the WQPP in a consultation role, and providing technical
information needed for developing the WQPP.
FUNDING: In 1991, $100,000 was appropriated fbr the Florida Keys WQPP under the Near Coastal Waters
Program. In addition, $200,000 was provided through EPA Headquarters from the CWA, Section 104(b)(3).
Funding for 1992 is being provided via Congressional add-on in the amount of $625,000.
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STAFFING: NOAA has several staff members who participate in the development of the WQPP and provide
>mjra| information needed for the plan. One EPA staff member located in the Region IV Coastal Planning Unit
works full tinw as the Florida Keys Project Manager and interacts frequently with the NOAA staff.
TRACKING: Tracking of program performance is based on milestones and work products set out in the annual
work program. Frequent communication between the EPA Project Manager and other involved resource agencies
and consultants occurs to ensure that the WQPP now being prepared results in an acceptable product. The WQPP
will identify how compliance will be monitored.
3.1 J.2 COASTAL ZONE MANAGEMENT ACT
PROGRAM RESPONSIBILITIES: The Department of Commerce through NOAA has been charged with the
responsibility of administering the provisions the CZMA. NOAA reviews and approves all state Coastal Zone
Management Programs (CZMPs). Once approved, all federal activities within a state's defined coastal zone
boundary must be consistent with the state's adopted CZMP, except when the "national interest" is at stake.
Annually, NOAA provides grant funds to states to support the implementation of the CZMPs.
AUTHORITY: The legislative authorization establishing the federal role in managing the coastal ecosystem is set
out in the CZMA.
OBJECTIVE(S):
*	To protect, maintain, and develop the natural, commercial, recreational, ecological, industrial, and
aesthetic resources in the coastal zone;
*	To achieve coordination among state, regional, and local officials and agencies; and
*	To involve citizens of the state in coastal zone issues.
JURISDICTION: All areas of the FKNMS are subject to the provisions of the CZMA.
OPERATION: NOAA approved Florida's CZMP in September 1981. Annually, NOAA processes the state CZMP
grant application. These funds are used to augment those of the state for the purpose of implementing the state's
CZMP.
FUNDING: NOAA staff positions are funded through the general operating budget of the agency. The amount of
state CZMP grants is dependent upon annual Congressional appropriations. CZMP monies made available to states
comes from Section 306 of the CZMA.
STAFFING: NOAA coordinates with the State of Florida regarding CZMP matters through the Gulf and Caribbean
Branch of Coastal Programs, Division of Coastal Resource Management.
TRACKING: A thorough examination of the implementation and effectiveness of the state CZMP is undertaken
every three years, and a limited review at the time the state CZMP grant is negotiated. The state also submits
quarterly progress reports. NOAA staff makes periodic visits to Tallahassee to interact with the state administrators
of the CZMP.
3.1.4 U.S. Army Corps of Engineers
3.1.4.1 DREDGE AND FILL REGULATION
PROGRAM RESPONSIBILITIES: The USACE Regulatory Division has responsibility for issuing and enforcing
permits involving dredge and fill activities or permits for placement of structures in waters of the United States.
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AUTHORITY: Legislative authority for the program is enabled under the following public laws:
•	Section 10 of the Rivers and Harbors Act of 1899;
•	Section 404 of the CWA; and
•	Section 103 of -lie MPRSA.
OBJECTIVE(S): To determine whether the proposed activity is or is not contrary to the public interest. Criteria
used to make such a determination address issues related to water quality degradation, endangerment to wildlife and
plant communities, archeological impact, and public safety.
JURISDICTION: US ACE jurisdiction extends throughout the Florida Keys and FKNMS. In the instance of Section
404 dredge and fill permits where both the USACE and EPA have specific and separate roles, the USACE and EPA
have entered into a MOA regarding jurisdictional determination. In practice, the USACE generally makes the
determination.
OPERATION: The focus of this operation description is on Section 404 permits. The USACE has primary
responsibility for issuing Section 404 permits for the discharge of dredge and fill material into "navigable waters."
In the Florida Keys, much of the land area falls under the USACE jurisdiction. Compared to the other southern
Florida counties of Palm Beach, Broward, and Dade, the number of Section 404 applications submitted in Monroe
County is considerably higher. In the past year, over ISO applications were submitted from Monroe County.
Statewide, an estimated 1,000-1,500 applications were processed by the USACE. The permit applications ranged
from requests to place fill on lots for house pads and driveways, to fill needed to plant trees in yards.
Initial screening of permits is conducted out of the Miami USACE office. The more complex and controversial
permits are processed in the Jacksonville District USACE office. The USACE has one full-time staff person
stationed in Marathon whose sole job involves processing various aspects of Section 404 permit applications in the
Florida Keys. Most of his time is spent making jurisdictional determinations and conducting permit compliance
inspections. Jurisdictional determinations are undertaken when requested by citizens wanting to know if a permit
is required. EPA has authority to determine jurisdiction as well; however, the Agency generally defers to the
USACE.
During the permitting process, the USACE sometimes discusses projects with relevant federal resource agencies,
i.e., Department of Agriculture, Department of Agriculture's Stabilization and Conservation Service, the Department
of Interior's U.S. Fish and Wildlife Service (FWS), the Department of Commerce's National Marine Fisheries
Service (NMFS), and EPA. In the Florida Keys, the USACE consults primarily with EPA, NMFS, and FWS.
Both the USACE and EPA have enforcement responsibilities under Section 404. EPA has statutory enforcement
authority for cases in which no permit has been obtained prior to the dredging or filling of material into "navigable
waters" of the United States. The USACE only provides enforcement for cases in which there has been a violation
in a Section 404 permit they have issued. Both the USACE and EPA have authority to seek civil or administrative
remedies for discharges into wetlands. In addition, EPA can pursue criminal action in its enforcement areas.
Under Section 404(c), the EPA can "veto" permits that have already been USACE-approved if use of the site will
have an unacceptable adverse effect on municipal water supplies, shellfish beds and fishery areas, wildlife, or
recreational areas. In reality, EPA had exercised this veto action only 11 times nationwide since the CWA was
enacted.
There are three MOAs between the USACE and EPA. They address procedures and coordination matters. One
involves an "elevation" of a permit decision if EPA has serious objections to the proposed permit written by the
USACE. The "elevation" delays the project and subjects the proposed permit to higher peer review. Another MOA
between the USACE and EPA addresses the issue of mitigation, and the third MOA addresses jurisdiction.
Compliance reviews are conducted by staff members as well as by a private contractor. The contractor is used for
initial compliance review of selected permits. This is a sort of "screening process" that allows the USACE to focus
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attention on the more s-nous violations. Based on the results of the initial review, if additional compliance
inspections are wa: /ante , they are conducted by US ACE staff.
FUNDING: The USACE Section 404 activities are funded through annual Congressional appropriations. Although
no specific funding figures were available, it was indicated that funding has gone up significantly over the past
several years. Increased funding has resulted in the Jacksonville District hiring 11 people during the past year.
STAFFING: There is one full-time field person located in Marathon. The only other staff person working full time
on USACE Florida Keys projects is located in the Jacksonville District Office. Although there is a Miami office,
it is involved only minimally It becomes involved when there is an unusually high number of permit applications
in the Florida Keys.
TRACKING: Information generated via the permitting and compliance process is being entered into the USACE
database known as the Regulatory Analysis Management System (RAMS). It contains the Section 404 permits and
special conditions, as well as data on compliance inspection. The existing RAMS database can be queried by the
USACE Project Manager; however, this feature has not been used that much to date. As the database evolves and
the level of computer sophistication increases, it is anticipated that querying of the database will increase. The
USACE does not share its permit database information with other federal, state, regional, or local agencies.
3.1.5 U.S. f ish and Wildlife Service
3.1.5.1 FISH AND WILDLIFE COORDINAT ON ACT
PROGRAM RESPONSIBILITIES: To protect
to provide technical assistance to Federal, State, &
and investigations of wildlife of the public dorm
agencies, and to accept donations of land and cor,
habitat.
e wildlife resources and associated habitats, the FWS is directed
i public and private agencies and organizations, to make surveys
t, including lands and waters acquired or controlled by federal
ibutions of funds to further the protection of the wildlife and its
AUTHORITIES: The FWS receives its legislati ; authority through Public Law 85-624, 72 Stat. 563; 16 U.S.C.
661 et seq.
OBJECTIVE(S): To provide that wildlife cons rvation receives equal consideration and is coordinated with other
features of water-resource development progr ns through effective and harmonious planning, development,
maintenance, and coordination with wildlife conservation and rehabilitation efforts.
JURISDICTION: The scope of the program encompasses all areas within the Florida Keys and the FKNMS.
OPERATION: Coordination of wildlife resources and habitat concerns in the Florida Keys is administered out of
the FWS Vero Beach Office of Ecological Services. The office serves an area extending from Tampa/Vera Beach,
south.
Coordination activities involve both, regulatory and planning matters. In the Keys, most coordination issues involve
dredge and fill permit applications; however, the FWS has also assisted in the Smathers Beach beach renourishment
program, and has been involved in discussions regarding the siting of a school on Big Pine Key. The Service has
been active in the development of the FKNMS planning effort.
Whenever a federal agency seeks to undertake a project or any public or private agency seeking a federal permit
or license (e.g., dredge and fill), the applicant must consult with the FWS. When a request is received, the FWS
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investigates and prepares a resort containing an analysis of the impacts of the proposed action on the wildlife
resources and associated habitat, and recommendation(s) to mitigate the loss of or damage of the wildlife resources
and brbitat.
FUN. iNG: Annually, the FWS funds a portion of the program out of its operating budget. This provides the
program with a "base level of funding". Additional revenues are generated via federal interagency transfers.
Whenever a federal agency requests that the FWS conduct an investigation and prepare a report regarding a specific
federal permit or project, the agency must cover the cost to conduct the FWS evaluation^ In the case of state or
local agencies, or private organizations, the FWS baseline funding covers the expenses incurred.
STAFFING: The Verq Beach office nas several biologists that handle regulatory responsibilities; however, only
one of those individuals is assigned to the Keys. This person also is responsible for activities occurring in Dade
County. There are three other biologists that serve specialized roles. One deals solely with endangered species
issues, another is involved in environmental contaminants and marine ecology, and the third deals with beach
erosion and renourishment issues as they relate to wildlife resources and habitat. There is a shortage of staff;
therefore, project monitoring stiffen.
TRACKING: The project reports and recommendations prepared by the FWS staff is followed up to some degree.
The quality of the monitoring effort depends upon staff limitations. The FWS tracks projects through status or
monitoring reports, and field inspections (number of inspections depends upon manpower available). The FWS has
no methodology for evaluating program effectiveness.
3.1.5.2 ENDANGERED SPECIES ACT OF 1973
PROGRAM RESPONSIBILITIES: Federal agencies are required to consult with the FWS to ensure that their
proposed federal permit action or project will not jeopardize the continued existence of any endangered species or
threatened species or result in the destruction or adverse modification of habitat of such species which is determined
by the Secretary of the Interior, after consultation as appropriate with the affected state, to be critical, unless
exempted from such protection in accordance with the exemption process set out in the Act.
AUTHORITIES: Legislative authority for this program is est out in the Endangered Species Act of 1973. The
administrative rule specifying the responsibilities of the FWS is SO CFR.
OBJECTIVE(S):
•	To provide a means whereby the ecosystems upon which endangered species and threatened species
depend may be conserved; and
•	To provide a program for the conservation of such endangered species and threatened species that are
in danger of or threatened with extinction.
JURISDICTION: The scope of the program encompasses all areas within the Florida Keys and the FKNMS.
OPERATION: Relative to the Florida Keys, this program's regulatory responsibility rests with the FWS Office
of Ecological Services located in Vero Beach. Each federal agency is required to ensure that any action it authorizes
or carries out is not likely to jeopardize the continued existence of endangered or threatened species, or result in
destruction or adverse modification of their critical habitat. Once consultations and investigations are completed
a written statement setting forth the Department's opinion is prepared. If jeopardy or adverse modification is
determined, the Department will suggest reasonable and prudent alternatives that can be taken to implement the
federal agency action.
The program contains penalty and enforcement provisions that are to ensure compliance with the provisions of the
Act.
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The FWS is involved in the environmental planning and management of "Trust Resources" (i.e., migratory birds,
rap tar birds, andranomous fishes, habitats of above, wetlands). This can include preparation of recovery plans.
Also, the FWS becomes involved in oil spill contingency planning.
FUNDING: The Endangered Species program is funded out of the FWS general operating budget.
STAFFING: Staff located in the Florida Keys are involved in refuge management. The Vera Beach office has
several biologists that handle regulatory responsibilities; however, only one person is assigned to the Keys. This
individual also pm^mtimniir responsibility for Dade County. Within the Vero Beach office there is only one
biologist with expertise regarding wildlife and habitat having a federal designation as Threatened and Endangered
Species. This one individual must cover all areas south of Tampa/Vero Beach. This program also includes two
enforcement officers located in Miami responsible for enforcing the provisions of the Act.
TRACKING: The program is tracked through status and monitoring reports and/or field inspections. Violations
are pursued in accordance with the program's enforcement provisions.
3.2 STATE
3.2.1 Florida oartment of Agriculture
3.2.1.1 MOSQUITO CONTROL
PROGRAM RESPONSIBILITIES: The state \ quito Control Program is administered by the Bureau of
Entomology and Pest Control. Responsibilities c. he state office involve oversight responsibility for all local
mosquito control programs; review and approval < ill county or mosquito control district work plans and work
budgets; and administration of state funding progrr
While the State's function is more administrative ;ฆ iarure, local mosquito control districts implement arthropod
control. In Monroe County, the Mosquito Contra: district is an independent special taxing district comprised of
a locally elected board. The Mosquito Control I trict headquarters is located on Stock Island. Its primary
responsibilities involve eradication of adult mosquit. ; and larval control.
AUTHORITY: Legislative authority for the Mosq i Control Program is contained in Chapter 388 Florida Statute
XFS).
OBJECTIVE(S):
•	To achieve and maintain such levels of arthropod control as will protect human health and safety and
foster the quality of life of the people;
•	To promote the economic development of the state, and facilitate the enjoyment of its natural
attractions by reducing the number of pestiferous and disease-carrying arthropods; and
•	To conduct arthropod control in a manner consistent with protection of the environmental and
ecological integrity of all lands and waters throughout the state.
-JURISDICTION: This program is administered by the Florida Department of Agriculture throughout Florida. The
Mosquito Control District has jurisdiction throughout Monroe County, including both incorporated and
unincorporated areas.
OPERATION: The Bureau of Entomology and Pest Control permits the types of application procedures that local
mosquito control districts must use. The Bureau also conducts training courses and licenses operators.
The Mosquito Control District applies pesticides via aerial spraying or truck spraying to control the adult mosquito
population. Which method is used depends on the level of infestation, which is determined by the information (e.g.,
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mosquito counts) District inspectors collect daily throughout t ie Florida Keys. Aerial spraying is conducted out
of the Marathon Airport. In addition to Marathon, there are three other staging areas in the Florida Keys. They
are Key Largo (at Mile Marker 100), Islamorada, and Stock Island.
FUNDING: The primary source of funds for the Monroe County Mosquito Control District are generated from ad
valorem taxes. Historically, the District received substantial funds from the State, approximately $135,000annually;
however, recent cutbacks in state revenues have severely curtailed the amount of state funds to the District. It is
anticipated that the District will receive approximately $15,000 for fiscal year 1992-1993.
STAFFING: There are 8 full-time professional staff members assigned to the Mosquito Control Program in the
Department of Agiiculture. The District has 36 full-time staff members. Sixteen are field inspectors. Others
include office administrators, supervisors, a pilot, and mechanics.
TRACKING: The Mosquito Control District maintains detailed logs containing the locations where all applications
of pesticides are made, when they are made, how they are made (i.e., aerial spraying or surface spraying), and
specifically what types of pesticides are used. These logs are transferred to the Bureau and maintained for future
reference.
District field inspectors also maintain detailed records of mosquito counts they make daily. The District Director
is hoping to computerize the information once funds become available.
3.2.2 Florida Department of Community A flairs
3.2.2.1 AREAS OF CRITICAL STATE CONCERN
PROGRAM RESPONSIBILITIES: The Areas of Crtical State Concern (ACSC) staff is located in the Bureau of
State Planning. It is responsible for review of all deve pment plans and permits including site visits; administration
of all resource planning and management committees and review of all comprehensive plans, plan amendments,
and development regulations within designated ACSC
AUTHORITY: Legislative authority for administering this program is contained in Section 380.05 FS.
OBJECTIVE(S): The objective of this program is to provide another level of legislative review for development
plans within areas where unique and fragile natural resources exist and local protection is lacking. ACSC are
declared where there is a perceived need to protect public resources from risk by unregulated or inadequately
regulated development. Specific ACSC objectives that address water quality issues in the FKNMS are as follows:
•	To coordinate with local governments and planning authorities responsible for the Florida Keys area
to ensure that their adopted comprehensive plans or amendments to the adopted plans are consistent
with the legislative principles adopted for guiding development in ACSC;
•	To strengthen local government capabilities for managing land development and growth in a manner
consistent with ACSC principles so that the ACSC designation may be removed from the Florida Keys;
•	To protect marine resources and shorelines including wetlands, mangroves, seagrasses, coral reefs,
and their respective faunas;
•	To protect upland resources including tropical biological communities, freshwater wetlands, native
vegetation, dune ridges, beaches, and wildlife; and
•	To limit the adverse effects of development on water quality throughout the Florida Keys.
JURISDICTION: Technically, this program has very little jurisdiction with the FKNMS area because the ACSC
program jurisdiction ends approximately 250 ft seaward of the mean high water line. However, this program is
important to the FKNMS because of the limits placed on upland development.
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OPERATION: Local governments within an A CSC must give notice to the Florida Department of Community
Affairs (FDCA) of any development permit application, amendment to the adopted comprehensive plan, or revision
or addition to the local government's land development regulation for review and comment. The FDCA may appeal
any development order issued by a local government to the Governor and Cabinet. No wofk authorized by the
developer can take place once an appeal has been filed. Following a hearing, the Governor and Cabinet issue a
decision either granting or denying permission to develop, based on standards and rules in Chapter 380 FS known
as the Principles for Guiding Development. The Governor and Cabinet may attach specific conditions and
restrictions to their decision. The FDCA must approve any amendments to the comprehensive plan or land
development regulation or they do not become effective. While a number of areas have been studied for
designation, only five areas have actually been designated since the legislation was originally enacted in 1979.
In addition to reviews of development permits, comprehensive plan amendments, and revisions or additions to local
government land development regulations, the FDCA, in accordance with the statutory law defining this program,
established the Florida Keys Resource Planning and Management Committee. The purpose of the committee is as
follows:
in state and local governments;
j.s to the FDCA as to the sufficiency of the comprehensive plans and land
n the Florida Keys;
;s to the FDCA concerning changes in regional and state comprehensive plans
affecting the Florida Keys;
•ats in carrying out planning functions; and
u agency reports relative to the Flonda Keys.
To serve as liaison ber
To make recommends
development regulati.
To make recommenc
and regulatory prog.
To assist local gover
To review all govern;
The committee functions through fc
of local governments in relation to
Water Quality Subcommittee, and
time to coordinate policy matters u
active. Recently, the Subcommittee
such as wastewater, stormwater, c:
Further, Section 380.0S1 FS dest
Coordinated agency review moanc
design features, and environmental
coordinated agency review proced:
procedures. At a minimum it i?
Flonda Department of Health and
agencies enter into local intergove
streamlined set of permitting proc,
and data collection methodologies,
remains in the statute.
subcommittees: the ACSC Subcommittee (responsible for reviewing progress
als of the ACSC program), Intergovernmental Coordination Subcommittee,
enprehensive Planning Subcommittee. These committees meet from time to
arise in the Florida Keys. The Water Quality Subcommittee has been quite
nalized a series of water-quality recommendations that addressed issue areas
oas, and mosquito spraying.
>es steps to be taken to institute a coordinated agency review process,
/iew of the proposed location, densities, intensity of use, character, major
'.pacts of a proposed development. It directs the FDCA to develop by rulr
with various state agencies, which must also adopt rules specifying revie
ฆnclude the FDER, Florida Department of Natural Resources (FDNR), ann
abilitative Services (FDHRS). In addition, it mandates that state and regional
ntal agreements with local governments in the Florida Keys to achieve a more
ฆs. This would include standardizing review procedures, data requirements,
Tiile this portion of the statute has never been fully implemented, it still
FUNDING: This program was funde litially by a $6-million appropriation specifically for the Florida Keys from
the state legislature in 1986. A I je portion of this money has been spent on land acquisition and on
comprehensive planning. Current funding comes from the ACSC statewide trust fund.
STAFFING: Bureau of State Planning personnel assigned to the ACSC program include five administrative
personnel in Tallahassee and five agency field office personnel located in Key West.
TRACKING: This program is administratively tracked by the development orders, comprehensive plan
amendments, and changes to land development regulations. Success or failure of the program depends on meeting
goals established in the Principles for Guidance Development; however, there is no comprehensive monitoring
program in place to assess the biological health of the natural resources.
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3.2.2.2 DEVELOPMENTS OF REGIONAL IMPACT
PROGRAM RESPONSIBILITIES: The Developments of Regional Impact (DRI) Program is administered by the
DRI stafflocated within the Bureau of S' Planning. A DRI is defined as a development that, because of its size,
character, and location, would substantia .y affect the health, safety, or welfare of the citizens of more than one
county. There are 14 types of development subject to the DRI rules, including large residential projects, offices,
industrial sites, retail uses, hospitals, marinas, airports, post-secondary schools, mining operations, petroleum
storage facilities, and hotels. This program involves a comprehensive assessment of the regional impacts by the
appropriate Regional Planning Council (RPC) prior to the proposed development being approved by local
government
AUTHORITY: Legislative authority that authorizes the DRI process is contained in Section 380.06 FS —
Environmental Land and Water Management. The rules through which this process functions are set forth in
Chapter (9J-2 of the Florida Administrative Code (FAC).
OBJECTTVE(S):
•	To protect the natural resources and environment of the state;
•	To ensure a water management system that will reverse the deterioration of water quality and provide
optimum utilization of limited water resources;
•	To facilitate orderly and well-planned development; and
•	To protect the health, welfare, safety, and quality of life of the residents of the state.
JURISDICTION: The DRI process applies to all areas of Monroe County just as it does in any other county m the
State of Flonda.
OPERATION: The Bureau of State Planning DRI staff is responsible for determining if a project requires a DRI
review. If the project is determined to be a DRI, the developer must .hen file an application document with the
local government of jurisdiction, the appropriate RPC, and the Burec i of State Planning. The DRI process is
coordinated by the local RPC and includes participation of all interes -d agencies. In the case of developments
adjacent to the FKNMS, this will be the South Florida RPC. Undoubt ily, many environmental groups associated
with the FKNMS would participate. The local RPC receives technics; rapport from the Bureau of State Planning
staff in Tallahassee. The RPC submits an assessment report thai summarizes the anticipated impacts and
recommends to local government whether the project should be approv d, modified, or denied. Local government
is required to make the final decision on the approval or denial of th DRI at a public hearing. The developer,
RPC, and FDCA have the right to appeal this decision to the Governs and Cabinet sitting in their capacity as the
Land and Water Adjudicatory Commission.
Recently, the Marathon Airport terminal expansion underwent a DRI review. The RPC indicated that the Key West
Airport expansion program may also trigger DRI review. In terms of water quality, airport expansions are of
concern, because existing facilities are close to coastal waters and hazardous materials are heavily used. Further,
new marinas ISO wet slips or greater or 200 dry slips or greater, are a DRI and among other issues, create a water
quality concern.
FUNDING: Positions in the Bureau of State Planning are funded out of the state operating budget. The South
Florida RPC defrays such costs by imposing special DRI fees.
STAFFING: There are 18 positions within the DRI Section of the Bureau of State Planning. Of those, one person
is assigned to monitor and track DRIs in Broward ( Dade, and Monroe counties. In terms of the RPC, there is a
DRI Coordinator; however, there are seven other planners who provide technical support in various aspects of DRI
reviews such as traffic, environment, drainage, and wastewater.
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TRACKING: The prog'" - is tracked through letters of interpretation, DR1 applications and docunents, and annual
DRI monitoring reports emitted by the RFC. In addition, the FDCA and RPCs coordinate with one another
extensively.
3.2.2.3 LOCAL COMPREHENSIVE PLANNING
PROGRAM RESPONSIBILITIES: The overall statewide responsibilities of the local comprehensive planning
process are as follows:
•	Plan for sound infrastructure;
•	Properly manage natural resources;
•	Provide for adequate education;
•	Maintain an attractive quality of life;
•	Provide a regulatory atmosphere that encourages enterprise; and
•	Develop fiscal stability characterized by reasonable tax rates.
AUTHORITY: Legislative authority for the comprehensive planning process is mandated under the following
statutes:
•	Chapter 163 Part II FS — The Local Government Comprehensive Planning and Land Development
Regulation Act — Confers on local officials the statutory authority and responsibility to plan and
regulate the use of land by adopting local comprehensive plans and land development regulations;
•	Section 186.507 FS — Outlines the requirements of comprehensive regional policy plans;
•	Chapter 187 FS — The State Comprehensive Plan — A compilation of goals and objectives that
Florida is to achieve through the planning process; and
•	Chapter 380 — Land and Water Management.
The rules that implement Section 163.3161 FS are as follows:
•	Chapter 9J-5 FAC — Minimum Criteria for Review of Local Government Comprehensive Plans and
Determination of Compliance;
•	Chapter 9J-11 FAC — Submittal Requirements for Proposed Local Government Comprehensive Plans;
and
•	Chapter 9J-24 FAC — Procedures and Criteria for the Review of Land Development Regulations.
OBJECTIVE(S): Local governments have the responsibility for regulating and planning the use of lands and land
development within their jurisdictions. The Bureau of Local Planning is responsible for reviewing local government
growth management plans and ensuring that the plan is in compliance with the requirements of Rule 9J-5 FAC, and
is integrated on state, regional, and local levels. Vertical integration occurs among the State Comprehensive Plan,
comprehensive regional policy plans, and local government comprehensive plans. Land development regulations
must be adopted that are consistent with and implement the local comprehensive plan. Levels of service standards
that are adequate and realistic must be adopted for public services and facilities located within each government's
jurisdiction.
JURISDICTION: The comprehensive planning process as coordinated under the Bureau of Local Planning affects
all upland areas adjacent to the FKNMS (i.e., Monroe County). There are four local government entities in this
area, including Monroe County, the City of Key West, the City of Layton, and the City of Key Colony Beach. In
addition, the regional comprehensive plan developed by the South Florida RPC affects water quality within the
FKNMS in the same manner as local government plans.
The local government comprehensive plan process has the potential to significantly affect water quality within the
FKNMS based on:
•	Maintaining or reducing hurricane evacuation time, which would create restrictions on upland
development limiting future growth in the Florida Keys;
•	Control of upland land development procedures;
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•	Stormwater runoff retention requirements; and
•	Sanitary sewer and wastewater treatment facilities level of service requirements.
OFERAT N: The comprehensive planning process for the Florida Keys has been an interactive process between
the FDCA and the government entities in Monroe County. This process is facilitated by a FDCA field office
located in Key West Field office staff members review the plan for consistency with the Principles for Guiding
Development, and make recommendations to the main office in Tallahassee. Final decisions on the acceptability
of the proposed comprehensive plans and their amendments are made in Tallahassee.
The current status of the local government comprehensive planning process in the Florida Keys is as follows.
•	Monroe County has adopted and submitted its plan. The plan has been found to be noncompliant.
Negotiations were conducted and a settlement agreement was signed (see below). A remedial plan has
been submitted to the FDCA. This plan is being revised by the County and is due to be adopted in
early 1993. Another compliance determination will be made by the FDCA at that time.
•	The City of Key West has adopted and submitted an initial plan which was found to be noncompliant.
The City has been working with FDCA staff and some differences have been resolved, but the FDCA
and the City have yet to officially enter into a settlement agreement.
•	The City of Layton has adopted and submitted a plan which was found to be noncompliant. No
settlement agreement has been reached between the City of Layton and the FDCA.
•	The City of Key Colony Beach has adopted a plan and submitted it to the FDCA. This plan was
originally rejected by rule, but subsequently amended by the City and approved by the FDCA.
Exhibit C (Monroe County Remedial Actions) of the FDCA's Settlement Agreement with Monroe County contains
the following amendments to existing policy statements affecting water quality within the FKNMS.
•	Storm Water Plan — The County should complete a Storm Water Master Plan within one year of
funding becoming available for the necessary engineering studies. A long-term funding source such
as a "stormwater authority" is to be established specifically for the implementation of the stormwater
management plan. The master plan will incorporate drainage level of service standards for all
developed and/or redeveloped areas, and best management practices for single family residences,
which address water quality and quantity.
•	Wastewater Plan — The County should develop, through the Florida Keys Aqueduct Authority
(FKAA) or other appropriate entity, a comprehensive wastewater management plan that will address
central sewer system possibilities, package plants, and alternative on-site disposal systems. This
master plan shall contain a fully integrated approach to water management from the well head in
Florida City through final use and disposal.
•	On-site Sewage Disposal System (OSDS) — The County shall establish a remedial plan defining
nutrient limiting standards for OSDSs that will apply to all development in the Florida Keys, including
subdivision lots that were platted before 1971. The County shall require systems that are efficient at
removing phosphate and total nitrogen from effluent. The County will work with the FDHRS to
establish uniform standards for nonconventional septic tanks and treatment systems in the Florida Keys.
Included in the remedial plan will be standards for the type of systems required, allowable density,
minimum elevation the bottom of the septic tank must be above the water table, setbacks, and other
limiting factors to ensure protection of surface and groundwater.
FUNDING: $247,000 was allocated for the comprehensive planning process in Monroe County in 1991. As yet,
no funds have been allocated to Monroe County for 1992.
STAFFING: The Bureau of Local Planning has a t6tal staff of 56 personnel to review comprehensive plans for 459
government entities within the State of Florida. Responsibilities also include technical assistance to the local
governments, review of the amended plans for consistency, and negotiating settlement agreements. Six staff
members in Tallahassee are currently working with comprehensive plans from the Florida Keys area. Field staff
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umbers located in the Key West office are also assigned comprehensive plan review responsibilities. As mandated
by Section 163.3184(4) FS, the FDCA staff must seek comments from other state agencies such as the FDER and
FDNR.
TRACKING: Local governments must prepare periodic progress reports that evaluate the success local governments
are making in achieving their adopted plan objectives. These documents are known as Evaluation Appraisal
Reports. When deficiencies have been noted, local governments must recommend corrective actions. These reports
must be submitted to the FDCA no later than five years from the date of adoption of the local government's
comprehensive plan.
3.2.2.4 COASTAL ZONE MANAGEMENT
PROGRAM RESPONSIBILITIES; The overall responsibilities of the CZMP are as follows:
•	To protect, maintain, and develop the natural, commercial, recreational, ecological, industrial, and
aesthetic resources in the coastal zone through coordinated management;
•	To involve the citizens of the state in addressing issues in the coastal zone; and
•	To amend existing statutes or provide additional regulatory authority to any government body if it
meets the federal consistency provisions of Section 380.23 FS.
AUTHORITY: Legislative authority establishing the CZMP in Florida is set out in Section 380.2 FS.
OBJECTIVE(S): To develop and implement a CZMP for the State of Florida and to achieve coordination among
state, regional, and local officials and agencies.
JURISDICTION: "Section 380.21 requires the State of Florida to prepare and submit to the U.S. Department of
Commerce a coastal zone management plan which includes the boundaries of the coastal zone. This plan defines
the boundary of the coastal zone as the entire state of Florida."
OPERATION: During the 1992 legislative session, the CZMP was transferred from the FDER to the FDCA. In
recent years, the program was primarily a grant program channeling funds to special projects that affect or further
the protection, maintenance, or development of Florida's coastal resources. Besides the grant aspects of the CZMP,
an important feature of the CZMP is the federal consistency provision. The CZMA requires all proposed federally
approved activities (e.g., offshore oil drilling, proposed federally financed wastewater treatment facilities, etc.)
planned within the jurisdictional boundaries of the State of Florida to be consistent with the state's adopted CZMP,
except when the "national interest" is at stake.
Because the program has been transferred from FDER to FDCA, FDCA staff has indicated that program emphasis
will shift from one of a granting program to one that will see staff and coastal management committees more
involved in addressing substantive management issues and problems that ultimately become reflected in state policy.
Staff members will prepare issue position papers, and the Interagency Management Committee will review and make
policy recommendations.
FUNDING: Staff positions are funded out of FDCA's operating budget.
STAFFING: The CZMP is located in the Office of the Secretary, FDCA. There are a total of 15 positions.
TRACKING: In the past, grant program performance was tracked based on staffs evaluation of the work products
and interaction with grant recipients.
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3.2.3 Florida Department of Environmental Regulation
3.2J.1 FLORIDA KEYS NATIONAL MARINE SANCTUARY PROGRAM
PROGRAM RESPONSIBILITIES: The State of Florida and EPA have joint responsibility in developing a WQPP
for the FKNMS. The Governor has assigned primary responsibility for program implementation to the FDER.
Within the FDER there is an individual whose activities include coordinating the WQPP work program with all state
and regional agencies as well as interacting with EPA staff, reviewing and commenting on all work products
produced by consultants, and ensuring effective intergovernmental coordination and public participation.
AUTHORITY: Legislative authority for National Marine Sanctuaries is set out in Title III of the Marine Protection,
Research, and Sanctuaries Act (as amended). More specifically, the Florida Keys National Marine Sanctuary
Program has been authorized by Public Law 101-605, Florida Keys National Marine Sanctuary and Protection Act.
OBJECTIVE(S): Three objectives are set out in the Florida Keys National Marine Sanctuary and Protection Act
as follows:
•	To protect the resources of the Florida Keys;
•	To educate and interpret for the public regarding the Florida Keys marine environment; and
•	To manage human use in the FKNMS consistent with the Act.
Further, Title III of the National Marine Sanctuaries Act (as amended) contains additional objectives that are as
follows:
•	To provide authority for comprehensive and coordinated conservation and management of these marine
areas that will complement the existing regulatory authorities; and
•	To support, promote, and coordinate scientific research of these marine waters.
More specifically, the purposes of the WQPP will be to
1.	recommend priority corrective actions and compliance schedules addressing point and nonpoint sources
of pollution;
2.	assign responsibilities for the implementation of the program;
3.	address legal, institutional, and management issues and recommend changes;
4.	establish a comprehensive water quality program;
5.	provide adequate opportunity for public participation; and
6.	identify funding mechanisms to implement the WQPP.
JURISDICTION: The FKNMS program has jurisdiction seaward of the mean high tide line to the outer limits of
the FKNMS as defined in the Florida Keys National Marine Sanctuary Act; however, Florida's jurisdiction extends
only to the outer boundaries of state waters.
OPERATION: FDER and EPA Region IV staffs are responsible for seeing that the WQPP for the FKNMS is
produced in a timely fashion. The work effort includes administering and monitoring the consulting team contracted
to prepare a draft WQPP. Project management also includes expediting technical information exchange and
coordinating meetings between the consultant and technical staff of FDER and other state agencies. The FDER
Project Manager is involved in scheduling all public and technical work sessions.
FUNDING: In 1991, $100,000 was appropriated for the Florida Keys under the Near Coastal Waters Program.
In addition, $200,000 was provided through EPA headquarters from the CWA, Section 104(b)(3). Funding for 1992
is being provided via Congressional add-on in the amount of $625,000. The FDER Project Managers's staff
position is funded from CZMP monies the state receives from NOAA.
STAFFING: There is one FDER staff member located in the FDER headquarters in Tallahassee who works full
time on Florida Keys issues related to the FKNMS program.
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TRACKING: Tracking of program performance is based on milestones and work products set out in the work
program. Frequent communication between the FDER Florida Keys Coordinator, the EPA Project Manager, and
other involved resource agencies and consultants occurs to ensure that the WQPP now being prepared results in an
acceptable product. The WQPP will identify how compliance will be monitored.
3.2.3.2 DOMESTIC WASTEWATER
PROGRAM RESPONSIBILITIES: The Domestic Wastewater Program at the district level within the FDER is
responsible for the review, approval, and permitting of local domestic wastewater treatment facilities. The
Tallahassee Domestic Wastewater Section provides technical oversight and guidance to the permitting procedure.
The section is also responsible for formulating FDER rules related to wastewater treatment, reuse, and disposal of
wastewater and residuals (sludge). This section also acts as the liaison between the FDER and FDHRS on on-site
sewage disposal issues.
The Ft. Myers District Office, which is responsible for Monroe County, is involved in permitting domestic
wastewater treatment facilities that generate more than 2,000 gallons of flow per day and all on-site wastewater
treatment and disposal in excess of 5,000 gallons per day. Systems falling below these standards are regulated by
the Monroe County Public Health Unit.
AUTHORITY: Legislative authority for the Domestic Wastewater Program is contained in the following statutes:
•	Section 373.016 FS — Declaration of policy of the Florida Water Resources Act of 1972;
•	Section 373.026 FS — General powers and responsibilities of the FDER regarding Florida's water
resources;
•	Section 403.021(2) FS — Legislative policy regarding wastewater;
•	Section 403.061 FS — Powers and responsibilities of the FDER concerning the control of air and
water pollution;
•	Section 403.085 FS — Secondary wastewater treatment; and
•	Section 403.086 FS — Secondary and additional wastewater facilities.
The rules under which the Domestic Wastewater Section operates are as follows:
•	Chapter 17-3 FAC — Water Quality Standards
•	Chapter 17-4 FAC — Requirements for Permits
•	Chapter 17-28 FAC — Underground Injection Control
•	Chapter 17-28.700 FAC — Ground Water Monitoring Requirements
•	Chapter 17-302 FAC — Surface Water Quality Standards
•	Chapter 17-600 FAC — Domestic Wastewater Facilities
•	Chapter 17-601 FAC — Domestic Wastewater Treatment Plant Monitoring
•	Chapter 17-603 FAC — Operator Certification
•	Chapter 17-604 FAC — Collection Systems and Transmission Facilities
•	Chapter 17-610 FAC — Reuse of Reclaimed Water and Land Application
•	Chapter 17-640 FAC — Domestic Wastewater Residuals
•	Chapter 17-650 FAC — Water Quality Based Effluent Limits
Other legislative authority supporting the activities of the domestic wastewater program is the CWA — Public Law
92-500.
OBJECTIVE(S): To ensure that no wastewater is discharged into the environment without the degree of treatment
necessary to meet state water quality standards.
JURISDICTION: This program applies to all upland lands adjacent to the FKNMS.
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OPERATION: This program operates on essential y three levels. Permitting activities are carried out at the district
office level and supplemented at the district branch level. Rule formulation and program oversight are conducted
out of the Tallahassee Office. Coordination is accomplished by the issuance of program guidance memorandums
from the Tallahassee Office to the district offices. These memorandums are designed to ensure uniform and
consistent application of the domestic wastewater rules during the permitting process. Every district and district
branch person receives formal training on any new rules or regulatory procedures. Enforcement and compliance
activities are conducted primarily by the Marathon District Branch Office with support from the Ft. Myers District
Office.
FUNDING: Funding for this particular program comes from General Revenue and from fees charged to permit
holders.
STAFFING: The district has four individuals assigned to processing domestic wastewater permit applications. Each
person spends approximately S to 10 hours per week processing permits in the Florida Keys. There are two
individuals based at the Marathon District Branch Office who are assigned to this program. The Marathon Field
Office of the FDER operates in conjunction with program staff assigned to the Ft. Myers District Office, but the
staff at Marathon is limited and has a variety of other duties.
TRACKING: Tracking permit issuance, enforcement, and compliance actions are handled through the Ft. Myers
District Office. Inspection data are submitted to the Ft. Myers District Office by the Marathon District Branch
Office on a continuous basis. Data are ultimately entered into the FDER Groundwater Monitoring System (GMS)
computerized database; however, in light of available staff, permitting and enforcement activities have higher
priority. Data entry into the GMS is slow. Once programs are established in the form of rules or regulations, there
are no formalized follow-up studies to evaluate their individual effectiveness. All district water facilities
administrators meet in Tallahassee every six weeks.
3.2JJ INDUSTRIAL WASTEWATER
PROGRAM RESPONSIBILITIES: The Industrial Wastewater Program at the district level within the FDER is
responsible for the review, approval, and permitting of local industrial wastewater treatment facilities (primarily
seafood processing plants and laundries in the Florida Keys). The Tallahassee Industrial Wastewater Section
provides technical oversight and guidance to the local FDER district and field staffs concerning permitting
procedures.
AUTHORITY: Legislative authority for the Industrial Wastewater Program is contained in the following statutes:
•	Section 403.021(2) FS — States the policies on control of air and water pollutants; and
•	Section 403.061 FS — States the powers and responsibilities of the FDER concerning control of air
and water pollution.
The rules under which the Industrial Wastewater Program operates are as follows:
•	Chapter 17-4 FAC — Requirements for Permits;
•	Chapter 17-302 FAC — Surface Water Quality Standards; and
•	Chapter 17-660 Series FAC — Rules Pertaining to Industrial Waste Limits in Wastewater Facilities.
Another legislative authority supporting the activities of the industrial wastewater program is the CWA — Public
Law 92-500.
OBJECTIVE(S): To ensure that no wastewaters are discharged into the environment without the degree of treatment
necessary to meet state water quality standards.
JURISDICTION: This program applies to all industries discharging wastewater into the FKNMS.
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OPERATION: This program operates in a tiered fashion. The Marathon District Branch Office is responsible for
compliance and enforcement (i.e., inspections); the Ft. Myers District Office is responsible for permitting; and the
Tallahassee Office is responsible for overall program oversight, policy guidance, and rule development.
All water quality standards are re-evaluated every three years. This process is known as the "Triennial Review"
and is mandated under the CWA design and operation. Standards and criteria for industrial wastewater facilities
may be adopted in statute, administrative rule, or departmental policy form. They are set by the central office in
Tallahassee.
FUNDING: Funding for this program comes from General Revenue. No funds have been specifically designated
for the Florida Keys area.
STAFFING: There are four professional staff members assigned to this program in Tallahassee. These people
provide technical assistance and review functions for the Marathon District Branch Office and Ft. Myers District
Office staffs and interact with EPA on NPDES requirements based on provisions in the CWA.
The district has two individuals assigned to processing industrial wastewater permit applications. Each person
spends, on average, 5 to 10 hours per week processing permits in the Florida Keys. The same two individuals at
the Marathon District Branch Office who are involved in domestic wastewater treatment compliance and enforcement
activities are also responsible for industrial wastewater compliance and enforcement.
TRACKING: Once permits have been approved, tracking is achieved through compliance monitoring and
inspections. District offices are responsible for ensuring that compliance monitoring data are provided by the
permittee. Inspection data are provided from the Marathon FDER staff whenever inspections are made. These data
are centralized at the district office and entered into the state's computerized databases; however, entry of data in
a timely fashion is slowed down due to understaffing.
3.2.3.4 POINT SOURCE EVALUATION
PROGRAM RESPONSIBILITIES: The specific responsibilities of the Point Source Evaluation Program involve
developing water quality based effluent limitations (WQBELs) for point source surface water discharges and
developing total maximum daily loads (TMDLs) for water bodies.
AUTHORITY: Legislative authority for the Point Source Evaluation Program is contained in the following statutes:
•	Section 373.016 FS — Declaration of policy of the Florida Water Resources Act of 1972;
•	Section 373.026 FS — States the general powers and responsibilities of the FDER regarding Florida's
water resources;
•	Section 403.021(2) FS — States the policies on control of air and water pollutants; and
•	Section 403.061 FS — States the powers and responsibilities of the FDER concerning the control of
air and water pollution.
The rules under which the Point Source Evaluation Program operates are as follows:
•	Chapter 17-4 FAC — Requirements for Permits;
•	Chapter 17-302 FAC — Surface Water Quality Standards;
•	Chapter 17-550 FAC — Permitting Public Water Systems;
•	Chapter 17-600 Series FAC — Rules Pertaining to Domestic Wastewater Facilities; and
•	Chapter 17-650 FAC — Water Quality Based Effluent Limitations.
Additional linkages between this program's activities and those of other state and federal agencies are found under
the following:
•	Section 403.60 FS, which establishes the Interstate Environmental Control Compact; and
•	CWA - Public Law 92-500.
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OBJECTTVE(S): To protect the beneficial uses of waters of the state by deviloping effluent limitations for
wastewater facilities.
JURISDICTION: This program applies to all surface water discharges into the FKNMS.
OPERATION: The Point Source Evaluation Section develops WQBELs, supervises the development of WQBELs,
and provides guidance for the development of WQBELs. WQBELs establish effluent limitations for point source
discharges to surface waters that will protect water quality and maintain the designated use of the water body. Level
I WQBELs are intended to be developed in the FDER district offices using existing information. Some additional
data collection by the Department or the applicant maybe required. The level of analysis is relatively simple and
typically does not require computer modeling. Level II WQBELs are directed by the Point Source Evaluation
Section in Tallahassee. These WQBELs are more involved than Level I WQBELs and usually include some level
of computer modeling. For most situations, the permit applicant is responsible, under the direction of the Point
Source Evaluation Section, for the data collection, computer modeling, and impact analysis. The WQBEL is then
developed by the Department based on the information provided by the applicant. However, the Department has
the option of doing this work rather than requiring it of the applicant.
The Point Source Evaluation Section is also responsible for the development of TMDLs for designated water bodies. .
The TMDLs are basinwide assessments that incorporate the development of effluent limitations for point and
nonpoint sources as well as management plans for the basin.
The Outstanding Florida Waters (OFW) designation for most of the waters in the Florida Keys assures even greater
protection than the water quality criteria that apply to designated water classes. Actual permits are issued at the
district level with Tallahassee staff acting in an advisory and oversight capacity. Coordination with other local,
state, and federal regulatory agencies is accomplished through the MOA and MOU processes.
During the past three years, the Point Source Evaluation Section assisted in permitting three wastewater facilities
in the Florida Keys. Two cases involved reverse osmosis plants, and the other included evaluating discharges at
the Key West Power Plant.
FUNDING: Funding for this particular program comes from General Revenue. No funds have been specifically
designated for the Florida Keys area.
STAFFING: There are 12 professional staff members assigned to the Point Source Evaluation Program in
Tallahassee. These people provide technical assistance to FDER staff located throughout the state as well as direct
the development of, and sometimes develop, level II WQBELs.
There are no specific individuals based in the Florida Keys or the Ft. Myers District Office who are assigned to
this program. Interaction between Marathon, Ft. Myers, and Tallahassee is limited. Field staff focus most of their
efforts on compliance and enforcement.
TRACKING: Compliance monitoring occurs once permits have been approved. District offices are responsible
for ensuring that compliance monitoring data are provided by the permittee. These monitoring data are centralized
at the district office and entered into the state's GMS.
3.2.3.5 WASTEWATER FACILITIES REGULATION AND PERMITTING
PROGRAM RESPONSIBILITIES: The Bureau of Water Facilities Planning and Regulation has oversight
responsibility for all district wastewater facility permitting, enforcement, and compliance activities. Their duties
are as follows:
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•	Training of district personnel;
•	Coordination of data needs for individual districts, and technical assistance with data management;
•	Identification of bioassay requirements for tonicity testing;
•	NPDES coordination with EPA;
•	Provide technical assistance to district personnel; and
•	Develop rules and provide interpretations to district personnel.
AUTHORITY: Legislative authority for the Wastewater Facilities Regulation and Permitting Program is contained
in the following statutes:
•	Section 373.016 FS — Declaration of policy of the Florida Water Resources Act of 1972;
•	Section 373.026 FS — States the general powers and responsibilities of the FDER regarding Florida's
water resources;
•	Section 403.021(2) FS — States the policies on control of air and water pollutants;
•	Section 403.061 FS — States the powers and responsibilities of the FDER concerning the control of
air and water pollution; and
" Section 403.0885 FS — Establishes the federally approved state NPDES program.
•	Other sections of Chapter 403 FS
The rules under which the Bureau operates are as follows:
•	Chapter 17-4 FAC — Requirements for Permits;
•	Chapter 17-17 FAC — Electrical Power Plant Siting;
•	Chapter 17-23 FAC — Industrial Siting;
•	Chapter 17-28 FAC — Groundwater Monitoring Requirements;
•	Chapter 17-103 FAC — Rules of Administrative Procedure—Final Agency Action (Non-Rule Making);
•	Chapter 17-301 FAC — State Waters of the State;
•	Chapter 17-302 FAC — Surface Water Quality Standards;
•	Chapter 17-550 FAC — Permitting Public Water Systems; and
•	Chapter 17-600 Series FAC — Rules Pertaining to Domestic and Industrial Wastewater Facilities.
Additional linkages between this program's activities and those of other federal agencies are found in CWA —
Public Law 92-500 (i.e., Sections 401 and 402).
OBJECTIVE(S): To regulate wastewater and stormwater discharges to a level at which there are no adverse water
quality impacts.
JURISDICTION: This program applies to all wastewater facilities in the Flonda Keys.
OPERATION: The Bureau oversees all wastewater treatment permitting and enforcement statewide. Permitting
and enforcement are actually handled at the district and/or district branch levels, with the section in Tallahassee
serving as a technical resource. Data from enforcement/compliance monitoring is initially maintained at district
offices but is eventually passed on to the Tallahassee Office. The Tallahassee Office serves as a technical advisor
to the districts in terms of data management needs.
At the present time, Florida is not a delegated state in terms of NPDES permitting. EPA coordinates with the
Wastewater Facilities Regulation Section when it iff processing NPDES permits. The purpose of coordinating is to
allow the state input regaining NPDES permits being written by EPA, and to ensure that the permit is consistent
with all state water quality standards. The FDER has 60 days in which to comment. Because Florida is not a
delegated state, surface water dischargers are required to have an FDER permit as well. However, Flonda is in
the process of becoming a delegated state; if this occurs, needless duplication in the permitting process will be
removed.
All actual state permitting or review of NPDES proposed permits is done at the distnct office level. All follow-up
inspection and compliance monitoring is done at the district and branch levels.
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FUNDING: Funding for the program comes from General Revenue, fees charged to dischargers, and federal grants.
No funds have been specifically designated for the Florida Keys area.
Currently 106 Grant funds from the CWA are being utilized for the following purposes:
•	To fund the state's existing ambient water quality monitoring program (only two routine sampling
stations for this program are located in the Florida Keys);
•	To defer cost of compliance inspections; and
•	To help fund the state's data retrieval network.
STAFFING: There are nine professional staff members in the Wastewater Facilities Regulation Section located in
Tallahassee. They have statewide responsibility. These people provide technical assistance and serve in an
overview capacity for all district and district branch offices in Florida. The staff also coordinates the EPA NPDES
permit commenting process.
TRACKING: Compliance inspection, enforcement records, and monitoring data are centralized at the district office
and entered into the state's computerized GMS. From time to time, section staff members make field visits.
3.2J.6 UNDERGROUND INJECTION CONTROL
PROGRAM RESPONSIBILITIES: Within FDER, the UIC Section regulates injection wells to ensure that current
and potential future drinking water sources are not contaminated by underground injection of waste.
AUTHORITY: Legislative authority mandating this program is contained in the following statutes:
•	Chapter 37 Part III — Regulation of Wells; and
•	Chapter 403 FS — Environmental Control.
The UIC Program operates according to the provisions described in Chapter 17-28 FAC — UIC, Criteria and
Standards.
Florida is designated as a "Primacy State" under the EPA's rules for enforcing the Safe Drinking Water Act —
Public Law 93-523. This means that Florida has the primary responsibility for issuing all underground injection
well permits. The EPA oversees this process and reviews issued permits.
OBJECTIVE(S): To ensure that no current or potential future source of drinking water is contaminated by
underground injection of waste.
JURISDICTION: The UIC Program has jurisdiction throughout the Florida Keys.
OPERATION: At the present time, all injection wells in the Florida Keys are Class V shallow injection wells for
domestic sewage or stonnwater runoff. Permitting is done through the Ft. Myers District Office, with the
Tallahassee Office serving as an oversight body and providing technical support and policy evaluation when
necessary.
Class V injection well permits for wastewater facilities require monthly operating reports and follow-up inspections.
Stonnwater wells are exempt from monitoring requirements. There is an ongoing monitoring study being conducted
on Class V injection wells on Saddlebunch Key.
FUNDING: The Florida UIC Program has received approximately $200,000 annually from EPA to supplement the
funds the state appropriates for operating the state program. This constitutes approximately 10% of the total Florida
budget The major source of funding comes from state General Revenue.
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STAFFING: There are five full-time professional staff members assigned to this program at the Tallahassee Office.
Permitting and enforcement are handled at the district office level. Follow-up inspections, if required, are handled
from the Marathon District Branch Office.
TRACKING: Injection wells are tracked by permit application and by entry into the state's GMS database at the
Ft. Myers District Office. If monitoring is required for the permit, the permittee is required to submit reports to
both the Tallahassee Office and the Ft. Myers District Office simultaneously.
3.2.3.7 WATER QUALITY STANDARDS
PROGRAM RESPONSIBILITIES: The Water Quality Standards Section is responsible for updating state water
quality standards for surface waters. Changes in these standards include classifications of surface waters, periodic
review and update of water quality standards, and designations of use in OFW.
AUTHORITY: Legislative authority mandating this program is contained in the following statutes:
•	Chapter 403 FS — General regulations to prevent, control, and prohibit the pollution of air and water;
and
•	Section 403.061 FS — Grants the FDER the power to establish rules that provide for a special
category of waterbodies called OFW, worthy of special protection because of their natural attributes.
The regulation under which the program primarily operates is Chapter 17-302 FAC — Surface Water Quality
Standards. This rule contains surface water use classifications, associated beneficial uses, standards applied to
surface waters, state antidegradation policy, and OFW.
OBJECTTVE(S):
•	To adopt, modify, and repeal rules and regulations to carry out the intent and purposes of Section
403.061 FS;
•	To adopt a comprehensive program for the prevention, control, and abatement of pollution of waters
of the state;
•	To establish classes in accordance with the present and future most beneficial uses, and allow their
modification with public input;
•	To establish ambient water quality standards for the state as a whole or for any part thereof, and allow
mixing zones;
•	To allow for field studies and periodic sampling in a logical geographic manner to determine levels
of water quality and source(s) of pollution;
•	To encourage and conduct studies, investigations, and research relating to pollution and its causes,
effects, prevention, abatement, and control; and
•	To collect and disseminate information and conduct educational and training programs relating to
pollution.
JURISDICTION: This program applies throughout the state waters within the FKNMS.
OPERATION: Most coastal waters in the Keys have a Class III designation. Waters within the Everglades
National Park are designated as Class II. In addition, the Florida Keys were designated as OFW in 198S. The
OFW program is implemented through the FDER's permitting system. Only those activities that require a FDER
permit are affected. The Key West sewage outfall, Stock Island power plant mixing zone, and various artificial
water bodies are exempt from the OFW designation under Chapter l7-302.700(9)(i) FAC.
All pollution sources in existence prior to implementation of OFW in 198S are "grandfathered in", and do not have
to meet the OFW water quality standards for the Florida Keys. The vast majority of Keys development occurred
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prior to the 198S OFW designation. Presently, the FDER is in the midst of conducting a triennial review of its
water quality standards as required by the CWA. One of the issues that is being studied is "grandfathering" of
water quality standards.
FUNDING: This program is funded entirely from General Revenue. No additional funds have been allocated for
the FKNMS.
STAFFING: There are five staff positions in this Section, one of the smallest in the Department. These include
one secretary, three Environmental Specialist Ills, and an Environmental Administrator. Staff responsibilities
include classification, reclassification, OFW designations, proposed standards changes, triennial review of surface
water standards, and related issues as they arise.
TRACKING: Classifications, standards review and changes, and OFWs are handled and tracked within the FDER
Headquarters, with some support from other sections and districts for specific projects.
3.2 J.8 AMBIENT MONITORING
PROGRAM RESPONSIBILITIES: The Ambient Monitoring Subsection is responsible for administration of the
Department's surface water ambient monitoring program and for coordination with other surface water monitoring
programs at the federal, state, regional, local government, and citizen group levels. Specific responsibilities include
preparation of the biennial Water Quality Assessment 305(b) Report, management of the state's STORET databases
and associated training program, management of the state's mercury databases, oversight and contract management
for a wide variety of ambient monitoring programs statewide (water management districts, other state agencies,
universities, and other entities), extensive Geographic Information System (GIS) support services, technical
assistance in the planning, design implementation and data analysis for surface water monitoring programs, and
scheduling district sample collection for analysis at the Department's Central Lab facility.
AUTHORITY: Legislative authority mandating this program is contained in the following statutes:
•	Chapter 373.026 FS - General Powers and Duties of the FDER; and
•	Section 403.061 FS - Powers of FDER to Control and Prohibit Pollution of air and water.
OBJECTIVE(S):
•	To provide for maximum coordination and compatibility among all entities in Florida conducting
surface water ambient monitoring programs;
•	To monitor the quality of Florida's water resources in order to characterize baseline conditions and
assess impacts;
•	To produce assessments of the conditions of Florida's water resources;
•	To provide for centralized surface water resource data management and associated training; and
•	To provide for the development and implementation of new surface water resources monitoring
techniques.
JURISDICTION: This program applies throughout the state waters within the FKNMS.
OPERATION: At present, monitoring efforts in the Florida Keys are associated with compliance monitoring and
enforcement conducted through the Marathon District Branch Office. Long-range planning, however, includes
investigating new methods to assess the quality of water resources in estuarine and marine environments and
providing for a monitoring network that will extend into waters of the FKNMS.
FUNDING: This program is funded entirely from General Revenue. No additional funds have been allocated for
the FKNMS.
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STAFFING: There are six administrative staff in the ambient monitoring program (five staff members in
Tallahassee and one in Orlando) and approximately 20 field staff in the district offices. Hie field personnel are
active participants in the planning and policy-making process of the overall program.
TRACKING: Monitoring is extremely limited in the FKNMS area and is almost uniformly associated with specific
permit requests. This type of monitoring is handled primarily by the Marathon District Branch Office and the Ft.
Myers District Office. Monitoring data flow back to Tallahassee slowly through the CMS, and occasionally by
special request.
3.2.3.9 STORMWATER MANAGEMENT
PROGRAM RESPONSIBILITIES: The Stormwater/Nonpoint Source Management Section is responsible for
administering the state's stormwater and nonpoint source management programs. * They help develop program
policy, which is implemented through State Water Policy, and work with the water management districts to develop
stormwater system design criteria that achieve the desired treatment level. They also are responsible for providing
technical assistance, coordinating with EPA on NPDES stormwater permitting, and for coordinating and overseeing
implementation of the stormwater program by the Water Management Districts and local governments.
AUTHORITY: Legislative authority for the Stormwater Management Program is contained in the following statutes:
•	Chapter 163 FS — Intergovernmental Programs;
•	Chapter 187 FS — State Comprehensive Plan;
•	Section 373.026 FS — General Powers and Responsibilities of the FDER Regarding Florida's Water
Resources;
•	Section 373.026 FS — Legislative Intent Regarding Pollution of Surface and Groundwaters;
•	Chapter 373 Part IV FS — Management and Storage of Surface Waters;
•	Section 403.021(2) FS — Policies on Control of Air and Water Pollutants;
•	Section 403.061 FS — Powers and Responsibilities of the FDER Concerning the Control of Air and
Water Pollution; and
•	Section 403.0891 FS — State, Regional, and Local Stormwater Management Plans and Programs.
The rules under which the Stormwater Management Program operates are as follows:
•	Chapter 17-4 FAC — Requirements for Permits;
•	Chapter 17-25 FAC — Regulation of Stormwater Discharge;
•	Chapter 17-40 FAC — Water Policy; and
•	Chapter 17-302 FAC — Surface Water Quality Standards.
Other legislative authority supporting the activities of the stormwater management program is found in the CWA —
Public Law 92-500.
The permitting of stormwater discharges was delegated to the South Florida Water Management District (SFWMD)
in 1982. This was done to streamline regulatory procedures. The SFWMD rules pertaining to stormwater discharge
are found in Chapter 40E-4 and Chapter 40E-40 of the FAC.
OBJECTIVE(S): To control stormwater discharges to a level at which there are no adverse impacts is the bodies
of water receiving them. The stated goal of this program is to reduce pollutant loads carried into Florida surface
waters by 80% in Class I, II, or III state waters or by 95% in OFW. Additional responsibilities include flood
protection and maintenance of water reserve levels in surface water retention areas.
JURISDICTION: The FDER has jurisdiction over all stormwater management activities in -the Florida Keys;
however, the FDER has delegated stormwater regulatory and permitting responsibilities to the SFWMD. While all
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individuals must comply with all stonnwater regulations, the SFWMD administrative rule Chapter 40E-4 FAC
exempts developments under 10 acres in size or projects with less than 2 acres of impervious surface from having
to submit stormwater management applications.
OPERATION: At the present time, the FDER Stonnwater Management Program provides technical assistance and
advice to the various water management districts upon request, reviews comprehensive plans, monitors technical
advancements in stonnwater management and control, investigates new technologies for stormwater control, and
reviews water quality research relative to stormwater. Recommendations are made to the Standards and Monitoring
Program, and other agency programs, as necessary. Staff of the Stonnwater Management Section provides technical
assistance to district and district branch personnel. They do aot play any present role in stormwater discharge
permitting in the FKNMS because of the 10-acre exemption provision now in force at the district.
FUNDING: Funding for this particular program comes from General Revenue with limited additions from EPA
through the 319 Grant Program. These funds are used to implement the state's EPA-approved Nonpoint Source
Management Program. No funds are specifically designated for the FKNMS.
STAFFING: There are six professional staff members assigned to the Stonnwater Management Program in
Tallahassee. One part-time person is assigned specifically to this program at the Ft. Myers District Office or
Marathon District Branch Office.
TRACKING: As far as the stated goals of this program are concerned, there is no tracking. Permit approvals and
permitting policies are decided upon at the distnct level. Any monitoring, if required, is handled at the distnct
branch. There is relatively little flow of data to the Tallahassee Office. Even if there were more and faster
exchange of existing data, evaluation of stonnwater management policies and procedures would require considerably
more in-depth monitoring than is currently possible.
3.2J. 10 WETLAND RESOURCE UTILIZATION PERMITTING (DREDGE AND FILL)
PROGRAM RESPONSIBILITIES: Staff of the Bureau of Wetlands Resource Management is responsible for
administering Florida's dredge and fill program. This includes making jurisdictional declaratory statements,
evaluating and approving wetland mitigation proposals, and reviewing and processing dredge and fill permit
applications.
AUTHORITY: Legislative authority for this program is contained in the following statutes:
a Chapter 403 Pan VIII FS — Permitting of Activities in Wetlands; and
•	Chapter 253 FS — General Authority for the FDER to Accomplish its Mission.
The rules under which the program operates are as follows:
•	Chapter 17-4 FAC — Requirements for Permits
•	Chapter 17-25 FAC — Regulation of Stonnwater Discharge;
•	Chapter 17-301 FAC — Extent and Boundaries of the Surface Waters of the State;
•	Chapter 17-302 FAC — Surface Water Quality Standards;
•	Chapter 17-312 FAC — Dredge and Fill Activities; and
•	Chapter 17-321 FAC — Mangrove Protection.
OBJECT IVE(S):
•	To conserve the waters of the state;, and
•	To protect, maintain, and improve the quality of the state waters for public water supplies; for the
propagation of wildlife, fish, and other aquatic life; and for domestic, agricultural, industrial,
recreational, and other beneficial uses.
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JURISDICTION: 'liis program has jurisdiction that extends from the mean high tide line offshore to the limits of
state waters.
OPERATION: Applications for wetlands resource permits (dredge and fill permits) that involve more than 10 acres
are processed in the Tallahassee Office. Applications for smaller projects are processed by the Ft. Myers District
Office and the Marathon District Branch Office. Permit processing is governed by Sections 403.91-403.929 FS —
Permitting of Activities in Wetlands. In determining whether or not a permit should be issued or denied, the
applicant must provide reasonable assurances that the project will not violate water quality standards or be contrary
to the public interest. Projects within OFW such as the Florida Keys must meet more stringent requirements
including not lowering ambient water quality in any way and proving the project is clearly in the public interest.
Part IV of Chapter 17-312 FAC is titled "Additional Criteria for Dredging and Filling Within Outstanding Florida
Waters in Monroe County." This part provides specific regulations concerning protection for algae, coral, sponge,
and seagrass communities: siting and design criteria for piers and boat moorings: and permitting requirements for
marinas and shoreline stabilization.
FUNDING: Funding for this program comes from General Revenue, supplemented occasionally by grants from the
Pollution Recovery Fund (Permit Fee Trust Fund).
STAFFING: The Tallahassee Office has one full-time staff person assigned to this program for Monroe County.
There are two professional-level positions assigned for Monroe County in the Ft. Myers District Office, and one
position in the Marathon District Branch Office.
TRACKING: The program is tracked through permit applications, inspection reports, and issued decisions.
Tallahassee maintains files on the cases it handles, and the Ft. Myers District Office maintains files on those permits
it issues.
3JJ.11 SOLID WASTE MANAGEMENT
PROGRAM RESPONSIBILITIES: Permitting and monitoring of landfills and solid waste disposal sites.
AUTHORITY: Legislative authority for this program is contained in Chapter 403 FS — Florida Air and Water
Pollution Control Act, which is the primary statute upon which most FDER rules have been developed.
Rules specific to the function of solid waste management are as follows:
•	Chapter 17-4 FAC — Requirements for Permits; and
•	Chapters 17-701 through 17-729 FAC — Rules Governing the Solid Waste Program.
OBJECTIVE(S): To ensure that solid waste disposal be conducted in a manner and under conditions that reduce
the waste of recoverable resources and eliminate the dangerous and deleterious effects of improper disposal upon
air quality, water quality, and human health, safety, and welfare.
JURISDICTION: The program is applicable throughout the Florida Keys.
OPERATION: At present, there are four major (Class 1) landfills in the Florida Keys. All are in the process of
being closed. All landfill permitting is handled through the Ft. Myers District Office, which also has oversight of
district branch solid waste activities. Monitoring and enforcement are handled through the Marathon District Branch
Office.
FUNDING: Funding for this program comes from General Revenue. ' No funds have been specifically allocated
to the Florida Keys area.
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STAFFING: There is > me FDER staff person is the Marathon District Branch Office whose responsibilities involve
solid waste, primarily in the areas of compliance and enforcement. Aside from landfill monitoring, she also is
responsible for ail activities dealing with hazardous materials/wastes and USTs.
TRACKING: Landfills are monitored by sampling water from shallow wells drilled near the landfill and analyses
of this water for leachates. Data from the sampling program are compiled in the Ft. Myers District Office and
entered into the GMS database system.
3.2.3.12 STORAGE TANK REGULATION
PROGRAM RESPONSIBILITIES: FDER and FDHRS staffs work cooperatively in administering storage tanir
regulation. Activities include cleanup of sites contaminated by aboveground and underground storage tank system
discharge, enforcement of new standards for storage tank installation and removal to prevent discharge from
contaminating groundwater.
AUTHORITY: Legislative authority is contained in Chapter 376 FS — Pollutant Discharge, Prevention, and
Removal.
Florida is a delegated state in terms of EPA's storage tank regulatory procedures authorized under RCRA, Subtitle I.
Responsibility is delegated to the state program through an MOU between EPA and the FDER. In addition, FDER
has contracted with the Monroe County Public Health Unit to conduct storage tank inspections.
Applicable rules under which this program functions are as follows:
•	Chapter 17-761 FAC — Underground Storage Tank Systems;
•	Chapter 17-762 FAC — Aboveground Storage Tank Systems;
•	Chapter 17-769 FAC — The Florida Petroleum Liability Insurance and Restoration Program;
•	Chapter 17-770 FAC — Clean-Up Criteria; and
•	Chapter 17-773 FAC — Reimbursement for Petroleum Contamination Site Cleanup.
OBJECTIVE(S):
•	To clean up previously contaminated sites;
•	To ensure proper precautions, in the form of new tanks with secondary containment and proper
installation; and
•	To prevent contamination in the future.
JURISDICTION: This program covers the Florida Keys.
OPERATION: This program regulates all USTs larger than 110 gallons and all aboveground storage tanks larger
than SSO gallons. Storage tank content can include ammonia, chlorine, pesticides and derivatives, and petroleum
or petroleum products. Under the 1976 RCRA legislation, the FDER is directed, to the greatest extent possible,
to contract with local governments to perform the compliance and enforcement activities associated with the state
tank rules. The tank program staff in Tallahassee has contracted with Monroe County FDHRS to perform annual
compliance inspections, installation inspections, and enforcement activities for storage tank facilities in the county.
Ultimately, the Ft. Myers District Office is responsible for enforcement actions. The Monroe County FDHRS is
responsible for all preliminary compliance and enforcement activities and for public assistance and complaint
response.
FUNDING: Funding for contracted services and Tallahassee staff positions is provided through the Inland Protection
Trust Fund (Section 376.3071 FS).
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STAFFING: Two FDER staff members are assigned to this program. One Program Supervisor is in the Ft. Myers
District Office. One Environmental Specialist II works part-time in the " larathon District Branch Offre. Three
Monroe County FDHRS personnel in the Public Health Unit are assigneu to this program in the Florida Keys.
TRACKING: FDER maintains computerized lists available of registered facilities, facilities inspected to date, and
clean-up actions in progress, pending, or under enforcement action.
3.2.3.13 EMERGENCY RESPONSE PROGRAM
PROGRAM RESPONSIBILITIES: The FDER Bureau of Waste Cleanup has primary responsibility for
interdepartmental coordination for emergency response. This program involves the abatement and proper
management of environmental emergencies caused by oil and hazardous materials spills. FDER-man dated functions
include administration of Emergency Services Contracts, Disposal Services Contracts, and Emergency Drinking
Water Funds. The section also has a variety of specific responsibilities acquired through interagency agreements
and MOUs.
AUTHORITY: Legislative authority for this program is contained in the following statutes:
•	Section 376.30 through 376.319 FS — Legislative Intent Regarding Pollution of Surface and
Groundwater;
•	Section 403.061 FS — Powers and Responsibilities of the FDER in Regard to Air and Water Pollution;
•	Section 403.161 FS — Prohibitions, Violations, and Penalties; and
•	Section 403.16SS FS — Environmental Short-Term Emergency Response Program.
There are also a number of critical MOUs, with the FDNR,, Florida Game and Fresh Water Fish Commission, and
USCG, on the use of dispersants and other chemicals to treat oil spills, enabling the Emergency Response Section
to perform its function. Additional authorization is specified in the Hazardous Materials Annex XXV, State of
Florida Peace Time Emergency Plan.
OBJECTIVE(S):
•	To provide a mechanism for the state to respond to short-term emergencies;
•	To have available financial resources to respond to emergencies that pose an immediate environmental
or public health threat; and
•	To coordinate the FDER response with other federal, state, and local entities.
JURISDICTION: The Emergency Response Program has a jurisdictional responsibility throughout the Florida Keys
and FKNMS.
OPERATION: Within the State of Florida, there is a multi-agency Hazardous Materials Task Force specified under
the Hazardous Materials Annex XXV, State of Florida Peace Time Emergency Plan. Within this structure, the
responsibilities of all state agencies are outlined. The FDNR normally has responsibility for spills that occur in
coastal waters, and the FDER for spills that occur on land. The FDCA maintains communication links between
agencies and can serve as backup for the responsible agency handling a spill. In the event of an oil or hazardous
material spill, that threatens the coastal zone or occurs far offshore, the USCG would be the responsible agency.
Both the FDNR and FDER have representatives on the Regional Response Team. There is an interagency
agreement, between the FDNR and FDER, that gives the Emergency Response Section of the FDER responsibility
for deciding when and if dispersants may be used.
FUNDING: Administrative staff positions are funded from the FDER operating budget. Based on the nature of
the incident, spill clean-up activities are funded by either the Water Quality Assurance Trust Fund or the Inland
Protection Trust Fund.
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STAFFING: One full-time professional staff person .s in Tallahassee. There are no full- or part-time FDER
professionals specifically assigned to emergency response in the FKNMS. Should a spill occur within the manne
environment, the Florida Marine Patrol (FMP) would assign staff members as needed.
TRACKING: This program is tracked based on emergency responses to given situations involving spills of oil or
hazardous materials. Such spills occur frequently on a statewide basis. A computerized database of response
activities is available.
3.2.3.14 LOCAL GOVERNMENT COMPREHENSIVE PLAN REVIEW
PROGRAM RESPONSIBILITIES: The FDER Office of Intergovernmental Programs is responsible for general
environmental management issue review of all local government comprehensive plans submitted to the FDCA.
AUTHORITY: Legislative authority for the tasks performed by the FDER Office of Intergovernmental Programs
is provided under the following statutes:
•	Section 163.3177 FS — Elements of Comprehensive Plan — Required and optional elements to include
in the prescription of principles, guidelines, and standards for the orderly and balanced future
development of an area;
•	Section 163.3178 FS — Coastal Management — Protection of human life and limitations of public
expenditures in areas subject to destruction by natural disasters. Restrictions to development activities
may be imposed where such activities would damage or destroy coastal, resources;
•	Section 163.3184(4) FS — Intergovernmental Programs - Identification of the FDER as a review
agency for local comprehensive plans and plan amendments;
•	Chapter 186 FS — State and Regional Planning — Integr fid planning system to ensure coordinated
administration of government policy;
•	Section 187.201 FS — State Comprehensive Plan — Policy ;uidance for the orderly growth of Florida;
•	Chapter 373 FS — State Water Resources Plan — Respc sibilities of the FDER for water resource
protection;
•	Chapter 380 FS — Land and Water Management — Protection of the natural resources and
environment of the state; and
•	Chapter 403 FS — Environmental Control — Regulation o control and prohibit the pollution of air
and water.
The rules under which the Office of Intergovernmental Programs fun (ions are promulgated under the following
elements of the FAC:
•	Chapter 9J-S FAC — Minimum criteria for the review r .ocal government comprehensive plans; and
•	Department 17 Series — Regulations to conserve, protec:. and restore air, water, and natural resources
in the State of Florida.
OBJECTIVE(S): To ensure that local government plans conform to and are consistent with the FDER's legislatively
mandated responsibilities to protect the natural resources and environment of the State of Florida.
JURISDICTION: The FDER Office of Intergovernmental Programs reviews all local government comprehensive
plans statewide. Within the area adjacent to the FKNMS, this has meant review of the local government
comprehensive plans of Monroe County, City of Key West, City of Layton, and City of Key Colony Beach.
OPERATION: The FDCA provides the FDER'Office of Intergovernmental Programs with copies of the
comprehensive growth management plan proposed by a local government entity. The Office of Intergovernmental
Programs is responsible for coordinating the FDER's review and draws upon the technical expertise of agency
personnel in various divisions within the FDER. Copies of appropriate sections of the proposed comprehensive
growth management plan are circulated to the appropriate group and its comments requested. In addition to review
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by frtiwinal staff in Tallahassee, the district that contains the local government ectity submitting the plan under
review is also requested to submit review comments. The Office of Intergovernmental Programs has 45 days from
the date of receipt to return comments to the FDCA.
The FDER staff, through the local government comprehensive plan review process, is able to affect water quality
issues in the following ways:
•	Influencing conservation/preservation of natural resources;
•	Influencing upland development and growth;
•	Ensuring that the FDER requirements for sanitary waste, drinking water, and waste management
planning are addressed; and
•	Ensuring that the FDER stonnwater standards are included in the local plans.
FUNDING: The positions of the FDER staff conducting the local government comprehensive reviews are funded
through state General Revenue.
STAFFING: There are four professional staff members assigned to this program for the entire state.
TRACKING: The local government comprehensive plan review process within the Office of Intergovernmental
Programs has a specific task to perform within a specific time frame. Copies of comments from the various FDER
bureaus and sections are synthesized into an FDER response. This response is forwarded to the FDCA. The Office
of Intergovernmental Programs maintains the responses and supporting documentation; therefore, it is possible to
track whether FDER comments have been incorporated into approved comprehensive growth management plans.
To date, the Office of Intergovernmental Programs has completed initial review and submitted comments on
proposed local government comprehensive plans from all local government entities in the Florida Keys. The Office
of Intergovernmental Programs has b.ซn involved in negotiations between the FDCA and county/municipalities
regarding compliance or approval of nay of the submitted plans. This remains an ongoing process.
3.2.4 Florida Department of Health and Rehabilitative Services
3.2.4.1 ON-SITE SEWAGE DISPOSAL
PROGRAM RESPONSIBILITIES: County public health units are charged with the responsibility of ensuring
proper construction, installation, and operation of individual OSDSs.
AUTHORITY: Legislative authority for this program is contained in the following statutes and rule:
•	Section 381.0064 FS — Requires the FDHRS to provide continuing education courses for septic tank
contractors, pumpout operators, environmental health specialists, and master plumbers who install
septic tanks or service septic tanks;
•	Section 381.0065 FS — Provides the installation conditions for OSDSs;
•	Section 381.0066 FS — Provides the authority to implement a fee schedule designed to recapture the
cost of carrying out the on-site disposal program; and
•	Chapter 10D-6 FAC — Contains the regulations promulgated by the FDHRS to oversee the installation
and operation of individual on-site disposal systems.
OBJECTIVE(S): To ensure that OSDSs are designed, installed, and maintained in such a way as to prevent ground-
and surface-water contamination and to prevent human health problems.
JURISDICTION: The OSDS permitting program has jurisdiction throughout Monroe County.
OPERATION: The OSDS program is administered at the state level and at the local level. The Tallahassee Office
is primarily responsible for policy, research, evaluation, and technical support services. It advises the district level
staff members and coordinates with them directly on most issues.
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Permitting and enforcement are done by the Monroe County Public Health Unit. In Moiaoe County, theie are three
offices for environmental health services, including the Stock Island Office (main office), Marathon Office, and
Tavernier Office.
Individual OSDSs regulated by the FDHRS/Monroe County Public Health Unit fall into the following categories:
•	Domestic sewage less than or equal to 5,000 gallons per day;
•	Food service establishments with total wastewater flows that are less than or equal to 3,000 gallons
per day; and
•	OSDS in areas zoned for industry or manufacturing, or an equivalent use, for which the system can
be demonstrated to be exclusively for domestic waste.
OSDSs with design flows in excess of the ones stated above may also be permitted through an appeal process
involving a hearing before the OSDS State Variance Review Group, provided the FDER has determined it to be
impractical to consolidate flow through sewering in low-density areas.
Individuals may also apply to the OSDS State Variance Review Group for special permits for innovative or
nonstandard OSDSs, or for special exemptions from given OSDS requirements. Usually, these .types of applications
are from individual home owners who need an OSDS to build on their property. In the past, the OSDS State
Variance Review Group has approved approximately 1/3 of the applications as requested, another 1/3 have received
a favorable decision but approval is subject to stipulated conditions, and finally, 1/3 are denied approval. Over the
past three years, roughly 3,500 OSDS permits were processed in the Florida Keys.
FUNDING: Funding for this program comes from General Revenue and from fees charged for permits. Funding
for this program was $220,422 in fiscal year 1991-1992.
STAFFING: There are six full-time professionals in the Tallahassee Office nd eight professional staff members
in the Florida Keys. Staffing in the Florida Keys has shown a downward tree- over the last three years. There were
12 professional level staff people assigned to this program in 1990, and 10 i 1991.
TRACKING: At the local level, this program is tracked by permit applies ins, inspection reports, and eventual
permit actions (issuance of denial). There is a county ordinance that requ a OSDS facilities to be inspected at
three-year intervals to determine if they are functioning properly. However, a ordinance never defined who would
be responsible for implementing the ordinance. Further, as of February s 23, the County has not provided any
funding to initiate the inspection program.
3.2.5 Department of Natural Reso: .as
3.2.5.1 ADMINISTRATION OF NATIONAL MARINE SANCTUARIES
PROGRAM RESPONSIBILITIES: The Bureau of Sanctuaries and Research Reserves is responsible for
administration and management of National Marine Sanctuaries and National Estuarine Research Reserves. There
are two National Marine Sanctuaries in Florida. They are both located in the Florida Keys at Looe Key and Key
Largo.
AUTHORITY: Legislative authority for this program is contained in Section 370.021(5)(a) and (b) FS, which
provides state authority to Sanctuary Officers for enforcement positions under the FDNR enforcement authorization.
Chapter 253 FS.
Federal statutes enforced under this authority are as follows:
•	MPRSA (as amended);
•	Magnuson Fisheries Conservation and Management Act;
•	Endangered Species Act;
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•	Marine Mammal Protection Act;
•	Fish and Wildlife Improvement Act; and
•	Lacy Act Amendments; and
•	Atlantic Tunas Convention Act.
OBJECTIVE(S):
•	To enhance resource protection through th.t implementation of comprehensive, long-term management
tailored to the resources;
•	To promote and coordinate research to expand scientific knowledge on significant marine resources
and improve management decision making;
•	To enhance public awareness, understanding, and wise use of the marine environment through public
education, interpretive, and recreational programs; and
•	To provide for the maximum compatible public and private use of special marine areas.
JURISDICTION: The legislative authority of this program is limited to the Looe Key National Marine Sanctuary
and Key Largo National Marine Sanctuary.
OPERATION: The National Marine Sanctuary Program is administered at the federal level by NOAA of the U.S.
Department of Commerce.
FUNDING: The 1991-1992 funding for the both Looe Key and Key Largo National Marine Sanctuaries consists
of a direct federal budget appropriation of $220,000 and a federal appropriation through the FDNR in the form of
an Operations Grant of $765,000.
STAFFING: Bureau of Sanctisaries and Research Reserves staffing consists of the following:
•	Looe Key NatiociU Marine Sanctuary
—	1 Administrator
—	2 Environmental Specialists
—	3 Law Enfonxcnent Officers
—	1 Secretary
—	2 Maintenance Mechanics
—	1 Administrative Assistant
•	Key Largo National Marine Sanctuary
—	3 Environmental Specialists
—	4 Law Enforcement Officers
—	1 Maintenance Mechanic
TRACKING: This is an administrative program tracked through standard state administrative procedures. Records
documenting violations and fines are maintained by each sanctuary office. Because it receives federal funding, the
program is also tracked by NOAA.
3.2.5.2 ENVIRONMENTAL CRIMES PROGRAM
PROGRAM RESPONSIBILITIES: The Environmental Crimes Program is essentially an effort by the Marathon
District Office of the FMP to centralize environmental crime detection and enforcement within a specialized unit.
This centralization of authority is an outgrowth of an interagency Environmental Crimes Task Force established by
the Monroe County Sheriffs Department. The creation of this specialized unit increases the efficiency of all the
district's officers. Patrol officers now have a fellow officer whose primary responsibility is enforcing environmental
crimes (e.g., illegal dredge and fill activities, mangrove destruction) that they can report suspicious situations to for
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followup, without sacrificing their patrol time and other law enforcement duties. The concept of a designated officer
or officers for environmental crimes is spreading with the various districts of the FMP. Specific courses in
environmental crime are now being offered at the FMP.
AUTHORITY: Legislative authority i> r the FMP to investigate environmental crime is contained in the following
statutes:
•	Chapter 161 FS — Authorizes the FMP to monitor all dredge and fill activities and associated coastal
construction;
•	Chapter 370 FS — Empowers the FMP to enforce all Florida fish and game regulations concerning
seasons, quotas, and gear types;
•	Section 372.072(4) FS — Authorizes the FMP to enforce the Threatened and Endangered Species Act;
and
•	Chapter 376 FS — Authorizes the FMP to deal with spills and pollutant sources.
OBJECTIVE(S):
•	To discourage environmental degradation by enforcing civil and criminal penalties; and
•	To educate the general populace about the importance of protecting and maintaining the natural marine
resources in the Florida Keys.
JURISDICTION: FMP Officers enforce the laws of the State of Florida throughout state waters.
OPERATION: The Environmental Crimes Program operates within the regular administrative framework of the
Marathon District Office of the FMP. Due to the nature of the work, close coordination and cooperation are
required between the FMP, the local office of the FDER, other FDNR divisions, and on occasion the Monroe
County Public Health Unit.
During regular FMP operations, an officer who is either informed of or encounters a potential en ironmental crime
makes a preliminary assessment, then turns the case over to the officer responsible for environnr. atal crimes. The
patrolling officer is then able to continue his regular duties while a specialist follows up on what r. ly be an involved
and time-consuming case.
There has been discussion among various law enforcement organizations in the Florida Keys > adopt a concept
known as "cross deputization." If this concept is implemented, FMP officers would have the a chority to enforce
all applicable federal environmental laws (see Section 3.2.5.1), in addition, to the state envirc mental statutes as
described above. Similarly, the federal National Marine Sanctuary officers at Looe Key and Ke;- Largo would have
the authority to enforce state environmental laws.
FUNDING: There is no special funding earmarked for the Environmental Crimes Program. F gram expenses are
paid out of the regular operating budget of the FMP Marathon District Office.
STAFFING: One officer is currently assigned full time to this program.
TRACKING: Tracking environmental crimes consist of reports, investigations, and in some cases charges and
eventual court decisions. All data concerning environmental crimes, other than court records and oil spill reports,
remain in the FMP Marathon District Office.
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3.2.5.3 SUBMERGED LANDS AND PRESERVES
PROGRAM RESPONSIBILITIES: The Bureau of Submerged Lands and Preserves has responsibility for
permitting any activity that occurs on state submerged lands. Examples of activities requiring permits are as
follows:
•	Dredge and fill (the majority of permits requested);
•	Live rock collection; and
•	Live-aboard mooring fields.
AUTHORITY: Legislative authority for this program is contained in the following statute and rules:
•	Chapter 18-14 FAC — Specifies the administrative fines for damaging state lands;
•	Chapter 18-18 FAC — Specifies management of submerged lands within the Biscayne Bay/Card Sound
Aquatic Preserve;
•	Chapter 18-21 FAC — Specifies management of sovereign submerged lands; specifies management
of submerged land within Aquatic Preserves;
•	Chapter 18-21.041 FAC — Specifies special rules adopted in 1985 to augment the existing rules
governing the management of sovereign submerged lands in the Florida Keys;
•	Chapter 253 FS — Provides the Board of Trustees with the authority to manage lands held in trust for
the people of Florida; and
•	Chapter 258 FS — Management of Aquatic Preserves.
OBJECTIVE(S): To regulate use of state-owned submerged lands in such a way as to protect, enhance, and ensure
the balanced use of these lands for the benefit of present and future generations.
JURISDICTION; All submerged lands within state waters of the FKNMS are subject to the laws and regulations
of the State of Florida.
OPERATION: The primary regulatory responsibility of the Division of State Lands relative to water quality within
the FKNMS ccuceras construction on or over lands within its jurisdiction including marinas, water-related
industries, and locking facilities of all types. The role of the Bureau of Submerged Lands and Preserves is
proprietary rather than regulatory. In terms of dredge and fill projects or marina siting projects, actual permits are
issued by the FDER. Once those permits have been issued, the Bureau of Submerged Lands and Preserves issues
"leases" for the submerged lands involved. They have the authority to place special stipulations, such as water
quality monitoring or mitigation requirements, into these land leases. They also charge for all leases issued to
commercial entities such as marinas. Submerged land leases must be renewed periodically to enable the Bureau
to determine if a given commercial enterprise is meeting the requirements of its lease. Submerged land leases can
be canceled if violations of the leasing agreement are detected or continued.
FUNDING: The 1991-1992 budget for bureau activities in the Florida Keys is $85,086 per year.
STAFFING: Three full-time staff members and one temporary staff member are located in the Florida Keys and
operate out of Marathon.
TRACKING: Re-evaluations of whether the stipulated conditions of submerged land leases are being adhered to
and whether they are effectively protecting the lands of the state are made periodically at the time leaseholders seek
to have their leases renewed.
3.2.5.4 FLORIDA MARINE RESEARCH INSTITUTE
PROGRAM RESPONSIBILITIES: The Florida Marine Research Institute (FMRI) is housed within the Division
of Marine Resources. It operates two research facilities in the Florida Keys. One is located in Marathon (South
Florida Regional Laboratory [SFRL]) and the other on Long Key (Keys Marine Lab [KML]). The Institute's major
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research laboratory is in St. Petersburg, Florida. All are conducting research programs aimed at the wise
management of marine resources in the FKNMS.
AUTHORITY: Legislative authority for this program is contained in the following statutes:
•	Chapter 370 FS — Salt Water Fisheries — Authorizes the Division of Marine Resources;
•	Section 370.02(2) FS — Summarise the duties of the Division of Marine Resources; and';
•	Section 370.02(2)(b)l-6 FS — Establishes the FMR1 and designates its purpose to be "to conduct high-
quality marine research on which management decisions can be based."
OBJECTIVE(S): To conduct high-quality marine research to form the basis for management decisions. Research
projects currently in progress at the laboratories within the FKNMS are oriented primarily toward the management
of commercial fisheries species such as conch, lobster, and finfish. A coral reef ecosystem program is based out
of the St. Petersburg facility. Research efforts at St. Petersburg concentrate on studies in the FKNMS.
JURISDICTION: The FMRI conducts research statewide, thus this includes all areas within state boundaries.
OPERATION: Both the SFRL and the KML operate in close coordination with the FMRI's main laboratory in St.
Petersburg. The KML program is operated jointly with the Florida Institute of Oceanography. To date, the focus
of the SFRL has been toward research concerning fisheries management issues, while the KML has sought to
provide a base of operations for the entire spectrum of marine researchers and educators. Of particular interest to
water quality issues are studies being conducted at the KML concerning nutnent dynamics, seagrass ecosystems,
and water current patterns.
FUNDING: Funding for all Florida K ys and FKNMS-related research programs conducted by the FMRI is
$1,925,123.
STAFFING: There are eight profession staff members assigned to the programs conducted through SFRL, and
one person at the KML. There are 23 pr ^ssional staff members at the St. Petersburg facility working on programs
that relate to the habitats or resources v dn the FKNMS.
TRACKING: Individual research proj s have stated goals and objectives. Research projects are tracked by
interim reports, budget expenditures, an lormal management procedures. Results are presented in the form of in-
house reports, presentations, and scienti : publications.
3.3 REGIONAL
3.3. Florida Keys Aqueduct Authority
3.3.1.1 WASTEWATER
PROGRAM RESPONSIBILITIES: Tt. FKAA presently provides potable water to the Florida Keys. Within its
enabling legislation, the FKAA has the legislative mandate to provide wastewater service to all areas within its
defined service area. At this time, the FKAA does not provide such service, although it is exploring the possibility
of assuming the operational responsibilities of the City of Key West wastewater treatment facility.
AUTHORITY: Legislative authority enabling the creation of the FKAA is set out in Florida Law 76441.
OBJECTIVE(S): To create a body with the power to "Own, acquire, construct, reconstruct, operate, maintain,
extend, and improve water systems, and to regulate the use and supply of water within the Authority boundaries. *
JURISDICTION: The FKAA has authority over all water supply matters throughout the Florida Keys.
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OPERATION: At this time, the FKAA supplies only potable water to the Florida Keys.
FUNDING: In terms of wastewater, no funds are expended for such a program at this time.
STAFFING: No staff is assigned because no wastewater program exists, although the Executive Director and the
Deputy Executive Director have had discussions with the City of Key West about assuming the city's wastewater
operations.
TRACKING: Not applicable until the FKAA ultimately becomes the purveyor of wastewater service.
3 J.2 South Florida Water Management District
3 J.2.1 WETLAND REGULATION
PROGRAM RESPONSIBILITIES: To regulate development that potentially affects freshwater or estuanne
wetlands in order to protect and preserve water quality within those areas.
AUTHORITY: The FDER has delegated certain wetland resource permitting responsibilities to the SFWMD. The
delegation of such responsibilities is in conformance with Chapter 403, Sections 120.54 and 380.23 FS, and
Chapters 17-4, 17-301, 17-302, 17-312, and 17-321 FAC.
OBJECT IVE(S):
•	To preserve ambient water quality; and
•	To prevent the loss of wetlands.
JURISDICTION: Within the Florida Keys, the SFWMD regulate activities within freshwater resources, only.
Activities within Florida Bay and the Atlantic Ocean are regulated y other agencies. While all individuals must
comply with all SFWMD stormwater regulations, the SFWMD adrc. nistrative rule (Chapter 40E-4 FAC) exempts
developments under 10 acres in size or projects with less than 2 acre of impervious surface from having to submit
stormwater management applications.
OPERATION: On July 9, 1992, the SFWMD's Governing Board approved an MOU with the FDER which
delegates certain dredge and fill permitting responsibilities from the FDER to the SFWMD. This agreement will
go into effect on November 1, 1992. The dredge and fill activities ?2r which the SFWMD will have responsibility
will occur only when a surface water permit is required from the SFWMD for a proposed project. If the project
is submitted after implementation of the agreement, the SFWMD will permit the proposed dredge and fill activity
using FDER's rules and criteria.
Although no dredge and fill permits have been issued to date, the procedures to be followed will be the same as
those applicants now follow to secure surface water management permits (see discussion in Section 3.3.2.2).
FUNDING: The SFWMD does not budget funds according to geographic area, such as the Florida Keys. Funds
are allocated district-wide according to program needs, (i.e., surface water management, water use, natural
resources management, field engineering, etc.). Funding sources are derived from ad valorem taxes and permit
application fees.
STAFFING: While the SFWMD has.an Intergovernmental Representative based in Big Pine Key, permitting and
compliance activities are handled through the main office in West Palm Beach. Two additional
enforcement/compliance staff members will be added in FY 1992/93 to handle dredge and fill responsibilities on
a district-wide basis.
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TRACKING: The SFWMD will utilize a post-permit compliance program as it currently does for surface water
management permits. The program consists of both office and field activities. Each permit is tracked by a
computer program with regard to data-dependent special conditions of the permit requiring the submittal of specific
information by the permittee. Information has not been received from the SFWMD at this time.
The SFWMD is completing a multi-phase automation program for permit issuance and compliance. It consists of
processes for the automated production of permit staff reports, database storage of important data from those staff
reports, correctly timed and scheduled retrieval of permit data for site inspection monitoring reports, automated
comparison of actual field or monitoring report data against permit values, and tracking and scheduling of required
compliance and enforcement actions.
3:3.2.2 STORMWATER MANAGEMENT PERMITTING
PROGRAM RESPONSIBILITIES: Permitting and regulation of stonnwater discharge.
AUTHORITY: Legislative authority which establishes the SFWMD's responsibility for stonnwater management
is provided in Chapter 373 FS, Parts II, III and IV and Section 120.54 FS. Chapters 40E-1 through 40E-4 FAC
contain the rules of the SFWMD as they relate to implementation of Parts II, III, and IV of Chapter 373 FS. Water
quality responsibilities were delegated from the FDER under Chapter 17-22 FAC in 1982.
OBJECTTVE(S):
•	To provide assurance of adequate flood protection;
•	To be consistent with State water quality standards; and
•	To preserve wetland habitat values.
JURISDICTION: Within the Florida Keys, the SFWMD regulates activities within freshwater resources only.
Activities within Florida Bay and the Atlantic Ocean are regulated by other agencies. While all individuals must
comply with all SFWMD stonnwater regulations, the SFWMD administrative rule Chapter 40E-4 FAC exempts
developments under 10 acres in size or projects with less than 2 acres of impervious surface from having to submit
stonnwater management applications. ,
OPERATION: The three types of individual and general stonnwater management permits include letters of
conceptual approval, construction permits, and operation permits. During the past three years, a total of 121 surface
water management permits were issued in the Flonda Keys, the majority of which were General Permits (60) or
Permit Exemptions (56). The remainder of the surface water management permits issued were Individual Permit
(5) (J. Smith, SFWMD, personal communication, 1992).
Within the SFWMD, the Regulation Department has responsibility for processing and issuing stonnwater permits.
Internally, the Department's permitting activities are coordinated through surface water management review meetings
that are held weekly. These meetings are also attended by staff from the local FDER office and SFWMD staff from
other departments and divisions depending on the specific resource issues associated with a given project.
When the SFWMD staff members review development permits, they evaluate them based in part on water quality/
stonnwater management impacts. Key factors include potential on-site impacts; quality, drainage, and discharge
of water offsite; impacts of stonnwater to existing surface or underground groundwater; and downstream wetlands
impacts.
These issues are also coordinated with agencies external to the SFWMD. Coordination is handled in several ways.
A copy of each new permit application submitted is transmitted to the FDER. The FDER and other agencies, such
as the Florida Game and Fresh Water Fish Commission, FDNR, USACE, and other local government agencies,
are copied on sufficiency letters and staff reports prior to the issuance of permits. Staff at these agencies are also
contacted on an as needed basis to deal with specific problems that arise in the review of specific projects.
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la addition to applications issued by the SFWMD, the county requires an applicant to ^ tain a Letter of Coordination
to verify that the site has received a preliminary review by the SFWMD prior to the issuance of local development
approvals. These letters are issued by the SFWMD's Surface Water Management Division to Monroe County based
on information submitted by the applicant, and they generally indicate permit requirements and any major resource
concerns.
FUNDING: The SFWMD does not budget funds according to geographic area such as the Florida Keys. Funds
are allocated district-wid; according to program needs, (i.e., surface water management, water use, natural
resources management, field engineering, etc.). Funding sources are derived from ad valorem taxes and permit
application fees.
STAFFING: While the SFWMD has an Intergovernmental Representative based in Big Pine Key, permitting and
compliance activities are handled through the main office in West Palm Beach. Because of the limited number/scope
of applications submitted, no one person is assigned to the Florida Keys. The existing permitting staff is adequate
to process permits in the Florida Keys.
During Fiscal Year 1992, the SFWMD developed major enhancements in its overall compliance program which will
benefit all areas of the SFWMD. Six new positions were approved for compliance work and four other existing
positions were redirected into compliance work. While none of these positions are assigned exclusively to the
Florida Keys, they do increase the overall availability of SFWMD staff for compliance work.
TRACKING: The surface water management permit compliance program consists of both office and field
activities. Each permit is tracked by a computer program with regard to data-dependent special conditions of the
permit requiring the submittal of specific information by the permittee.
The SFWMD is completing a multi-phase automation program for permit issuance and compliance. It consists of
. processes for the automated production of permit staff reports, database storage of important data from those staff
reports, correctly timed and scheduled retrieval of permit data for site inspections monitoring reports, automated
comparison of actual field or monitoring report data against permit values, and tracking and scheduling of required
compliance and enforcement actions.
3.4 LOCAL
3.4.1 Monroe County
3.4.1.1 COMPREHENSIVE PLAN
PROGRAM RESPONSIBILITIES: Monroe County, like all counties and cities in the State of Florida, has been
mandated by law to prepare a long-range comprehensive plan that will serve as a blueprint for anticipated growth,
as well as to address problems that exist. All local comprehensive plans must address eight broad areas, each
constituting an element of the plan. They include future land use, transportation, conservation, recreation and open
space, infrastructure (potable water, drainage, solid waste, wastewater, and aquifer recharge), housing,
intergovernmental coordination, and capital improvements. In addition, local governments within coastal areas must
prepare a coastal management element that addresses special issues such as beach erosion, hurricane evacuation,
and estuarine pollution problems.
AUTHORITY: The Monroe County Comprehensive Plan has been prepared in accordance with various provisions
of the following statutes:
• Section 163.3161 FS — The Local Government Comprehensive Planning and Land Development
Regulation Act — Confers on local officials the statutory authority and responsibility to plan and
regelate the use of land by adopting local comprehensive plans and land development regulations;
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•	Chapter 187 hS — The State Comprehensive Plan — A compilation of goals and objectives that
Florida is to achieve through the planning process;
•	Section 186.507 FS — Outlines the requirements of regional comprehensive policy plans; and
•	Section 380.0552 FS — The Florida Keys Area Protection Act — Contains the principles for guiding
development that must be addressed in local government comprehensive plans in the Florida Keys.
The administrative rules that local governments are required to satisfy are as follows:
•	Chapter 9J-5 FAC — Minimum criteria for review of local government comprehensive plans and
determination of compliance;
•	Chapter 9J-11 FAC — Submittal requirements for proposed local government comprehensive plans;
and
•	Chapter 9J-24 FAC — Procedures and criteria for the review of land development regulations.
OBJECTIVE(S): To utilize and strengthen the existing role, processes, and powers of local governments in the
establishment and implementation of comprehensive planning programs to guide and control future development.
The local government comprehensive plan process has the potential to significantly affect water quality within the
FKNMS based on:
•	Maintaining or reducing hurricane evacuation times, which would create restrictions on upland
development limiting future growth in the Florida Keys;
•	Control of upland land development procedures;
•	Stormwater runoff retention level of service requirements; and
•	Sanitary sewer and wastewater treatment facilities level of service requirements.
JURISDICTION: The provisions of the Monroe County Comprehensive Plan 1990-2010 apply to ail areas of the
unincorporated county.
OPERATION: In the State of Florida, not only were local governments required to undertake the preparation of
long-range growth policy plans, but so was the state through the auspices of the state planning agency, FDCA, and
all eight RPCs. The grand design for planning in the State was based on what has been termed a "top-down"
planning process. Regional policy plans and local government comprehensive plans had to be consistent with the
state plan. FDCA, as the state planning agency, was charged with the responsibility of determining whether
regional comprehensive policy plans and local government comprehensive plans were consistent with the state plan,
and in compliance with statutory laws and administrative rules governing comprehensive plans. Because the Florida
Keys are designated ACSC, the comprehensive plan must meet not only the requirements of the Local Government
Comprehensive Planning Act, but also the Principles for Guiding Development m the Florida Keys as set forth in
Section 380.0552 FS.
The State Comprehensive Plan was prepared first and adopted by the Florida Legislature. Next came the regional
policy plans and finally local government comprehensive plans. Monroe County has been involved in plan
preparation for a number of years.
The policies set out in the following plan elements can affect water quality in the FKNMS:
•	Future Land Use;
•	Conservation;
•	Coastal Management;
•	Solid Waste;
•	Wastewater; and
•	Drainage.
Monroe County has adopted and submitted its plan. The plan has been found to be noncompliant. Negotiations
have been conducted and the required settlement agreement has been reached. This agreement must now be adopted
by the county.
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FUNDING: The County Comprehensive Plan was funder. in large part by the FDCA; however, County funds from
generating operating revenues was a source of funding as well.
STAFFING: Comprehensive planning is conducted out of the County's Planning Department. This department is
housed within the Division of Growth Management. The department is involved with all issues affecting the
Monroe County Comprehensive Plan, as well as other areas of planning concern such as the FKNMS. The Planning
Department has 5 planners and 20 support personnel (e.g., planning technicians, graphic designer, secretaries).
Persons in the planning positions have educational backgrounds and experience not only in such areas as
transportation and land use but also in environmental matters. The county recently established the Department of
Marine Resources. It deals specifically with issues related to the FKNMS. Two staff members are assigned to the
department.
TRACKING: The Monroe County Planning Department is planning to establish a Geographic Information System
(GIS) mapping program. The GIS database will be constructed from information generated from the County
Comprehensive Plan effort. However, a number of government agencies will serve as valuable resources. It
includes the multiple databases maintain^ by the FDER, as well as information from the FMRI and the SFWMD.
All proposed changes to the adopted comprehensive plan are reviewed and processed by the FDCA Bureau of Local
Planning for consistency and compliance with adopted state and regional comprehensive policy plans. In addition,
because the Florida Keys are designated ACSC, the FDCA field staff also provides comments regarding proposed
plan amendments. Once the FDCA Florida Keys staff completes its review, comments are submitted to the
Tallahassee Office for inclusion into the Department's official Objections, Recommendations, and Comments (ORC)
response.
The county is required to review its comprehensive plan and make adjustments as necessarily annually, as directed
by Chapter 163 FS. In addition, the county is required by Section 163.3191 FS to review its comprehensive plan
at least every five years after the plan was adopted. The report that documents the review is known as the
Evaluation and Appraisal Report.
3.4.1.2 LAND DEVELOPMENT REGULATIONS
PROGRAM RESPONSIBILITIES: Local governments are required to adopt or amend land development
regulations which are consistent with and implement their adopted comprehensive plans. Land development
regulations must be incorporated into a single land development code, and it must contain, at a minimum,
regulations that
•	Govern the subdivision of land;
•	Implement the land use categories (should contain provisions for ensuring appropriate densities and
intensities, compatible adjacent land uses, and open spaces);
•	Control land uses around identified cones of influence for potable water wells;
•	Regulate development in areas subject to seasonal and periodic flooding;
•	Ensure adequate drainage facilities to control individual and cumulative impacts of flooding and non-
point source pollution;
•	Regulate signage;
•	Ensure that proposed development meet or exceed adopted level of service standards, commonly
known as concurrency management; and
•	Regulate parking.
Further, local governments may include other specific and detailed provisions necessary or desirable to implement
the adopted comprehensive plan.
AUTHORITY: Legislative authority directing local governments to prepare land development regulations is set forth
in Section 163.3202 FS. Administrative Rule 9J-24 FAC specifies the regulations that must be contained within
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the single land development code, as well as criteria for detei mining consistency of the land development regulations
in relation to the local government comprehensive plans. In addition, the rule describes the role and rules involving
the FDCA, and how substantially affected persons, local governments and the FDCA may initiate an administrative
review of the land development regulations.
OBJECTIVE(S): To utilize and strengthen the existing role, processes, and powers of local governments in
regulating the development of the area within their jurisdiction, and ensure that affected persons have a wwnng to
assure that land development regulations implement and are consistent with the local comprehensive plan.
JURISDICTION: The provisions of the Monroe County Land Development Regulations apply to all areas of the
unincorporated comity.
OPERATION: Chapter 9.5 of the Monroe County Code contains the county's land development regulations. The
existing regulations control signage, parking, density and intensity of land use, subdivision of land, adequate
facilities (concurrency management), floodplain management, and environmental resource protection. Section 9.5-
345, Environmental Design Criteria, contains provisions regarding the placement of fill in environmentally sensitive
habitats, (i.e., salt marsh and buttonwood associations, mangroves and submerged lands, beach-berm complex).
Also, the land development regulations include special rules for places in the unincorporated county designated as
Areas of Critical County Concern (ACCC). The purpose of this regulation is to provide procedures and standards
for areas with special environmental sensitivity, important historical or archaeological resources, substantial capital
improvement deficiencies or significant redevelopment opportunities. North Key Largo, Ohio Key, Holiday Isles,
and Big Pine Key have been designated ACCCs. These environmental standards relate more to habitat protection
than to water quality protection.
The county has no wellfield protection regulation. The only specific regulation directly affecting groundwater is
the prohibition of well excavation in "high quality pineland" areas. The county is the sole supplier of potable water
to Monroe County. The wellfields are not within the Florida Keys, but are located west of Florida City in southeast
Dade County. While contamination of the freshwater lens on Big Pine Key may not be an immediate threat to
public health, it could affect the environment which contributes to the economy of the Florida Keys, and thus
indirectly affect its residents. Saltwater intrusion is of primary concern since shrinkage of a given lens system could
result
In addition, there is no stormwater management regulation that sets official standards; however, the county does
address stormwater concerns in its development review process. The county is in the process of adopting a
stormwater management regulation. The county also has no regulation controlling how hazardous materials and
waste are managed. While there are no officially adopted standards, the county addresses such concerns on a case-
by-case basis, whenever it is appropriate (T. Symroski, Monroe County, personal communication, 1992).
Another ordinance was enacted in June 1992 that will have a major impact on future development within the Florida
Keys. It is known as the Dwelling Unit Allocation Ordinance. This ordinance is one of the new land development
regulations (commonly called a rate of growth ordinance) recently added to the county's existing land development
regulations. The ordinance regulates the rate at which the county will issue building permits for residential dwelling
units commensurate with the county's ability to maintain a reasonable and safe hurricane evacuation clearance time.
Between 1989-1990, housing units in the unincorporated county increased at a rate of approximately 900 units per
year. The Dwelling Unit Allocation Ordinance allows only 255 dwelling unit permits be issued annually; this
amounts to a three-fold decrease in residential development. What this means in terms of water quality is that the
prioritization water quality protection strategies should focus first on correcting existing problems, then on
controlling the impacts of new development.
Administrative responsibility rests with the Planning Department that is situated within the Division of Growth
Management. The existing County Land Development Regulations establish a Development Review Committee
comprised of the planning director, the development review coordinator, representatives from the public works
department, health department, county engineer, county biologist, and any other staff person the county
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administrator or planning director feels is necessary to include. Also, the regulatioas provide for a FDCA
representative on the committee as long as the area is designated ACSC. Also, the regulations state that those local,
regional, state and federal agencies that have entered into a intergovernmental agreement with the county should
have an opportunity to participate.
Because it is within the ACSC, the county must transmit all development permits it approves to the FDCA field
office in Key West for review. The state has 43 days from the date the permit is transmitted to the state planning
agency, the FDCA, to appeal the local action. Permits can range from a roof repair to variance petition to a new
hotel site plan.
FUNDING: The county's land development regulations are being modified in part through financial assistance
received from the State of Florida under the Local Government Comprehensive Planning Assistance Program,
Chapter 163 FS. In addition, the county has utilized local general revenues to underwrite the costs of updating the
land development regulations.
STAFFING: The Planning Department has 5 planners and 20 support personnel (e.g., planning technicians, graphic
designer, secretaries). One of the planners serves as the Department Review Coordinator whose primary duties are
facilitating and coordinating the permitting process, coordinating with the regional, state and federal agencies, and
preparing the materials necessary for review by the Development Review Committee, Planning Commission, and
Board of County Commissioners.
Persons in the planning positions have educational backgrounds and experience not only in areas such as
transportation and land use, but also in environmental matters. The county recently established the Department of
Marine Resources. Staff within that department deal specifically with issues related to the FKNMS. Two staff
members are assigned to the department.
TRACKING: All building permits in the county are tracked by a computerized data management system. When
site plans and subdivision applications are submitted, they are assigned to one of several assistant building officials.
These individuals are responsible for controlling the flow of the application through the review process; therefore,
they know exactly where each application is in the review process. Finally, the county will be setting up a tracking
system for the new Dwelling Unit Allocation Ordinance.
3.4.2 City of Key West
3.4.2.1 COMPREHENSIVE PLAN
PROGRAM RESPONSIBILITIES: The City of Key West, like all counties and cities in the State of Florida, has
been mandated by law to prepare a long-range comprehensive plan that will serve as a blueprint for anticipated
growth, as well as address problems that exist. All local comprehensive plans have to address eight broad areas,
each constituting an element of the plan. They include future land use, transportation, conservation, recreation and
open space, infrastructure (potable water, drainage, solid waste, wastewater, and aquifer recharge), housing,
intergovernmental coordination, and capital improvement. In addition, local governments within coastal areas must
prepare a coastal management element that addresses special issues such as beach erosion, hurricane evacuation,
and estuarine pollution problems.
AUTHORITY: The City of Key West Comprehensive Plan has been prepared in accordance with various provisions
of the following statutes:
•	Section 163.3161 FS — The Local Government Comprehensive Planning and Land Development
Regulation Act — Confers on local officials the statutory authority and responsibility to plan and
regulate the use of land by adopting local comprehensive plans and land development regulations;
•	Section 186.507 FS — Outlines the requirements of regional comprehensive policy plans;
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•	Chapter 187 FS — The State Comprehensive Plan — Compilation of goals and objectives that Florida
is to achieve through the planning process; and
•	Section 380.0S52 FS — TTie Florida Keys Area Protection Act — Contains the principles for guiding
development that must be addressed in local government comprehensive plans in the Florida Keys.
The administrative rules that local governments are required to satisfy are as follows:
•	Chapter 9J-5 FAC — Minimum criteria for review of local government comprehensive plans and.
determination of compliance;
•	Chapter 9J-11 FAC — Submittal requirements for proposed local government comprehensive plans;
and
•	Chapter 9J-24 FAC — Procedures and criteria for the review of land development regulations.
OBJECTIVE(S): To utilize and strengthen the existing role, processes, and powers of local governments in the
fftpfriichnwnt and implementation of comprehensive planning programs to guide and control future development.
The local government comprehensive plan process has the potential to significantly affect water quality within the
FKNMS based on:
•	Hurricane evacuation time, restrictions on upland development limiting future growth in the Florida
Keys;
•	Control of upland land development procedures;
•	Stonnwater runoff retention level of service requirements; and
•	Sanitary sewer and wastewater treatment facilities level of service requirements.
JURISDICTION: The provisions of the City of Key West Comprehensive Plan apply to all areas within the legally
defined boundaries of the city.
OPERATION: In the State of Florida, not only were local governments required to undertake the preparation of
long-range growth policy plans, but so was the state through the auspices of the state planning agency, FDCA, and
all eight RPCs. The grand design for planning in the State was based on what has been termed a "top-down"
planning process. Regional policy plans and local government comprehensive plans had to be consistent with the
state plan. FDCA, as the state planning agency, was charged with the responsibility of determining whether
regional comprehensive policy plans and local government comprehensive plans were consistent with the state plan,
and in compliance with statutory laws and administrative rules governing comprehensive plans. Because the Florida
Keys are designated ACSC, the comprehensive plan must meet not only the requirements of the Local Government
Comprehensive Planning Act, but also the Principles for Guiding Development in the Florida Keys as set forth in
Section 380.0SS2 FS.
The State Comprehensive Plan was prepared first and adopted by the Florida Legislature. Next came the regional
policy plans and finally local government comprehensive plans. The City of Key West has been involved in plan
preparation for a number of years.
The policies set out in the following plan elements can affect water quality in the FKNMS:
•	Future Land Use;
•	Conservation;
•	Coastal Management;
•	Solid Waste;
•	Wastewater, and
•	Drainage.
The City of Key West has submitted an initial plan and received an ORC report on this proposed plan. It has been
working with the FDCA Bureau of Local Planning staff and the FDCA field staff located in Key West. The city
and FDCA have resolved most of their differences, but the city has yet to officially adopt the proposed plan.
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FUNDING: The city comprehensive plan was funded in large part from a FDCA grant. The city also used local
funds to underwrite the cost of plan preparation.
STAFFING: Comprehensive planning is conducted out of the city planning office. Staff consists of two planners
and secretaries. The Planning Director is responsible for managing all changes related to the comprehensive plan.
TRACKING: All proposed changes to the adopted comprehensive plan are reviewed and processed by the FDCA
Bureau of Local Planning for consistency and compliance with adopted state and regional comprehensive policy
plans. In addition, because the Florida Keys are designated ACSC, the FDCA field staff also provides comments
regarding proposed plan amendments. Once the FDCA Florida Keys staff completes its review, comments are
submitted to the Tallahassee Office for inclusion into the department's official ORC response.
The city is required to review its comprehensive plan and make adjustments as necessarily annually, as directed by
Chapter 163 FS. In addition, the city is required by Section 163.3191 FS to review its comprehensive plan at least
every five years after the plan was adopted. The report that documents the review is known as the Evaluation and
Appraisal Report.
3.4.2.2 LAND DEVELOPMENT REGULATIONS
PROGRAM RESPONSIBILITIES: Local governments are required to adopt or amend land development
regulations which are consistent with and implement their adopted comprehensive plans. Land development
regulations must be incorporated into a single land development code that must contain, at a minimum, regulations
that
•	Govern the subdivision of land;
•	Implement the land use categories (should contain provisions for ensuring appropriate densities and
intensities, compatible adjacent land uses, and open spaces);
•	Control land uses around identified cones of influence for potable water wells;
•	Regulate development in areas subject to seasonal and periodic flooding;
•	Ensure adequate drainage facilities to control individual and cumulative impacts of flooding and non-
point source pollution;
•	Regulate signage;
•	Ensure that proposed development meet or exceed adopted levels of service standards, commonly
known as concurrency management; and
•	Regulate parking.
Further, local governments may include other specific and detailed provisions necessary or desirable to implement
the adopted comprehensive plan.
AUTHORITY: Legislative authority directing local governments to prepare land development regulations is set forth
in Section 163.3202 FS. Administrative Rule 9J-24 FAC specifies the regulations that must be contained within
the single land development code, as well as criteria for determining consistency of the land development regulations
in relation to the local government comprehensive plans. In addition, the rule describes the role and rules involving
the FDCA, and how substantially affected persons, local governments, and the FDCA may initiate an administrative
review of the land development regulations.
OBJECTIVE(S): To utilize and strengthen the existing role, processes, and powers of local governments in
regulating the development of the area within their jurisdiction, and ensure that affected persons have a means to
assure that land development regulations implement and are consistent with the local comprehensive plan.
JURISDICTION: The provisions of the City of Key West land development regulations apply to ail areas within
the legally defined boundaries of the city.
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OPERATION: The City of Key West implements a number of land development regulations. The existing
regulations address such issues as densities and intensities of land use (zoning), signage, parking, and flooding.
Although concerns such as hazardous waste and stormwater management are not formally regulated, the city takes
these issues into consideration in its site plan review process. However, subsequent to the city adopting its new
Comprehensive Plan in 1991, the City contracted with a consultant to update and expand the land development
regulations to bring them into compliance with the new Comprehensive Plan and the requirements of Section
163.3161 FS and Chapter 9J-24 FAC.
The Planning Department is responsible for processing site plans and re zoning applications. Although there is no
formalized set of administrative review procedures, in practice the City Planning Director seeks input from all
appropriate departments within city government depending upon the particular issue in question. The Chief Building
official is responsible for ensuring that the project is in compliance with the provisions of the development approval.
Whether a project requires City Council approval depends on whether certain minimum development thresholds have
been triggered. In the City of Key West, proposed developments containing less than 9,999 sq. ft and/or less than
20 residential living units are reviewed by city staff and approved by the City Planning Board. Projects larger than
these must receive the approval of City Council (T. Strader and J. Castro, City of Key West, personal
communication, 1992).
FUNDING: The City's land development regulations are being modified in part through financial assistance
(approximately $28,000) received from the State of Florida under the Local Government Comprehensive Planning
Assistance Program, Chapter 163 FS. In addition, the city is planning to supplement the state funds by adding in
an additional $50,000 to update the land development regulations.
STAFFING: At present, the City Planning Department consists of a secretary and Planning Director. Currently,
there is a vacant planner position; however, that position should be filled in the near future. The Chief Building
official has four inspectors that report to him. These individuals have the responsibility for ensuring that the
conditions set forth in the approved development order are being satisfied.
TRACKING: There is no formal traci ng process; however, follow-up is provided by the building official to
ensure that the approved development order is in compliance. Formal tracking of development permits will be
addressed during the updating of the land development regulations.
3.4.2.3 WASTEWATER TREATMENT
PROGRAM RESPONSIBILITIES: The City of Key West provides sanitary sewer service throughout nearly the
entire city. Responsibilities include both operation and maintenance.
AUTHORITY: Legislative authority for the City of Key West to provide for the collection and disposal of sewage
and other liquid wastes is contained in Chapter 180 FS. Municipal Public Works. It enables the city to construct
sewer systems, trunk sewers, intercepting sewers, pumping stations, and treatment and disposal plants. Further,
it allows municipalities to contract with private service providers.
OBJECTIVE(S): To provide an adequate and economically feasible sewage collection, treatment, and disposal
system that promotes the public health, safety, and welfare of the residents of the City of Key West.
JURISDICTION: The city has the authority to provide sanitary sewer service to all areas within its corporate
boundaries.
OPERATION: Sewer service is provided, with few exceptions, throughout the city. The four isolated areas not
presently served will be connected by the mid-nineties. The city's sanitary sewer utility is under the general
management of the City Manager and Director of Technical Services. Operation and maintenance of the city's
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collection system, pump stations, and wastewater treatment facility are performed under a contract operations
agreement with a private company, OMI, Inc. OMI, Inc., reports directly to the City Manager and the Director
of Technical Services.
The city is exploring, only very preliminarily, the possibility of having the FKAA purchase its wastewater system.
FUNDING: The city's wastewater system operating expenses are paid by user fees. Capital costs are funded by
revenue from the city's Renewal and Rehabilitation Fund. Over the next few years, funding from the U.S. Navy
will assist to defray some future capital expansion costs. These funds will be used to tie the area presently served
by the Navy's Sigsbee Park package plant into the city's wastewater system.
STAFFING: The city has only	staff involved in the daily wastewater operations. OMI, Inc., is under
contract for operation and maintenance.
TRACKING: OMI, Inc., maintains all operating records. The contractor prepares and submits monthly Discharge
Monitoring Reports to the city which transmits copies of the reports to EPA in accordance with the provisions of
the city's NPDES permit. The city also files similar reports with the FDER.
3.4.3 City of Key Colony Beach
3.4J. 1 COMPREHENSIVE PLAN
PROGRAM RESPONSIBILITIES: The City of Key Colony Beach, like all :ounties and cities in the State of
Florida, has been mandated by law to prepare a long-range comprehensive pL , that will serve as a blueprint for
anticipated growth, as well as address problems that exist. All local compre :osive plans have to address eight
broad areas, each constituting an element of the plan. These areas inciu i future land use, transportation,
conservation, recreation and open space, infrastructure (potable water, drai ige, solid waste, wastewater, and
aquifer recharge), housing, intergovernmental coordination, and capital lprovements. In addition, local
governments within coastal areas must prepare a coastal management element iat addresses special issues such as
beach erosion, hurricane evacuation, and estuarine pollution problems.
AUTHORITY: The City of Key Colony Beach Comprehensive Plan has been prepared in accordance with various
provisions of the following statutes:
•	Section 163.3161 FS — The Local Government Comprehensive Planning and Land Development
Regulation Act — Confers on local officials the statutory authority and responsibility to plan and
regulate the use of land by adopting local comprehensive plans and land development regulations:
•	Section 186.507 FS — Outlines the requirements of regional comprehensive policy plans;
•	Chapter 187 FS — The State Comprehensive Plan — A compilation of goals and objectives that
Flonda is to achieve through the planning process; and
•	Section 380.0SS2 FS — The Florida Keys Area Protection Act — Contains the principles for guiding
development that must be addressed in local government comprehensive plans in the Florida Keys.
The administrative rules that local governments are required to satisfy are as follows:
•	Chapter 9J-5 FAC — Minimum criteria for review of local government comprehensive plans and
determination of compliance;
•	Chapter 9J-11 FAC — Submittal requirements for proposed local government comprehensive plans;
and
•	Chapter 9J-24 FAC — Procedures and criteria for the review of land development regulations.
OBJECTIVE(S): To utilize and strengthen the existing role, processes, and powers of local governments in the
establishment and implementation of comprehensive planning programs to guide and control future development.
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The local government comprehensive plan process has the potential to significantly affect water quality within the
FKNMS based on:
•	Maintaining or reducing hurricane evacuation times, which would create restrictions on upland
development limiting future growth in the Florida Keys;
•	Control of upland land development procedures;
•	Stormwater runoff retention level of service requirements; and
•	Sanitary sewer and wastewater treatment facilities level of service requirements.
JURISDICTION: The provisions of the City of Key Colony Beach Comprehensive Plan apply to all areas within
the legally defined boundaries of the city.
OPERATION: In the State of Florida, not only were local governments required to undertake the preparation of
long-range growth policy plans, but so was the state through the auspices of the state planning agency, FDCA, and
all eight RPCs. The grand design for planning in the state was based on what has been termed a "top-down"
planning process. Regional policy plans and local government comprehensive plans had to be consistent with the
state plan. FDCA, as the state planning agency, was charged with the responsibility of determining whether
regional comprehensive policy plans and local government comprehensive plans were consistent with the state plan,
and in compliance with statutory laws and administrative rules governing comprehensive plans. Because the Florida
Keys are designated A CSC, the comprehensive plan must meet not only the requirements of the Local Government
Comprehensive Planning Act, but also the Principles for Guiding Development in the Florida Keys as set forth in
Section 380.0552 FS.
The State Comprehensive Plan was prepared first and adopted by the Florida Legislature; next came the regional
policy plans and finally local government comprehensive plans. The City of Key Colony Beach has been involved
in plan preparation for a number of years.
The policies set out in the following plan elements can affect water quality in the FKNMS:
•	Future Land Use;
•	Conservation;
•	Coastal Management;
•	Solid Waste;
•	Wastewater; and
•	Drainage.
The City of Key Colony Beach Comprehensive Plan was found in compliance by the FDCA. It was officially
adopted in February 1992.
FUNDING: The city comprehensive plan was funded through a grant from the FDCA.
STAFFING: The city staff is minimal City planning issues are handled by the Planning and Zoning Chairman.
Plan preparation was completed through the use of a consulting firm.
TRACKING: All proposed changes to the adopted comprehensive plan are reviewed and processed by the FDCA
Bureau of Local Planning for consistency and compliance with adopted state and regional comprehensive policy
plans. In addition, because the Florida Keys are designated ACSC, the FDCA field staff also provides comments
regarding proposed plan amendments. Once the FDCA Florida Keys staff completes its review, comments are
submitted to the Tallahassee Office for inclusion into the department's official ORC response.
The city is required to review its comprehensive plan and make adjustments as necessarily annually, as directed by
Chapter 163 FS. In addition, the city is required by Section 163.3191 FS to review its comprehensive plan at least
every five years after the plan was adopted. The report that documents the review is known as the Evaluation and
Appraisal Report.
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3.4.3.2 LAND DEVELOPMENT REGULATIONS
PROGRAM RESPONSIBILITIES: Local governments are required to adopt or amend land development
regulations which are consistent with and implement their adopted comprehensive plan. Land development
regulations must be incorporated into a single land development code that must contain, at a minimum, regulations
that
•	Govern the subdivision of land;
•	Implement the land use categories (should contain provisions for ensuring appropriate densities and
intensities, compatible adjacent land uses, and open spaces);
•	Control land uses around identified cones of influence for potable water wells;
•	Regulate development in areas subject to seasonal and periodic flooding;
•	Ensure adequate drainage facilities to control individual and cumulative impacts of flooding and non-
point source pollution;
•	Regulate signage;
•	Ensure that proposed development meet or exceed adopted level of service standards, commonly
known as concurrency management; and
•	Regulate parking.
Further, local governments may include other specific and detailed provisions necessary or desirable to implement
the adopted comprehensive plan.
AUTHORITY: Legislative authority directing local governments to prepare land development regulations is set forth
in Section 163.3202 FS. Administrative Rule 9J-24 FAC specifies the regulations that must be contained within
the single land development code, as well as criteria for determining consistency of the land development regulations
in relation to the local government comprehensive plans. In addition, the rule describes the role and rules involving
the FDCA, and how substantially affected persons, local governments, and the FDCA may initiate an administrative
review of the land development regulations.
OBJEdTVE(S): To utilize and strengthen the existing role, processes, and powers of local governments in
regulating the development of the area within their jurisdiction, and ensure that affected persons have a means to
assure that land development regulations implement and are consistent with the local comprehensive plan.
JURISDICTION: The provisions of the City of Key Colony Beach Land Development Regulations apply to all
areas within the legally defined boundaries of the city.
OPERATION: The City of Key Colony Beach manages the development of land within its jurisdiction through
its land development code. The existing code contains provisions that regulate the densities and intensities of land
use, development subject to seasonal and periodic flooding, as well as parking and signage. Presently, the code
does not contain regulations relative to stormwater; however, Policy 1.43 of the Infrastructure Element of the
Comprehensive Plan describes specific drainage standards that must be met by ail new development. More specific
standards may be developed once the City completes its master stormwater management plan. With the exception
of prohibiting boat repairs, bottom scraping, and repainting, hazardous waste issues are not regulated by the city.
The city depends upon the FDER, since the Department has statutory responsibility for regulating hazardous waste
in Florida. In terms of wastewater, the city requires that all development connect to the city's wastewater plant (W.
Botten and J. Sheldon, City of Key Colony Beach, personal communication, 1992).
The city is a very small jurisdiction, both in terms of size (acres) and population; therefore, municipal staff is
minimal. In practice, the Building Inspector administers the land development code for the city, and the Planning
and Zoning Board reviews and makes recommendations on site plans and rezonings, and submits their findings and
recommendations to the City Council for its deliberation. In areas already subdivided, which is the vast majority
of the city, development basically occurs on a lot-by-lot basis. Therefore, within the city the Building Inspector
is the individual who becomes involved in most development permit applications. However, because the Florida
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Keys are designated an ACSC, the FDCA field staff reviews all development permits to ensure they are w
compliance with local regulations and consistent with the city's adopted Comprehensive Plan.
FUNDING: The city's land development regulations are being modified in part through financial assistance received
from the State of Florida under the Local Government Comprehensive Planning Assistance Program, Chapter 163
FS. In addition, the city has utilized local general revenues to underwrite the costs of updating the land development
regulations.
STAFFING: The Building Inspector has sole administrative responsibility with respect to the city land development
regulations. This individual reviews development applications for completeness, and packages the development
application for review by the Planning and Zoning Commission.
TRACKING: Tracking of development permits is done by the Building Inspector at various designated points during
various stages of construction. Since the city is a small community approaching build-out, development activity is
not formally tracked through the development approval process as in larger, more rapid growing local governments
along Florida's east coast.
3.4.3.3 WASTEWATER TREATMENT
PROGRAM RESPONSIBILITIES: The City of Key Colony Beach provides sanitary sewer service throughout
its corporate limits. It is responsible for both the operation and maintenance of the system.
AUTHORITY: Legislative authority for the City of Key Colony Beach to provide for the collection and disposal
of sewage and other liquid wastes is contained in Chapter 180 FS, Municipal Public Works. It enables the city to
construct sewer systems, trunk sewers, intercepting sewers, pumping stations, and treatment and disposal plants.
Further, it allows municipalities to contract with private service providers.
OBJECTIVE(S): To provide an adequate and economically feasible sewage collection, treatment, and disposal
system that promotes the public health, safety, and welfare of the residents of the City of Key Colony Beach.
JURISDICTION: Wastewater service extends to all areas within its corporate boundaries.
OPERATION: The city's sanitary sewer utility is under the general management of the Sewer Utility Board.
Operation and maintenance of the city's collection system, pump stations, and wastewater treatment facility are
performed under a contract operations agreement with a private company, Anti-Pollution Associates.
FUNDING: The city's wastewater system operating expenses are paid for by user fees. They amount to SIS per
month per residential unit. In addition, a connection fee of $3,500 is assessed for each new residential unit.
STAFFING: The city's Sewer Utility Board coordinates with the contractor/operator concerning operational and
maintenance issues and problems.
TRACKING: The city maintains all operating records. The contractor prepares and submits monthly Discharge
Monitoring Reports that are transmitted by the city to EPA in accordance with the provisions of the city's NPDES
permit. The city files similar monthly monitoring reports to the FDER.
2-ซ8

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3.4.4 City of Layton
3.4.4.1 COMPREHENSIVE PLAN
PROGRAM RESPONSIBILITIES: The City of Layton, like ail counties and cities in the State of Florida, has
been mandated by law to prepare a long-range comprehensive plan that will serve as a blueprint for anticipated
growth, as well as address problems that exist. All local comprehensive plans have to address eight broad areas,
each constituting an element of the plan. These areas include future land use, transportation, conservation,
recreation and open space, infrastructure (potable water, drainage, solid waste, wastewater, and aquifer recharge),
housing, intergovernmental coordination, and capital improvement. In addition, local governments within coastal
areas must prepare a coastal management element 'hat addresses special issues such as beach erosion, hurricane
evacuation, and estuarine pollution problems.
AUTHORITY: The City of Layton Comprehensive Plan has been prepared in accordance with various provisions
of the following statutes:
•	Section 163.3161 FS — The Local Government Comprehensive Planning and Land Development
Regulation Act — Confers on local officials the statutory authority and responsibility to plan and
regulate the use of land by adopting local comprehensive plans and land development regulations;
' Section 186.507 FS — Outlines the requirements of regional comprehensive policy plans;
•	Chapter 187 FS — The State Comprehensive Plan — A compilation of goals and objectives that
Florida is to achieve through the planning process; and
•	Section 380.0SS2 FS — The Florida Keys Area Protection Act — Contains the principles for guiding
development that are required to be addressed in local govemmec: comprehensive plans in the Florida
Keys.
The administrative rules that local governments are required to satisfy are ai follows:
•	Chapter 9J-5 FAC — Minimum criteria for review of local ; >vemment comprehensive plans and
determination of compliance;
•	Chapter 9J-11 FAC — Submittal requirements for proposed lc al government comprehensive plans;
and
•	Chapter 9J-24 FAC — Procedures and criteria for the review f land development regulations.
OBJECTIVE(S): To utilize and strengthen the existing role, processes, a;;d powers of local governments in the
establishment and implementation of comprehensive planning programs tr guide and control future development.
The local government comprehensive plan process has the potential to significantly affect water quality within the
FKNMS based on:
•	Maintaining or reducing hurricane evacuation times, which would create restrictions on upland
development limiting future growth in the Florida Keys;
•	Control of upland land development procedures;
•	Stormwater runoff retention level of service requirements; and
•	Sanitary sewer and wastewater treatment facilities level of service requirements.
JURISDICTION: The provisions of the City of Layton Comprehensive Plan apply to all areas within the legally
defined boundaries of the city.
OPERATION: In the State of Florida, not only were local governments required to undertake the preparation of
long-range growth policy plans, but so was the state through the auspices of the state planning agency, FDCA, and
all eight RPCs. The grand design for planning in the State was based on what has been termed a "top-down"
planning process. Regional policy plans and local government comprehensive plans had to be consistent with the
state plan. FDCA, as the state planning agency, was charged with the responsibility of determining whether
regional comprehensive policy plans and local government comprehensive plans were consistent with the state plan,
and in compliance with statutory laws and administrative rules governing comprehensive plans. Because the Florida
2-69

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Keys are designated ACSC, the comprehensive plan must not only the requirements of the Local Government
Comprehensive Planning Act, but also the Principles for Guiding Development in the Florida Keys as set forth in
Section 380.0SS2 FS.
The State Comprehensive Plan was prepared first and adopted by the Florida Legislature. Next ramป the regional
policy plans and finally local government comprehensive plans. The City of Layton has been involved in plan
preparation for a number of years.
The policies set out in the following plan elements can affect water quality in the FKNMS:
•	Future Land Use;
•	Conservation;
•	Coastal Management;
•	Solid Waste;
•	Wastewater, and
•	Drainage.
The City of Layton has adopted its comprehensive plan; however, the city has not submitted it to the FDCA for
compliance determination.
FUNDING: The city comprehensive plan was funded frpm a grant provided to the city by the FDCA.
STAFFING: Due to the city's very small size, staff is minimal City planning issues are handled by the local
planning agency. Plan preparation was completed through the use of a consulting firm.
TRACKING: All proposed changes to the adopted comprehensive plan are reviewed and processed by the FDCA
Bureau of Local Planning for consistency and compliance with adopted state and regional comprehensive policy
plans. In addition, because the Florida Keys are designated ACSC, the FDCA field staff also provides comments
regarding proposed plan amendments. Once the FDCA Florida Keys staff completes its review, comments are
submitted to the Tallahassee Office for inclusion into the department's official ORC response.
The city is required to review its comprehensive plan and make adjustments as necessarily annually, as directed by
Chapter 163 FS. In addition, the city is required by Section 163.3191 FS to review its comprehensive plan at least
every five years after the plan was adopted. The report that documents the review is known as the Evaluation and
Appraisal Report.
3.4.4.2 LAND DEVELOPMENT REGULATIONS
PROGRAM RESPONSIBILITIES: Local governments are required to adopt or amend land development
regulations which are consistent with and implement their adopted comprehensive plans. Land development
regulations must be incorporated into a single land development code that must contain, at a minimum, regulations
that
•	Govern the subdivision of land;
•	Implement the land use categories (should contain provisions for ensuring appropriate densities and
intensities, compatible adjacent land uses, and open spaces);
•	Control land uses around identified cones of influence for potable water wells;
•	Regulate development in areas subject to seasonal and periodic flooding;
•	Ensure adequate drainage facilities to cpntrol individual and cumulative impacts of flooding and non-
point source pollution;
•	Regulate signage;
•	Ensure that proposed development meet or exceed adopted level of service standards, commonly
known as concurrency management; and
•	Regulate parking.
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Further, local governments may include other specific and detailed provisions necessary or desirable to implement
the adopted comprehensive plan.
AUTHORITY: Legislative authority directing local governments to prepare land development regulations is set forth
in Section 163.3202 FS. Administrative Rule 9J-24 FAC specifies the regulations that must be contained within
the single land development code, as well as criteria for determining consistency of the land development regulations
in relation to the local government comprehensive plans. In addition, the rule describes the role and rules involving
the FDCA, and how substantially affected persons, local governments and the FDCA may initiate an administrative
review of the land development regulations.
OBJECTTVE(S): To utili7ซ and strengthen the existing role, processes, and powers of local governments in
regulating the development of the area within their jurisdiction, and ensure that affected persons have a means to
assure that land development regulations implement and are consistent with the local comprehensive plan.
JURISDICTION: The provisions of the City of Layton Land Development Regulations apply to all areas within
the legally defined boundaries of the city.
OPERATION: The City of Layton manages the development of land within its jurisdiction through its land
development code. The existing code contains provisions that regulate the densities and intensities of land use, the
subdivision of land, parking and signage. At present, the city has a separate. ordinance that regulates land,
development subject to seasonal and periodic flooding; however, the flood protection ordinance will be integrated
into the single land development regulations that will be developed in the near future. The present land development
regulation also addresses environmentally sensitive areas. Parcels of land located in such areas would need to
address special provisions set out in the land development regulations that would ensure the protection of the
environmental resources; however, the regulation does not contain any specific standards. Presently, the code does
not contain regulations relative to stormwater or the management of hazardous materials.
In practice, most development permits are limited to individual single family building permits. These permits are
processed and monitored for compliance by the city's Building Inspector. Anything larger than a single family
building permit must receive City Council approval. Rezonings or site plans an processed by the City
Administrator, and undergo the scrutiny of the City Council which serves as both the Planning and Zoning
Commission.
Because the city is within the ACSC. the county must transmit all development permits it approves to the FDCA
field office in Key West for review. The state has 45 days from the date the permit is rendered to FDCA to appeal
the local action. Permits can range from a roof repair to variance petition, to a new hotel site plan.
FUNDING: The City's land development regulations are being modified in part through financial assistance received
from the State of Florida under the Local Government Comprehensive Planning Assistance Program, Chapter 163
FS. In addition, the city will supplement the state funds with local general revenues to defray the costs of updating
the land development regulations.
STAFFING: The city has a very small staff. Basically, staff is limited to the City Administrator and the Building
Inspector. If complex issues arise, the city employs the services of a consulting firm, as needed.
TRACKING: Tracking of development permits is (lone by the Building Inspector at various designated points
during construction. Since the city is a small community approaching build-out, development activity is not formally
tracked through the development approval process as in the larger, more rapid growing local governments along
Florida's east coast.
2-71

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4.0 REFERENCES
Adamus, P.R., L.T. Stockwell, E.J. Clairain, Jr., M.E. Morrow, L.P. Rozas, and R.D. Smith. 1991. Wetland
evaluation technique (WET), Volume I: Literature review and evaluation rationale. Tech. Rep. WRP-DE-
2. U.S. Army Corps of Engineers Waterways Experiment Station, Vicksburg, MS. 292 pp.
Odum, W.E., C.C. Mclvor, and T.J. Smith, III. 1982. The ecology of the mangroves of South Florida: A
community profile. U.S. Fish and Wildlife Service, Washington, DC. FWS/OBS-81/24. 144 pp.
Odum, W.E. and C.C. Mclvor. 1990. Mangroves. Pp. 517-548 in: R.L. Myers and J.J. Ewol (Eds.) Ecosystems
of Florida. University Presses of Florida, Gainesville, FL. 765 pp.
2-72

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APPENDIX A
List of Agencies and People Contacted and Interviewed

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LIST OF AGENCIES AND PEOPLE CONTACTED AND INTERVIEWED
Information pertinent to this Institutional and Agency Management Report was collected through various means.
Relevant literature, legislative laws, agency administrative rules, and Memorandums of Agreement and
Understanding between various agencies were reviewed. Key regulatory agencies at federal, state, regional, and
local levels of government were identified and specific contacts within those agencies were established. Survey
questionnaires concerning program functions were developed and mailed to key individuals associated with specific
water quality regulatory programs. Individuals within identified programs were interviewed either in person or via
telephone.
This Appendix provides the names of the agencies and individuals who were identified as potentially having pertinent
information for this report. Individuals who were sent but did not return questionnaires have (1) following their
names. Individuals who received and returned questionnaires have (2) after their names. Individuals who were
interviewed either in person or via telephone have (3) following their names. Individuals with (4) after their name
reviewed and commented on the draft Institutional and Agency Management Inventory Report. Acronyms used in
the Appendix are defined in the List of Acronyms.
FEDERAL
U.S. ENVIRONMENTAL PROTECTION AGENCY
Gary Collins - Ocean Dumping (2,3,4)
Ed Decker - NPDES Enforcement (3)
Harry Desai - RCRA (2,3,4)
Roland Ferry - Ocean Discharge (2,3,4)
Catherine Fox - Ocean Dumping
Mary Ann Cerber • Nonpoint Sources (2,3,4)
Mike Hollinger - Underground Injection Control (2,3)
David Holroyd • Federal Facilities (3)
Anne Inderbitzin • Dredge and Fill (3)
John Isbell - Underground Storage Tanks (2,4)
Ken Kwan - NPDES Enforcement (2,3)
Jim McGuire • Superfund (2,3)
Fred McManus - FKNMS Intergovernmental Coordination (2,4)
Tammy Moore • NPDES Domestic and Industrial Wastewater Permitting (2,4)
Duncan Powell - Dredge and Fill (2,3,4)
Mark Robertson • NPDES Federal Facilities (2,3,4)
Donna Seadler - Underground Storage Tanks (2)
Chris Thomas - NPDES Storm Water Permitting (2,3,4)
Tom Welboni - Dredge and Fill (4)
Lloyd Wise - Gulf of Mexico Program (2,3,4)
U.S. COAST GUARD
Lt. Robert Garrott - Spills (3,4)
Petty Officer Steven Hansen - Spills (3)
NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION
Billy Causey - Florida Keys National Marine Sanctuary (1,3)
Ed Lindelof - Sanctuaries and Reserves Division (4)
Natalie Peter - Coastal Zone Management (3)
2A-1

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U.S. ARMY CORPS OF ENGINEERS
District IV, Jacksonville
Bob Barron - Dredge and Fill (4)
John Hall - Dredge and Fill (3)
STATE
FLORIDA DEPARTMENT OF AGRICULTURE
Jacksonville Office
John Mulrennan - Entomology and Pest Control (3)
Tallahassee Office
Chuck Buddell - Mosquito Control (3)
FLORIDA DEPARTMENT OF COMMUNITY AFFAIRS
Key West Office
Ken Metcalf - Areas of Critical State Concern (3)
Tallahassee Office
Maria Abadal - Local Planning (3)
Alexis McGee - Developments of Regional Impact (3)
Toy Livingston - Areas of Critical State Concern (2,3,4)
Jim Quinn - Areas of Critical State Concern (3)
Charles Pattison - Resource Planning and Management (2)
FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION
Marathon District Branch Office
R. J. Helbling - Storm Water, Solid and Hazardous Waste (3,4)
Lisa Goodwin - Solid Waste, Hazardous Waste (3,4)
Gus Rios • Wastewater, Underground Injection Control (2,3,4)
Ft. Myers District Office
Abdul Ahmadi - Wastewater (2,3)
Phil Barbaccia - Solid Waste, Hazardous Wastes Underground Injection Control (2)
Ron Blackburn - Water Quality Monitoring (2,3)
Bill Krumholtz - Solid Waste (3)
Gordon Romeis - Dredge and Fill (2)
Tallahassee Office
Phil Coram - Industrial Wastewater (2,3,4)
Bruce DeGrove - Point Source Evaluation (2,3,4)
Rodney DeHan - Drinking and Groundwater Management (2)
Richard Drew - Water Facilities (2,3,4)
Doug Fry - Dredge and Fill (2,3)
Vivian Garfein - Surface Water Management (4)
Lynn Griffin - CZMP Federal Consistency (3)
Joe Haberfeld - Underground Injection Control (3)
Jim Hulbert - Ambient Monitoring (4)
Janet Klemm • Standards (2,3,4)
Greg Lee - Emergency Response (3)
Eric Livingston - Storm Water Management (2,3,4)
Peggy Mathews - FKNMS Intergovernmental Coordination (3,4)
Ellen McCarron • Nonpoint Sources (3)
Elsa Potts - Domestic Wastewater (2,3,4)
Marshall Mott-Smith • Storage Tank Regulation (4)
Tom Swihart • Standards and Monitoring (2,3)
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FLORIDA DEPARTMENT OF HEALTH AND REHABILITATIVE SERVICES
Monroe County Public Health Unit
Chris Williams - Environmental Health (2,3)
Tallahassee Health Office
Enaix Poule • Environmental Health (3)
Kevin Sherman - Environmental Health (2,3,4)
FLORIDA DEPARTMENT OF NATURAL RESOURCES
Key Largo National Marine Sanctuary
Bill Goodwin - Sanctuaries (3)
Marathon Office
Ann Lazar • Submerged Lands (1,3)
Major Ron McCuilers - Florida Marine Patrol (1,3)
Annette Nielson - Submerged Lands, Aquatic Preserves (3)
St. Petersburg Laboratory
Paul Carlson - Research (3)
Ken Haddad • Research (3)
Tallahassee Office
Ernie Bamett - Marine Resources (3)
Dana Bryan - Parks and Recreation (3)
Peter Mallison - State Lands (3)
Fran Manilla • Parks and Recreation (3)
Debbie Parrish - State Lands (3)
Debbie Preble • Oil Spill Emergency Response (3)
Dan Riley • Sanctuaries and Research Reserves (3,4)
FLORIDA GOVERNORS OFFICE
Paul Johnson • Intergovernmental Coordination (3)
David Stage - Data Cataloguing (3)
REGIONAL
FLORIDA KEYS AQUEDUCT AUTHORITY
Paul Mitchell - Engineering (3)
SOUTH FLORIDA REGIONAL PLANNING COUNCIL
Dick Ogbum - Development of Regional Impact (3)
SOUTH FLORIDA WATER MANAGEMENT DISTRICT
Rick Alleman • Planning (3)
Jim Smith - Marathon Office, Local Government Liaison (1,2,3,4)
LOCAL
MONROE COUNTY
Barry Bolbissar • Solid Waste (1,3)
George Garrett - Marine Resources (1,3)
Pat McNeese • Environmental and Comprehensive Planning (3)
Lois Ryan • Mosquito Control (3)
Ty Symvoski - Comprehensive Planning (3,4)
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CITY OF KEY WEST
Ray Archer - Engineering (3)
John Castro - Chief Building Official (3,4)
Paul Cates - Technical Services (3)
Chuck. Hamlin - Port and Transit Authority (3)
Sally Lewis - City Commissioner (Environmental Liaison) (3)
Ted Strader • Planning Director (1,3,4)
Ken Williams - Consulting Engineer (CH2M Hill) (3)
CITY OF KEY COLONY BEACH
William Botten - Planning and Zoning Committee (4)
Joan Rinyu - City Clerk (3)
CITY OF LAYTON
Dean Turaey - Administrator (3,4)
1	- Questionnaires were not returned.
2	- Questionnaires were returned.
3	- Interviews occurred.
2A-4

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TASKS 3 AND 4 — ENGINEERING, MANAGEMENT, AND INSTITUTIONAL OPTIONS
CONTENTS
Acronyms		 vi
1.0 INTRODUCTION	 3-1
2.0 BACKGROUND AND APPROACH 	 3-2
2.1	POLLUTION SOURCES AND LOADINGS	 3-2
2.2	SOURCES TARGETED FOR CORRECTIVE ACTION	 3-4
2.2.1	Domestic Wastewater		3-4
2.2.2	Stormwater 		3-6
2.2.3	Marinas and Live-Aboards		3-6
2.2.4	Landfills		3-6
2.2.5	Hazardous Materials		3-7
2.2.6	Mosquito Control Program		3-7
2.2.7	External Influences 		3-7
2.3	SOURCES NOT TARGETED FOR CORRECTIVE ACTION		3-7
2.3.1	National Pollutant Discharge Elimination System Discharges
other than Wastewater 	 3-7
2.3.2	Underground Tanks	 3-8
2.4	DEVELOPMENT OF OPTIONS	 3-8
2.4.1	Engineering Options		3-8
2.4.2	Management Options			3-8
2.4.3	Institutional Options		3-9
2.5	OPTION NUMBERING 		3-9
3.0 DOMESTIC WASTEWATER	 3-9
3.1	INTRODUCTION 	 3-9
3.1.1	Existing Wastewater Facilities	3-11
3.1.2	Population Growth Considerations	3-12
3.2	ENGINEERING METHODS 	3-13
3.2.1	Centralization of Facilities	3-13
3.2.2	Level and Type of Treatment	3-13
3.2.3	Effluent Disposal . . 	3-14
3.3	ENGINEERING OPTIONS 	3-15
3.3.1	Demonstration Projects	3-15
3.3.2	Wastewater Treatment Outside the City of Key West	3-18
3.3.3	Effluent Disposal for the City of Key West	3-23
3.4	MANAGEMENT OPTIONS	3-24
3.4.1	Option W5 — Develop Water Quality Standards 	3-24
3.4.2	Option W6 — Delegate National Pollutant Discharge Elimination System Program
to the State of Florida		3-25
3.4.3	Option W7 — Require Resource Monitoring		3-26
3.4.4	Option W8 — Establish Permit Fees	3-26
3.4.5	Option W9 — Improve Interagency Coordination	3-27
3.4.6	Option W10 — Improve On-site Sewage Disposal System Permitting	3-27
3.4.7	Option Wll — Establish Interagency Laboratory	3-29
3.4.8	Option W12 — Increase Wastewater Data Management Capacity 	3-30
3.5	INSTITUTIONAL OPTIONS 	3-31
3.5.1	Existing Institutional Framework	3-31
3.5.2	Options	3-31
in

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CONTENTS (continued)
4.0 STORMWATER			3-35
4.1	INTI.ป 'JCTION	3-35
4.2	ENGi. .ERING OPTIONS 	3-35
4.3	MANAGEMENT OPTIONS	3-39
4.3.1	Option S2 — Eliminate Permitting Threshold 	3-39
4.3.2	Option S3 — Enact Stormwater Management Ordinances and Master Plans	3-40
4.3.3	Option S4 — Institute Best Management Practices 	3-41
4.4	INSTITUTIONAL OPTIONS 	3-41
4.4.1	Existing Institutional Framework	3-41
4.4.2	Options	3-42
5.0 MARINAS AND LIVE-ABOARDS	3-44
5.1	INTRODUCTION	3-44
5.2	MANAGEMENT OPTIONS	3^5
5.2.1	Option B1 — Establish No-Discharge Zones	3-45
5.2.2	Option B2 — Establish Mooring Fields	3-46
5.2.3	Option B3 — Enhance Pump-Out Facilities and Usage	3-46
5.2.4	Option B4 — Establish Containment Areas for Boat Maintenance	3-48
5.2.5	Option B5 — Require Manna Operating Permit	3-49
5.2.6	Option B6 — Implement Water Quality Environmental Awareness Program	3-49
6.0 LANDFILLS 	3-50
6.1	INTRODUCTION	3-50
6.2	MANAGEMENT OPTIONS	3-51
6.2.1	Option LI — Conduct Historical Luidfill Search 	3-51
6.2.2	Option L2 — Intensify Landfill Monitoring	3-51
6.3	REMEDIAL ENGINEERING METHODS	3-52
6.3.1	Boring or Mining 	3-52
6.3.2	Upgrading Landfill Closure 		3-53
6.3.3	Leachate Collection and Treatment	3-53
6.3.4	Construction of Slurry Walls 	3-53
6.3.5	Excavation 	3-53
7.0 HAZARDOUS MATERIALS STORAGE, TRANSPORT, AND SPILLS	3-53
7.1	INTRODUCTION	3-53
7.2	MANAGEMENT OPTIONS	3-54
7.2.1	Option HI — Continue Response and Preparedness Planning		3-54
7.2.2	Option H2 — Improve Hazardous Materials Database	3-55
7.2.3	Option H3 — Improve Small Spill Reporting	3-55
7.2.4	Option H4 — Speed Up Storage Tank Inspection	3-56
7.2.5	Option H5 — Change Environmental Crimes from Misdemeanors
and Felonies to Civil Offenses 	3-56
7.2.6	Option H6 — Increase Funding for Environmental Crimes Program 	3-57
8.0 MOSQUITO CONTROL PROGRAM	 	3-58
8.1	INTRODUCTION			3-58
8.2	MANAGEMENT OPTIONS	3-58
8.2.1	Option Mia — r educe Aerial Spraying Over Marine Areas 	3-58
8.2.2	Option Mlb — Temporarily Ban Aerial Spraying	3-59
9.0 FLORIDA BAY/EXTERNAL INFLUENCES 			 	3-60
iv

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CONTENTS (continued)
10.0 REFERENCES	3-61
APPENDICES
A Pollution Source Inventory and Loadings
B Engineering Methods for Domestic Wastewater Collection, Treatment, and Disposal
C Engineering Options for Domestic Wastewater Collection, Treatment, and Disposal
D Engineering Methods for Storm water Collection, Treatment, and Disposal
E Engineering Options for Storm water Collection, Treatment, and Disposal
TABLES
3-1 Summary of nutrient and suspended sediment loadings from domestic wastewater and stormwater ... 3-3
3-2 Types of options developed for pollution sources	 3-5
3-3 List of engineering and management options for all pollution sources 	3-10
3-4 Summary of engineering and management options for domestic wastewater	3-16
3-5 Nutrient reductions and cost estimates for wastewater engineering options 	3-17
3-6 Engineering methods for stormwater pollution control	3-36
3-7 Nutrient and sediment reductions and cost estimates for stormwater engineering options	3-37
v

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ACRONYMS
ACSC
Area of Critical State Concern
ASR
aquifer storage and recovery
AWT
advanced wastewater treatmeo'
BOD
biological oxygen demand
BODj
biochemical oxygen demand
BMP
Best Management Practices
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CETS
Compliance Enforcement Tracking System
CFR
Code of Federal Regulations
COD
chemical oxygen demand
DO
dissolved oxygen
EPA
U.S. Environmental Protection Agency
FAC
Florida Administrative Code
FDCA
Florida Department of Community Affaire
FDER
Florida Department of Environmental Regulation
FDHRS
Florida Department of Health and Rehabilitative Services
FDNR
Florida Department of Natural Resources
FDOT
Florida Department of Transportation
FKAA
Florida Keys Aqueduct Authority
FKNMS
Florida Keys National Marine Sanctuary
FMP
Florida Marine Patrol
FS
Florida Statutes
FWS
[U.S.] Fish and Wildlife Service
GIS
Geographic Information System
GMS
Groundwater Management System
GPD
gallons per day
I/I
infiltration/inflow
mg/L
milligrams per liter
MGD
million gallons per day
MOA
Memorandum of Agreement
MOU
Memorandum of Understanding
nh3
ammonia
nh3-n
immnnia nitrogen
no3
nitrate
NO3-N
nitrate nitrogen
NOAA
National Oceanic and Atmospheric Administration
NPDES
National Pollutant Discharge Elimination System
O&M
operation and
OSDS
on-site sewage disposal system
PAED
Pluming Area Analysis/Enumeration Districts
PCB
polychlorinated biphenyl
PCS
Pollution Control Structures
PE
Professional Engineer
PO4
phosphate
QA/QC
Quality Assurance/Quality Control
RCRA
The Resource Conservation and Recovery Act
SFWMD
South Florida Water Management District
STEP
septic tank effluent pump
SWIM
Surface Water Improvement and Management
TN
total nitrogen
TP
total phosphorus
vi

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ACRONYMS (continued)
TREEO
[University of Florida Center for] Training, Research, and Education for Environmental Occupations
TSS
total suspended solids
ULV
ultra low volume
USACE
U.S. Army Corps of Engineers
USCG
U.S. Coast Guard
WWTP
wastewater treatment plant
WQBEL
water quality-based effluent limitation
vii

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TASl^S 3 AND 4 — ENGINEERING, MANAGEMENT, AND INSTITUTIONAL OPTIONS
1.0 INTRODUCTION
The objective of Tasks 3 and 4 is to provide a range of options for corrective actions to reduce pollution entering
Florida Keys National Marine Sanctuary (FKNMS) waters. As described in the General Introduction, a major goal
of the Water Quality Protection Program is to "recommend priority corrective actions and compliance schedules
addressing point and nonpoint sources of pollution to restore and maintain the chemical, physical, and biological
integrity of the sanctuary." Options presented here will be considered by the Environmental Protection Agency
(EPA) for recommendation as priority corrective actions in the Water Quality Protection Program document. In
addition, the options will be considered by the National Oceanic and Atmospheric Administration (NOAA) for
inclusion in management alternatives being developed for the Sanctuary.
Two caveats must be noted here. First, the options presented here are just that — options — not recommended or
approved courses of action. Some options may seem obviously beneficial and innocuous; others may be so
expensive or controversial that they would never be implemented. Second, the level of detail provided in this report
is sufficient to evaluate the options but not sufficient to implement them. Implementation requirements will be
detailed in "Action Plans" prepared by NOAA for any options selected. Environmental and socioeconomic impacts
of options eventually included in NOAA's management alternatives for the FKNMS will be evaluated in an
environmental impact statement.
Phase I of the Water Quality Protection Program included the identification of known, suspected, and potential
pollution sources affecting water quality in the FKNMS. An inventory of pollution sources is given in the Phase I
report. An updated pollution source inventory is included here in Appendix A. Based on the available information,
pollution sources were targeted for corrective actions involving one or more of three types of options (discussed in
more detail in Section 2.0):
ฐ Engineering options
Options designed to reduce pollution directly through engineering methods.
•	Management options
Options to reduce pollution directly by prohibiting or restricting certain activities, tightening existing
regulations, increasing enforcement, and/or increasing environmental awareness. Other management
options are recommendations to make the regulatory/management system work more efficiently and
would have little or no direct effect on pollution.
•	Institutional options
Options for institutional control of the pollution source (if applicable). These have little or no direct
effect on pollution.
The organization of this document is intended to provide the reader with an adequate description and rationale for
the options, while providing additional detail in the Appendices:
•	Section 2.0
This section reviews pollution sources .and loadings, identifies sources targeted for corrective action,
and explains types of options considered and how they were developed.
•	Sections 3.0-9.0
These sections describe the options for each pollution source targeted for corrective action.
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Appendices A-E
The appendices present detailed supporting data, including pollution sources and loadings and
descriptions of engineering methods and options.
2.0 BACKGROUND AND APPROACH
2.1 POLLUTION SOURCES AND LOADINGS
An inventory of pollution sources in and adjacent to the FKNMS is given in Task 2, Section 3.0 of the Phase I
report. An updated pollution source inventory is included in Appendix A of this Task 3 and 4 report.
For each pollution source identified in Appendix A, loadings are quantified for only those pollutants that are of
primary concern with respect to adverse effects on receiving water quality, and that can be estimated by reliable
means. This approach lays the groundwork for subsequent development of engineering options that focus on
removal of the most significant pollutant loadings associated with the various sources. Targeted pollutants associated
with the two major source categories are as follows:
The main focus of engineering options in this report is reducing nutrients in wastewater and stonnwater. Toxic
constituents in stormwater runoff have a relatively high potential for adversely affecting nearshore marine waters,
particularly in confined areas. However, because of the great variety of toxic materials, the wide range of
concentrations at which specific constituents are toxic, the high variability from site to site, and the lack of
stormwater data in the Keys, toxic loadings cannot be quantified with any degree of confidence. Toxic materials
are not targeted for pollution sources other than stonnwater because there are no data indicating significant or
persistent toxicity problems associated with those sources. Oxygen demand is not targeted because oxygen depletion
has not been demonstrated to be a significant problem, with the possible exception of some confined waters. There
is only one cooling water discharge identified within the FKNMS (Stock Island Steam Plant), and it has not been
demonstrated to have adverse thermal or toxic impacts on receiving waters. No adverse salinity effects have been
attributed to discharges originating within the FKNMS.
A summary of total nitrogen, total phosphorus, and total suspended sediment loadings to the FKNMS from domestic
wastewater and stormwater is given in Table 3-1. Calculations of nutrient loadings from various groundwater
pollution sources assume that no significant absorption or adsorption of nutrients occurs in the shallow surface soils
or underlying limestone formations. While there is some evidence that certain forms of phosphorus are absorbed
within the limestones, the evidence is not conclusive and the overall, long-term retention of phosphorus within the
formations has not been shown to be significant.
Table 3-1 indicates that wastewater sources account for about 84% of the combined wastewater/stormwater nitrogen
loadings and 66 % of the combined wastewater/stormwater phosphorus loadings. Atmospheric nutrient inputs have
not been estimated for the FKNMS, although rough calculations based on data from Tampa Bay (Fanning 1992)
indicate that atmospheric nitrogen loadings to the FKNMS may be 8 to 20 times the combined nitrogen loadings
of wastewater and stonnwater. Atmospheric nutrient loadings are derived from both anthropogenic and natural
sources. Advective nutrient inputs from Florida B?y, Biscayne Bay, and the Florida Current are believed to be
potentially significant, but cannot be quantified with existing data. Both atmospheric and advective nutrient inputs
are targeted for further study under the Research Program (Task 7). Other human inputs, such as non-wastewater
National Pollutant Discharge Elimination System (NPDES) discharges, marinas, landfills, hazardous material spills,
and underground storage tanlrs are not believed to be regionally significant sources of nutrients.
Source Category
Pollutant Category
Domestic wastewater
Stormwater
Nutrients
Nutnents, sediment, toxics
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Table 3-1. Summary of r utrient and suspended sediment loadings from
domestic wastewater and stormwatcr.*
Source
TN
(lb/day)
TP
(lb/day)
TSS
(tons/day)
DOMESTIC WASTEWATER



OSDS
1553
377
ND
Cesspits
709
250
ND
Package plants
(groundwater discharge)
758
152
ND
Municipal wastewater treatment
plants (surface discharge,
NPDES)
320
36
ND
Live-aboards
84
30
ND
Total
3424
845

STORMWATER



Developed areas
401
364
85
Undeveloped areas
234
75
39
Total
635
439
124
ND: No data.
'Calculations are based on the 209 treatment plants listed in the Phase I report
(Table 2-5). Recent, unverified information suggests there may be as many as
270 treatment facilities in the Florida Keys.
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As indicated in Table 3-1, about 69% of the total estimated stormwater sediment load is from developed areas and
31 % is from undeveloped areas (developed areas account for about 29 % of the total Keys land mass). A significant
portion of toxic constituents present in stormwater runoff will be associated with this .sediment load. Advecuve
sediment inputs from Florida Bay, Biscayne Bay, and the Florida Current are believed to be potentially significant,
but cannot be estimated with the existing data.
The possibility that nutrient and sediment loadings from external sources may be greater than anthropogenic loadings
from wastewater or stormwater sources should not diminish the importance of focusing on anthropogenic nutnent
loadings and their effects on water quality. Nutrient loadings from atmospheric sources are diffuse and somewhat
evenly distributed over the Sanctuary. Wastewater nutrient loadings emanate from the land/water boundary and may
cause concentration increases in nearshore waters well above those caused by atmospheric inputs. Similarly,
external advective nutrient or sediment inputs would be more diffuse than their land-based, human-induced
counterparts. Understanding the physical processes driving these advective and atmospheric loadings and the effects
they may have on water quality within the Sanctuary would require a considerable data collection and analysis effort,
and is therefore identified as a topic for further study in the Research Program (Task 7).
Nutrient and sediment loadings in Table 3-1 are based on current population and development intensity. Population
growth in the Keys will be limited by the caps of 2552 equivalent residential units in the unincorporated county and
1150 equivalent residential units between Key West, Key Colony Beach, and Layton over the next 20 years (see
Section 3.1.2). Using 2.2 persons per household, this would result in a population increase of only 8,144 or 8.5%.
Wastewater flows are proportional to population, and the values in Table 3-1 would increase accordingly.
Stormwater pollution loadings are not directly proportional to population, but it is reasonable to assume that they
are proportional to population in the absence of other data. Population growth is discussed further in Section 3.1.2.
Note: Information received in Florida Department of Environmental Regulation (FDER) comments on the Phase
I report indicates that there are 270 wastewater treatment plant (WWTP) permits and 250 active WWTPs
in the Keys. Because updated information on the additional WWTPs has not been received, this report and
all calculations of nutrient removals and costs will address the 209 WWTPs identified in the Phase I report.
The additional WWTPs will affect nutrient removals and costs associated with some engineering options,
but only by a relatively small percentage (less than 5% for most options). Overall strategies and structure
of the engineering options will not be affected.
2.2 SOURCES TARGETED FOR CORRECTIVE ACTION
Based on the discussion above, the supporting details in Appendix A, and the Phase I report, each pollution source
was considered for engineering and/or management options. The types of options developed for each pollution
source are summarized in Table 3-2.
2.2.1 Domestic Wastewater
Wastewater discharges originating from land-based sources account for about three quarters of the
wastewater/stormwater nutrient loadings from within the FKNMS. Insufficient site-specific data exist to confirm
a direct relationship between groundwater disposal of package plant or on-site sewage disposal system (OSDS)
effluents and regional nearshore or offshore water quality in the FKNMS. Several studies have suggested
relationships between OSDS use and nutrient levels in nearshore and offshore waters of the FKNMS. Limited data
have also indicated a relationship between high OSDS densities and poor water quality conditions in semi-confined
waters such as dead-end canals. These observations and studies, together with the magnitude and extent of estimated
nutrient loadings from wastewater sources are a strong indication that these combined sources are regionally
significant. A full range of engineering and management options was developed to reduce pollutant loadings from
wastewater. In addition, the existing institutional framework was reviewed, and alternative institutional
arrangements were evaluated.
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Table 3-2. Types of options developed for pollution sources.
Pollution Source
Engineering
Options
Management
Options
Institutional
Options
Domestic Wastewater
•
•
•
NFDES Discharges other than
Wastewater



Stonnwater
•
•
•
Marinas and Live-Aboards



Mosquito Control Program .

•

Landfills

fb

Hazardous Materials

•

Underground Tanks

|c

External Influences



•Only management options are presented for marinas/live-aboards; however, engineering
methods would be required to implement some of them.
bOnly investigative management options are presented for landfills. Engineering options
would have to be developed on a case-by-case basis if problems were discovered. An
overview of applicable engineering methods is presented.
eA separate section of options for underground storage tanks is not presented. However,
one management option relevant to underground tanks is included under Hazardous Materials.
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2.2.2 Storm water
Stormwater is a source of nutrients, sediment, and toxic materials to FKNMS waters. Stormwater nutrient loadings
constitute about one quarter of the wastewater/stormwater nutnent loadings to the FKNMS. Stormwater also carries
significant quantities of suspended sediment to nearshore waters. In areas of heavy vehicular traffic and in
commercial or industrial areas, the potential also exists for the discharge of fuel, oil, metals, and other
contaminants. These observations, coupled with the low level of stormwater control throughout the FKNMS,
jซ4irntiป that stormwater is a regionally significant source of pollution within the FKNMS. A full range of
engineering and management options was developed to reduce these loadings. In addition, the existing institutional
framework was reviewed, and alternative institutional arrangements were evaluated.
2.2.3 Marinas and Live-Aboards
Disposal of wastewater by live-aboards represents an estimated 2% of all total stormwater and wastewater nutrient
loadings to FKNMS waters. For this reason, detrimental effects of live-aboard wastewater disposal are not likely
to be significant from a regional standpoint. However, because of the low level of treatment, the tendency of live-
aboards to congregate in certain mannas or anchorages, and potential adverse health effects of discharging untreated
wastewater into Sanctuary waters, live-aboard wastewater disposal is a significant localized problem. Methods for
collecting wastewater from live-aboards are fairly simple and inexpensive. However, the regulatory or management
issues to be addressed in order to implement proper collection and disposal of live-aboard wastes are somewhat
complex. For this reason, collection of wastewater from live-aboards is addressed under management options rather
than under engineering options.
Marina operations with the potential for polluting water or sediments include boat bottom scraping and painting,
fueling operations, residual fuels and oils from engine repairs or bilge cleaning, and the use or disposal of resins
and solvents associated with fiberglass construction or repair. Available data are insufficient to quantify loadings
of pollutants to waters and sediments or to assess the detrimental effects of bottom painting operations. There are
no data documenting detrimental effects from other marina operations — only anecdotal evidence such as visible
sheens on waters near fueling operations. Management options (some of which would involve engineering) are
presented.
2.2.4 Landfills
For active and recently closed landfills in the Keys, there is no indication of a leaching problem based on existing
monitoring data, but more information is needed. Two investigative management options are presented, followed
by an overview of remedial engineering methods to be considered if problems are found.
The four U.S. Navy landfills being arasseri under the U.S. Navy Installation Restoration Program all show evidence
of metals and other contamination in groundwater and soils. The extent of this contamination is continuing to be
assessed. If found to warrant remedial actions, those actions would be designed and implemented under the
Installation Restoration Program in accordance with the guidelines of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) and The Resource Conservation and Recovery Act (RCRA). Given
the level of effort toward remediation at these four landfill sites, additional action is not warranted.
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2.2.5 Hazardous Materials
Spills of toxic or hazardous materials occur occasionally in the Keys, but little historical information is available
on the frequency or severity of spills. Discussions with FDER personnel in Marathon indicate that most spills are
minor, involving less than 100 gallons of material. These spills do not appear to regionally significant, but could
create local problems. The possibility also remains that a large spill could occur (e.g., tanker grounding), with the
potential for regional consequences. Due to the lack of evidence indicating degradation from spills and their
unpredictable nature, engineering options addressing toxic or hazardous material spills are not warranted.
Management options were developed to decrease the potential for spills and to increase spill response readiness.
2.2.6 Mosquito Control Program
Although the amounts of pesticides used in the Mosquito Control Program are known, little information is available
regarding the amounts that reach FKNMS waters. Also, little is known about the environmental concentrations or
effects of residual pesticides in the Sanctuary. The use of engineering options for mosquito control (e.g., pumped
mosquito impoundments) is being discontinued elsewhere in Flonda and would probably not be practical or
permittable in the Keys. With no evidence indicating regional degradation from mosquito control operations, and
with engineering options being impractical from the outset, the only actions considered were further study [through
the Monitoring Program (Task 6) and the Research Program (Task 7)] and management options to refine the existing
spraying program or temporarily ban aerial spraying while gathering further information.
2.2.7 External Influences
Hie Phase I report indicates that there are potentially significant external influences on water quality in the FKNMS.
Potentially significant influences in terms of advection (water transport) include Florida Bay, Biscayne Bay, and the
Florida Current. In addition, atmospheric loadings could be a substantial contributor to the nutrient budget. These
external influences require further study, and are therefore included in the Research Program described under
Task 7. However, the need for action regarding water delivery problems in Florida Bay has been strongly stressed
by workshop participants and other scientists during the development of the Water Quality Protection Program.
Therefore, a management option for working to restore the historical freshwater flow to Florida Bay is included
here.
2.3 SOURCES NOT TARGETED FOR CORRECTIVE ACTION
Two pollution sources were not considered for engineering or management options: NPDES discharges other than
wastewater, and underground storage tanks. The rationale for not considering these sources is discussed below.
2.3.1 National Pollutant Discharge Elimination System Discharges Other than Wastewater
Only seven NPDES discharges other than wastewater were identified. Of these, four have ceased surface water
discharge or have never discharged, two provide emergency or stormwater discharges, and one (the City of Key
West Utilities Stock Island Steam Plant cooling water discharge) regularly discharges. Water quality data for the
Stock Island Steam Plant discharge do not indicate a significant potential for degradation of receiving waters.
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2.3.2 Underground Tanks
Underground tanks constructed prior to current FDER requirements for secondary containment and monitoring have
the potential to adversely affect groundwater and surface waters in the Sanctuary. Most of these are fuel tปnirc
associated with service stations or marinas. In 1984, the FDER began a program to retrofit all stationary mnlrc to
achieve secondary containment, provide leak detection capability, and install monitoring systems and overfill
protection. When old fuel tanks are replaced under the FDER retrofitting program, soil samples are analyzed and
any fuel contamination from the tank is required to be cleaned (e.g., through soil excavation and incineration,
floating fuel recovery, etc.). All identified facilities were to have monitoring systems in place by 1989. The lining
or replacement of non-approved tanks began in 198S and is scheduled to be completed by 1998. All identified
stationary underground tanks are presumed to be included in this retrofitting program.
The FDER underground storage tank program represents a considerable effort toward resolving water quality
problems associated with leaking underground storage tanks, and additional efforts in this area are not warranted.
Therefore, a separate group of options for dealing with underground storage tanks was not developed. One
management option to hasten the FDER inspection and retrofitting program is included in Section 7.0.
2.4 DEVELOPMENT OF OPTIONS
Three types of options were developed for this report: engineering, management, and institutional. The sections
below explain what each type of option is designed to do, which pollution sources were targeted for each type of
option, and how the options were developed.
2.4.1 Engineering Options
Engineering options are designed to reduce pollution directly through engineering methods. Engineering options
were developed for two major pollution sources: domestic wastewater and stormwater. Options were developed
under Task 4 by reviewing the existing facilities and the applicable engineering solutions, including both
conventional (e.g., advanced wastewater treatment [AWT]) and innovative (e.g., nutrient-removing OSDS)
techniques and equipment. Preliminary engineering options were discussed at the Engineering/Management Options
Workshop (August 1992). For each engineering option, anticipated construction and operating/maintenance costs
and pollution reductions were estimated.
2.4.2 Management Options
Management options include reducing pollution directly by prohibiting or restricting certain activities, tightening
existing regulations, increasing enforcement, and/or increasing environmental awareness. Other management options
are recommendations to make the regulatory/management syster- work more efficiently and would have little or no
direct effect on pollution. Management options were developed . t all of the sources targeted for corrective action:
domestic wastewater, stormwater, marinas/live-aboards, landfills, hazardous materials, the Mosquito Control
Program, and external influences. The first step in developing management options was conducting an institutional
and agency management inventory to identify agencies and institutions with jurisdiction over water quality in the
Florida Keys (Task 2). Then, under Task 3, management options were developed through questionnaires and
interviews with personnel from federal, state, and local agencies and institutions. Preliminary management options
were discussed at the Engineering/Management Options Workshop (August 1992). Because of the nature of most
management options, costs and pollution reductions were not quantified.
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2.4.3 Institutional Options
Institutional options are for the institutional control of the pollution source (if applicable) and would have little or
no direct effect on pollution. Institutional options were developed for two major pollution sources: domestic
wastewater and stonnwater. The first step in developing institutional options was conducting an institutional and
agency management inventory to identify agencies and institutions with jurisdiction over water quality in the Florida
Keys (Task 2). Then under Task 3, the existing institutional framework was reviewed, and alternative institutional
arrangements were considered. Information was obtained through questionnaires and interviews with personnel from
federal, state, and local agencies and institutions. Preliminary institutional options were discussed at the
Engineering/Management Options Workshop (August 1992). Because of the nature of the institutional options, costs
and pollution reductions were not quantified.
2.5 OPTION NUMBERING
Engineering	and management options are numbered within pollution source categories, which are identified by
letters:
ฐ	W = wastewater
ฐ	S = stonnwater
•	B = marinas/live-aboards
•	L = landfills
•	H = hazardous materials
•	M = Mosquito Control Program
•	E = external influences
Table 3-3 lists all of the engineering and management options presented in subsequent sections. Under each topic,
the options that are essentially independent are numbered sequentially. For example, the options for hazardous
materials are numbered HI, H2, H3, etc. Related options reflecting a gradient of mutually exclusive actions are
ordered alphabetically. For example, seven options are presented for dealing with wastewater treatment outside the
City of Key West, ranging from upgrading existing systems to current standards (Option W3a) to advanced treatment
for almost the entire Keys (Options W3f and W3g).
Unlike the engineering and management options, institutional options are not assigned option numbers because the
engineering and management options are all designed to be considered for inclusion into the NOAA management
alternatives for the Sanctuary. The option numbering scheme is designed to be similar to NOAA's numbering
scheme for water quality "strategies" (=options). Under NOAA's framework, institutional options would be
considered matters of implementation and would not appear as "strategies."
3.0 DOMESTIC WASTEWATER
3.1 INTRODUCTION
Domestic wastewater is the largest local anthropogenic source of nutrients to FKNMS waters. Accordingly, a full
range of engineering, management, and institutional options was developed for this pollution source. Because of
the complexity of the engineering methods and options, most of the details are described in the appendices. The
text of Section 3.0 is organized into five major subsections:
• Section 3.1 — Introduction
This subsection describes the existing wastewater facilities and summarizes the nature of the problem.
A discussion of the historic and projected population growth in the Florida Keys is included because
this would affect the magnitude of nutrient reductions achieved through engineering options.
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Table 3-3. Li ;t of engineering and management options for all pollution sources.
Text explains option numbering and details of each option.
DOMESTIC WASTEWATER
Engineering Option: Demonstration Project*
•	W1 — Alternate OSDS Demonstration Project
•	W2 — AWT Demonstration Project
Engineering Options: Wastewater Treatment Outside
Key West
•	W3a — Upgrade Existing Systema to Current Standard]
•	W3b — Upgrade OSDSa to Current Standarda and
Upgrade Package Plant! to AWT
•	W3c — Upgrade OSDSa to Alternate,
Nutrient-Removing Syne mi and Upgrade Package
Plant! to AWT
•	W3d — Construct Two Community Waatewaier
Treatment Planta for Marathon and Key Largo and
Use Excels Capacity of Key Wen Waatewaier
Treatment Plant in Lower Keys
•	W3e — Construct Seven Community Wastewater
Treatment Plants for Moat Densely Populated Areas
•	W3f — Conauuct Twelve Community Wastewater
Treatment Plants for All Areaa
•	W3g — Conauuct Three Sub regional Wastewater
Treatment Plants
"'"'fl Options: Effluent Disposal, City of Key West
•	W4a — Deep well injection
•	W4b — Reuae for irrigation outside the Florida Keys
•	W4c — Reuse for potable water
Management Options
•	WS — Develop Water Quality Standarda
•	W6 — Delegate NPDES Program to the Slate of Florida
•	W7 — Require Resource Monitoring
•	W8 — Establish Permit Fees
•	W9 — Improve Interagency Coordination
•	WIO — Improve OSDS Permitting
•	W11 — Establish Interagency Laboratory
•	W12 — Increase Wastewater Data Management Capacity
STORMWATER
Engineering Options
•	Sla — Retrofit Hot Spou
•	Sib — Retrofit Hot Spots and Population Centers
•	Sic — Retrofit Stormwater Facilities Throughout
Sanctuary
Management Options
•	S2 — Eliminate Permitting Threshold
•	S3 — Enact Stormwater Management Ordinancea and "
Master Plana
•	S4 — Institute Beat Management Practices
MARINAS AND LIVE-ABOARDS
Engineering/Management Options
•	B1 — Establish No-Discharge Zones
•	B2 — Establish Mooring Fields
•	B3a — Increase Pump-Out Facilities
•	B3b — Enforce Pump-Out Use
•	B4 — Establish Containment Areas for Boat Maintenance
•	B5 — Require Marina Operating Permit
•	B6 — Implement Water Quality Environmental
Awareneu Program
LANDFILLS
Management Options
•	LI — Conduct Historical Landfill Search
•	L2 — Intensify Landfill Monitoring
HAZARDOUS MATERIALS
Management Options
•	HI — Continue Response and Preparedness Planning
•	H2 — Improve Hazardous Materiala Database
•	H3 — Improve Small Spill Reporting
•	H4 — Speed Up Storage Tank Inspection
•	H5 — Change Environmental Crimea from
Misdemeanors and Felonies lo Civil OfTensea
•	H6 — Increase Funding for Environmental Crimes
Program
MOSQUITO CONTROL PROGRAM
Management Options
•	Mia — Reduce Aerial Spraying over Marine Areaa
•	Mlb — Temporarily Ban Aerial Spraying
EXTERNAL INFLUENCES
Management Option
•	El — Restore Freshwater Flow to Florida Bay
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•	Section 3.2 — Engineering Methods
This subsection summarize the engineering methods applicable to domestic wastewater. Details are
provided in Appendix B.
•	Section 3.3 — Engineering Options
This subsection summarizes the engineering options in three categories: demonstration projects,
wastewater treatment outside Key West, and effluent disposal for the City of Key West. Estimated
costs and nutrient reductions are presented. Details are provided in Appendix C.
•	Section 3.4 — Management Options
This subsection describes the eight management options for reducing pollution and/or improving the
existing management/regulatory system.
•	Section 3.5 — Institutional Options
This subsection reviews the existing institutional framework for the management and permitting of
domestic wastewater in the Florida Keys. Three options (alternative institutional arrangements) are
presented.
3.1.1 Existing Wastewater Facilities
In the Florida Keys, domestic wastewater facilities include regulated OSDSs, unregulated cesspits, small package
treatment plants, and municipal WWTPs. The inventory of existing sewage treatment/collection facilities is
summarized below.
Facility Type
Approximate
Number
Average Flow
Treated (MGD)
Percent of Florida
Keys Wastewater
Treated
Regulatory
Agency
OSDSs
24,000
6.00
35
FDHRS
Cesspits
5,000
1.25
7
Unpermitted
Small package plants
200*
2.70*
16
FDER
Municipal plants
2
7.00
41
FDER
MGD: million gallons per day
1 Number of package plants and average flow treated will be revised for the final Phase II report based on FDER
comments.
OSDSs: Single family residences and duplexes are commonly served by permitted OSDSs, as are some of the older
motels, campgrounds, and mobile home parks. OSDS designs include conventional septic tank systems, mound
septic tank systems, and aerobic systems. Health officials with the Florida Department of Health and Rehabilitative
Services (FDHRS) indicate that the conventional ancf aerobic OSDS, if properly installed and maintained, provides
adequate treatment levels and does not endanger the health of the general populace. However, both systems achieve
only minimal nutrient reduction through phosphorus absorption and precipitation in the natural soil system. Some
innovative, nutrient-reducing OSDSs are being experimentally tested around the nation, and the engineering options
proposed here include a demonstration project to evaluate several of these systems.
Cesspits: Although numerous in the Keys, cesspits are an unacceptable method for domestic wastewater disposal,
both from public health and environmental health perspectives. Basically, the liquid waste is discharged into an
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unlined excavated pit in which sewage is allowed to collect, digest, and seep into the porous limestone formations
toward outlets typically at shorelines and canals.
Package plants: Package plants ranging in permitted capacity from 0.0008 to 0.45 MGD serve many facilities such
as restaurants, motels, and campgrounds, as well as multiple-family dwellii^ -j (condominium and apartment
buildings). All of these package plants serve site-specific projects and are privately owned, operated, and
maintain^
Municipal plants: The City of Key West uses a 10 MGD capacity central system for collection and treatment of
its wastewater. The Key West plant uses an ocean outfall for effluent disposal. The City of Key Colony Beach
owns and operates the only other municipal WWTP in the Florida Keys, a 0.175 MGD facility.
3.1.2 Population Growth Considerations
Historical growth in the Florida Keys and reliance upon private development have led to a proliferation of small
package treatment plants and a large inventory of individual OSDSs and cesspits. Current wastewater treatment
practices combined with soils in the Keys that have high porosity and low organic content, and high land-use
densities have resulted in increased potential for groundwater and surface water contamination. As described in the
Phase I report, degraded water quality has been documented in confined waters where there are large numbers of
OSDSs and/or cesspits (e.g., canal systems in some residential developments). Although it is suspected that
wastewater nutrients are also affecting nearshore waters (e.g., beyond canal systems), this has not been documented
to the same extent as degradation of confined waters.
If no action is taken to alter current wastewater treatment practices, new developments would continue to use OSDSs
or package plants, and retrofitting would only occur where permit applications for additions or remodeling require
increased system capacity. Elimination of cesspits would remain passive (i.e., initiated by other permit actions or
complaints). Replacement of cesspits with approved OSDSs would continue to occur at a slow rate because of the
inability of FDHRS personnel to access private property for inspections.
An understanding of the historical and projected population growth is an important consideration in evaluating the
engineering and management options to control wastewater discharges. For example, small percentage reductions
in nutrient loadings could eventually be outstripped by population increases. However, projected low population
growth in the Florida Keys suggests that it is appropriate to focus on correcting existing conditions rather than
centering attention on new development.
Historically, from 1970 to 1990, the Florida Keys experienced significant growth in its resident and tourist
population. In 1970, Monroe County had 52,586 permanent residents and by 1990, the number increased to 78,024.
Between 1970 and 1980 the population increased annually by approximately 1,100 yearround residents, and between
1980 to 1990 the annual increase was somewhat higher, approximately 1,500 yearround residents. Of equal
significance to the historic growth trends in the County is the shift of population centers over this time from the
incorporated areas to the unincorporated areas of the County. Because of the County's popularity as a tourist
destination, seasonal population has a significant impact on local facilities and services. The estimated 1990 seasonal
population in Monroe County was 56,643. In 1990, the combined year-round and seasonal population was 134,667
(Solin 1991; Swarthout 1992; Wallace Roberts Sl Todd a al. 1991).
Future growth in the Florida Keys will not reflect this historical trend. As described in the Phase I report, growth
will be dramatically reduced. In Florida, the state land planning agency, the Florida Department of Community .
Affairs (FDCA), is charged with the responsibility of ensuring that all local comprehensive plans are in compliance
with state and regional plans (see Section 163.3161, Florida Statutes (FS) and Rule 9J-5, Florida Administrative
Code (FAQ. It is through the law and administrative code that FDCA and the local governments have reached or
are reaching agreement regarding the future levels of growth for each local government in the Florida Keys. At
this time, the following scenario is expected to be adopted by all local governments. The unincorporated County
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will be able to apf rove only 2,552 equivalent residential units between 1992-2002 resulting in approximately 255
units per year. The three cities will be able to approve 1.146 equivalent units between 1992-2002, or on average
115 units per year. Therefore, new development will be minor when compared to existing development. Most of
the growth is expected to occur as single family homes, built in areas already platted.
If unchecked nutrient loadings cause a downward trend in water quality within the FKNMS, there will be secondary
costs associated with the loss of revenue from tourist-related or other businesses that rely on good water quality.
The economic impacts of potentially deteriorated water quality may be significant, but quantifying the impacts is
difficult. Socioeconomic benefits and costs of all proposed options that are eventually included in NOAA's
management alternatives for the Sanctuary will be analyzed as part of an environmental impact statement for the
management plan.
3.2 ENGINEERING METHODS
Four general issues must be addressed when considering engineering methods for wastewater centralization, type
and level of treatment, effluent disposal, and method of wastewater collection and transmission. These issues are
discussed at length in Appendix B. A brief summary of the first three issues, which are most relevant to the
subsequent discussion, is presented below.
3.2.1	Centralization of Facilities
Centralization of wastewater treatment facilities can range from practically none (the existing condition) to full
centralization using as few as four subregional WWTPs. During development of wastewater collection and treatment
options, three levels of centralization were considered:
•	On-Site Facilities
Continue widespread use of OSDS and package plants.
•	Community Facilities
Construct relatively small WWTPs with service areas limited to single islands or a small number of
islands in close proximity. With this approach, 12 community WWTPs would serve nearly all of the
Keys.
•	Subregional Facilities
Divide the Keys into three subregions, each with its own subregional collection and treatment systems.
The City of Key West WWTP would be the fourth subregional facility.
The decision on centralization of wastewater collection and treatment facilities will largely be dependent on cost.
Generally, as the size of a wastewater service area increases, the cost per gallon for treatment decreases and the
cost per gallon for collection and transmission increases. These differences are apparent in the cost estimates
provided for various engineering options in Section 3.3.
3.2.2	Level and Type of Treatment
There are four general levels of treatment commonly used in engineering practice, as summarized below. Each can
be attained by a variety of processes, as discussed in Appendix B.
•	Primary Treatment
This method involves physical removal of solids by screening and sedimentation. Removal rates of
35-65 % for suspended solids and 30-36 % for organic materials can be attained.
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•	Secondary Treatment
This method uses biological processes in addition to physical processes to attain 80-95% suspended
solids removal and 80-95% orgamcs removal.
•	Irrigation Quality Treatment
This method adds filtration and high-level disinfection to secondary treatment to attain sufficient quality
for irrigation of public access areas.
•	Advanced Wastewater Treatment
This method adds tertiary processes to secondary treatment for removal of constituents not adequately
reduced by secondary treatment. The most common application of AWT is nutrient (nitrogen and
phosphorus) removal.
The level of treatment generally depends on the intended use or disposal method for the treated effluent and there
is a significant increase in cost as the level of treatment is increased. Primary treatment is generally used only for
pre-treatment and under current regulations cannot be considered a complete treatment process. Secondary treatment
is generally adequate when groundwater or deep well disposal is used. However, it may not be adequate for shallow
groundwater disposal in the Keys because of the efficient hydraulic connection between effluent disposal sites and
nearshore surface waters. Irrigation quality treatment is required for irrigation reuse in public access areas. AWT
is used when residual nutrients in secondary-treated effluent present a problem with effluent disposal. AWT is
generally used in connection with surface water discharges or high-quality reuse, such as for potable or process
water.
3.2.3 Effluent Disposal
Six effluent disposal methods were considered in selection of wastewater options:
•	Ocean Outfalls
With this method, the effluent is piped directly to the ocean. This would require a high level of
treatment (AWT) and may still have adverse salinity effects. Cost is relatively high.
•	Class V Injection Wells (Boreholes)
Boreholes are generally 60 to 90 ft deep and cased to 30 to 60 ft. Current FDER rules require a
90-foot depth and a casing to 60 ft. The effluent enters the borehole by gravity (not under pressure)
and flows radially outward through the porous limestone formation. The treatment level should be
AWT to minimize nutrient loadings to nearshore waters. Cost is minimal for boreholes but high for
AWT.
•	Aquifer Storage and Recovery (ASR)
With this method, the effluent is pumped into a shallow, confined aquifer for future withdrawal and
reuse. Wells are generally 500 to 600 ft deep. The treatment level should be irrigation quality or
higher, depending on intended use. Cost is moderate.
•	Deep Injection Wells
These are large diameter wells usually extending 2,500 to 3,000 ft to the boulder zone. The treatment
level can be secondary. Cost is relatively high.
•	Reuse for Irrigation
This method involves irrigation use of effluent on crops, landscape areas, golf courses, or other areas.
The treatment level should be irrigation quality. Cost is moderate to high if the reuse area is close
to the WWTP and very high if long transmission distances are involved.
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• Raise for Potable Water
This method involves reuse of the effluent for drinking water. It would require the AWT level of
wastewater treatment and extensive retreatment at a potable water treatment facility. Cost is very high,
but can be partially offset by revenues generated by the sale of potable water.
3 J ENGINEERING OPTIONS
Engineering and management options for domestic wastewater are summarized in Table 3-4. The options are
divided into three categories:
•	Demonstration Projects
This category includes two projects (Options W1 and W2) to evaluate alternate, nutrient-removing
OSDSs and to evaluate water quality improvements resulting from replacing OSDSs with a small AWT
plant. These projects would be conducted prior to implementing any major, broad-scale engineering
options for wastewater treatment outside the City of Key West.
•	Wastewater Treatment Outside the City of Key West
This category includes Options W3a-W3g, which offer a range of choices for reducing pollution from
domestic wastewater. Areas outside the City of Key West are currently served by OSDSs, cesspits,
and small package plants — there are no central collection or treatment systems currently in place.
•	Effluent Disposal, City of Key West
This category includes four options for upgrading effluent disposal from the City of Key West WWTP.
Currently, the effluent is discharged to surface waters through an ocean outfall.
Appendix C contains detailed descriptions of these options, including the basis for selection, option components,
pollution reduction potential, costs, implementation schedules, affected entities, environmental effects, and alternate
means of wastewater collection or effluent disposal, with associated increases in cost. Costs and nutrient reductions
(excluding the demonstration options) are summarized in Table 3-5.
3.3.1 Demonstration Projects
All of the main engineering options for wastewater involve significant planning and design periods preceding
construction. Therefore, it would be advisable to pursue demonstration projects to increase the body of knowledge
available for ultimate decisionmaking. Two engineering demonstration options are proposed to evaluate the
prospective wastewater treatment processes. One is an in-depth, long-term evaluation of alternate OSDSs with
nutrient removal capability. The other is a performance evaluation of an AWT package plant constructed to serve
a relatively small area with a high density of OSDSs.
3.3.1.1 OPTION W1 — ALTERNATE ON-SITE SEWAGE DISPOSAL SYSTEM DEMONSTRATION
PROJECT
Description: Under this option, three to six alternate OSDSs designed for nutrient removal would be installed and
maintained by contractors in a manner consistent with actual residential installations. Influent, effluent, and
background/downgradient groundwater quality would be monitored at regular intervals for at least one year. The
study would evaluate the long-term nutrient removal capabilities of the various alternate OSDSs in Florida Keys
soils. In addition to nutrient removal efficiency, the study would evaluate maintenance and inspection requirements
to keep units operating properly, and the feasibility of using these systems in widespread application versus using
these systems for isolated areas only.
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Table 3-4. Summary of engineering and management options for domestic wastewater.
Fii|iii .aring Options: Demonstration Projects
•	W1 — Alternate OSOS Dun onst ration Project
Conduct i demonstration project to evaluate the efficacy of
alternate, nutrient-removing OSDS.
•	W2 — AWT DftnonH ration Project
Conduct a demonstration project by installing a small,
expandable AWT plant in Manihon to serve an area of heavy
OSDS use and associated water quality problems.
Engineering Options: Wastewater Treatment Outside Key West
•	W3a — Upgrade Existing Systems to Current Standards
Identify and eliminate all cesspiu. Identify all non-complying
OSDSi and package plants, and retrofit or upgrade to meet
current standards.
•	W3b — Upgrade OSOS* to Curat Standards and
Upgrade Package Plants to AWT
Identify and eliminate all cesspits. Upgrade all OSDSs to meet
current standards and upgrade all package plsms to AWT.
•	W3c — Upgrade OSDS to Alternate. Nutrient-Removing
Systems and Upgrade Package Plants to AWT
Identify snd eliminate all cesspits. Upgrade sll pscksge plants
to AWT and upgrade all OSDSs to alternate, nutnent-removing
systems.
ฐ W3d — Construct Two Community Wastewater Systems
for Marathon and Key Largo and Use Excess Capacity of
Key West Wastewater Treatment Plant in Lower Keys
Construct (wo community wsstewater systems for Marathon
and Key Largo and use excess capacity of the Key West
wastewater treatment plant in adjacent areas of the lower Keys.
Beyond the areas served by these systems, identify sll cesspiu
and non-complying OSDSs snd package plants, and retrofit or
upgrade to meet current standards.
•	W3e — Construct Seres Community Wastewater
Treatment Plants for Most Densely Populated Areas
Construct seven wastewater treatment plants for the most
densely populated areas to treat 73 % of wastewater flows
outside Key West. Beyond the areas served by these systems,
identify all cesspits and non-complying OSDS and package
plants, and retrofit or upgrade to meet current standards.
•	W3f — Construct 12 Community Wastewater Treatment
Plants for All Areas
Construct 12 community wastewater treatment plants to treat
94% of wastewster flows outside Key West. Beyond the areas
served by these systems, identify all cesspits and
non-complying OSDSs and package plants, and upgrade to
AWT or equivalent (e.g., nutnent-removing OSDS)
•	W3g — Construct Three Subregional Wastewater
Treatment Plants
Construct three subregional wastewater treatment plants to treat
94% of wastewster (lows outside Key West. Beyond the sreas
served by these systems, identify all cesspits and
non-complying OSDSs and package plants, and upgrade to
AWT or equivalent (e.g., nutrient-removing OSDS).
Engineering Options: Effluent Dispose' City of Key West
•	W4 — Upgrade Effluent Disposa. ^ity of Key West WWTP
Upgrade effluent disposal for City of Key West plant.
Discontinue use of ocean outfall and implement one of the
following effluent disposal methods:
W4a — Deep well injection
W4b — Reuse for irrigation outside of the Florida Keys
W4c — Reuse for potable water
Management Options
•	W5 — Develop Water Quality Standards
Develop and monitor water quality standards, including
nitrogen and phosphorus standards and biocriteria, for
permitting of waswwater and stormwater discharges.
•	W6 — Delegate NPDES Piugiam to the State of Florida
Delegate adminisumtion of the NPDES program for Florida
Keys dischargers to the State of Florida. This would
streamline the permitting process.
•	W7 — Require Resource Monitoring
Require sll NPDES-permioed surface dischargers to develop
resource monitoring programs. All NPDES dischargers except
the City of Key West sewsge treatment plant are currently
exempt because their discharges occur landward of the baseline
(the mean low tide line).
•	W8 — Establish Permit Fees
Establish permit fees to support the FDER Poini Source
Evaluation Program.
•	W9 — Improve Interagency Coordination
Improve interagency coordination for industrial wastewater
discharge permitting. Reconcile FDER and FDHRS permitting
approaches.
•	W10 — Improve OSDS Permitting
WlOa — Combine OSDS permitting responsibilities for
commercial establishments, institutions, and multi-family
residential establishments in one agency.
WlOb — Review OSDS permit applications from a 'carrying
capacity" perapecuve.
WIOc — Modify current FDHRS policy relative to OSDS
permitting fees by having a percentage of the fees returned
directly to the county in which the fees were collected.
WlOd — Monitor revised OSDS rules.
•	Wll — Establish Interagency Laboratory
Reestablish sn FDHRS-certified (or equivalent) laboratory in
the Florida Keys to process monitoring and compliance
samples.
•	W12 — Increase Wastewater Data Management Capacity
Increase the data management capacity of both the FDER
district snd district branch office levels to reduce lag time in
updating the Groundwater Management System and the
Compliance Enforcement Tracking System databases.
Note: Base option for all wastewater treatment alternatives involving package AWT plants or community/subregionsl AWT plants
includes effluent disposal by Class V injection wells. Upgraded methods of effluent disposal are discussed in Appendix C.
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Table 3-5. Nutrient reductions and cost estimates for wastewater engineering options. [NOTE: Implementation schedules are in Appendix C.J
Option
Wastewater Receiving
Advanced Treatment
<*)
Reduction in
Waitcwater
Nutrient
Loadings
(*)
Fff	Cog
Entire
Kcyi
Outiide
Key West
TN
TP
Inhiil
(S million*)
20 yr O & M
($ million*)
Toul 20 yr
(i millions)
20 yr per
connection
($ UiouMnda)
Coat
Effective-
ness*
TN
TP
OUTSIDE CITY OF KEY WEST*
W3a — Upgrade existing lyalenu to	0
current standard*
W3b — Upgrade OSDSi to current	16
atandardi and upgrade package
planli to AWT
W3c - Upgrade OSDSa to	53
alternate, nutrient-removing *y*tem*
and upgrade package plant* to AWT
W3d — Construct 2 comniunity	73
AWT plant* for Marathon and Key
Largo and uie excess capacity of
Key Wed plant in Lower Key*
W3c — Coiutnict 7 community	S3
AWT plant*
WJf — Construct 12 community	96
AWT plant*
W3g — Construct 3 aubregional	96
AWT" plant*
CITY OF KEY WEST ONLY
(Efllutnt disposal option for
Key West plant)
W4a — Deep well injection	40
W4b — Reuse for irrigation outside	40
the Key*
W4c — fteusc for potoble water1	40
0
27
87
52
73
94
94
10
27
57
43
58
72
72
17
24
43
28
35
43
43
4.7 9.3
4.7 9 3
4.7
9 3
42
56
306
184
265
368
418
7
46
80
0
8
240
105
154
239
272
4.5
31
60
42
64
546
289
419
607
690
12
77
140
1-5
1-5
2 18
12.9
14.8
16.9
19.1
0.44
2.8
5.1
4.2 2.5
2.4 2.7
10	13
6.7	10
7.2	12
8.4	14
9.6	16
2.6 1.3
16 8.3
10 15
JCost effectiveness a total coat/percent reduction in nutrients
All option* for area* outside the City of Key Weal include elimination of all cesspits. For community and (ubregional plant options, *11 non-complying package planta and OSDS* in area*
beyond those served by the proposed AWT plants would be upgraded to current itandard* (Options W3d, W3e) or to AWT or equivalent (Option* W3f, W3g).
'Costs for reuse options assume aquifer storage and recovery is used.

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Rationale: This option would provide information to help decide the appropriate role, if any, for alternate OSDSs
in wastewater management in the Keys. Although some alternate OSDS designs appear promising, it is not
appropriate to proceed with broad-scale installation of these systems until an independent evaluation has been
conducted. Major concerns include cost, nutrient-removal efficiency, and the degree of inspection and maintenance
needed to keep these systems operating properly.
Cost: The cost of the demonstration project is estimated at $105,000 to $210,000, depending on the number of
systems selected ($35,000 for each system including monitoring wells, sampling, and analysis).
Nutrient Reduction: (Not applicable; this is a demonstration project).
3 J. 1.2 OPTION W2 - ADVANCED WASTEWATER TREATMENT DEMONSTRATION PROJECT
Description: Under this option, a small (5,000 to 10,000 gallons per day [GPD]), expandable AWT package plant
would be installed to serve an area of high-density OSDS use in close proximity to semi-confined nearshore waters,
preferably where water quality problems have been identified. Initial background groundwater and surface water
monitoring would be conducted, and plant influent and effluent would then be monitored for a minimum of one year
after the AWT plant is in operation. Surface water and groundwater monitoring would be continued for 3 to 5
years.
Rationale: This option would provide information to help decide whether the replacement of OSDSs with an
advanced wastewater treatment system would improve water quality in areas believed to be degraded by nutrients
from OSDSs. The study would provide information about the effectiveness of nutrient removal on a package plant
scale; short-term or long-term changes in groundwater or surface water quality as a result of discontinuing OSDS
use; and current, site-specific cost information for initial construction and operation/maintenance. Most facilities
constructed for the demonstration project could be incorporated into a larger system (e.g., under Option W3d) if
the results are favorable.
Cost: The cost of the AWT demonstration project is estimated at $350,000 to $700,000, depending on the size of
the system (5,000 to 10,000 GPD), including costs for extensive sampling and analyses.
Nutrient Reduction: (Not applicable; this is a demonstration project).
3.3.2 Wastewater Treatment Outside the-City of Key West
Seven options were developed for wastewater treatment outside the City of Key West. The simplest, minimum
approach (Option W3a) would eliminate cesspits and bring existing OSDSs and package plants to current standards.
Beyond that level, two broad approaches were identified:
•	Use existing systems (OSDSs, package plants), but upgrade the level of nutrient removal.
Under this approach, either package plants (Option W3b) or both package plants and OSDSs
(Optical W3c) would be upgraded beyond current standards to enhance nutrient removal.
•	Construct community or subregional AWT plants and associated collection systems.
Under this approach, either 2 community plants (Option W3d), 7 community plants (Option W3e),
12 community plants (Option W3f), or 3 subregional plants (Option W3g) would be constructed.
These options are presented in order of the increasing percentage of total Florida Keys wastewater
flows that would be treated.
The selection of either approach would be based on the results of the demonstration projects (Options W1 and W2)
as well as other relevant research findings (e.g., estimates for currently unknown external nutrient loadings). If
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the OSDS Demonstration Project identified an inexpensive, effective alternate OSDS, then an appropriate strategy
might be to upgrade all OSDSs to alternate systems and all package plants to AWT (Option W3c).
In contrast, if the OSDS Demonstration Project showed that a suitable alternate OSDS for broad-scale use could
not be identified (e.g., too expensive, too much maintenance and inspection to keep operating properly), then it
would be appropriate to choose one of the options from the second approach (constructing community or subregional
AWT plants). The simplest of the "community plant" options would involve constructing two community plants
(Option W3d), and the next level would involve constructing seven community plants (Option W3e). If either of
these limited options were chosen, then outside the service area for those plants, OSDSs would be upgraded to
current standards. Data from the OSDS Demonstration Project would have indicated that upgrading the remaining
OSDSs further to nutrient-removing OSDSs would not be cost-effective (i.e., to capture the remaining flows, it
would be better to build more AWT plants).
If one of the most extensive "community plant" options were implemented (Option W3f or W3g — 12 community
plants or 3 subregional plants, respectively), nearly all of the wastewater flows would have been captured by these
systems. In that case, it would be feasible to upgrade the remaining OSDSs to alternate, nutrient-removing systems
(even if the systems were known to be not very cost-effective), because the remote OSDSs would never be
connected to a community or subregional AWT plant.
3.3.2.1 OPTION W3a - UPGRADE EXISTING SYSTEMS TO CURRENT STANDARDS
Description: Under this option, all cesspits would be identified and eliminated, and all non-complying OSDSs and
package plants would be upgraded to meet current standards. An aggressive program would be conducted to
identify and eliminate cesspits. The present level of OSDS use would be continued, but all systems would be
brought into compliance with current FDHRS standards. Package plant use would be continued for individual
developments which require them under the current regulations, and all existing package plants would be brought
into compliance with FDER regulations for secondary treatment under 1992 standards.
Rationale: This option is a minimal approach to reducing pollution by bringing existing facilities to current
standards, rather than constructing any new facilities.
Cost: Initial construction costs are estimated at $42 million (Table 3-5). No increase in operating and maintenance
costs is anticipated; therefore, the total 20-year cost is $42 million.
Nutrient Reduction: Nutrient reduction resulting from this option would be limited because of continued
widespread OSDS use. The greatest reduction in nutrient loadings (about 5 % and 10% for nitrogen and phosphorus,
respectively) would be achieved by eliminating and replacing cesspits with approved OSDSs. Smaller additional
reductions would be obtained by upgrading non-complying OSDSs and package plants. Total estimated nutrient
reductions are 10% for total nitrogen and 17% for total phosphorus (Table 3-5).
Cost Effectiveness: This option is among the most cost-effective options (cost/nutrient reduction) (Table 3-5);
however, the total nutrient reduction achieved is low.
3.3.2.2 OPTION W3b - UPGRADE ON-SITE SEWAGE DISPOSAL SYSTEMS TO CURRENT
STANDARDS AND UPGRADE PACKAGE PLANTS TO ADVANCED WASTEWATER
TREATMENT
Description: Under this option, all cesspits would be identified and eliminated, and all non-complying OSDSs
would be upgraded to meet current standards. In addition, the treatment level of the existing and future package
plants would be upgraded to AWT to provide further nutrient removal.
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Rationale: This option would exceed the minimal approach described in Option W3a by upgrading package plants
to AWT. This would be the next logical step because it would further reduce nutrient loadings within the
order of magnitude of total cost.
Cost: Initial construction costs are estimated at S56 million (Table 3*5). Estimated 20-year operating and
maintenance costs are $8 million, for a total 20-year cost of $64 million. Although there would be no construction
of new facilities, retrofitting package plants to AWT would be very expensive for individual plant owners, costing
perhaps as much or more than the existing plants and increasing operating and maintenance costs considerably.
Nutrient Reduction: This option would improve the nutrient reduction obtained in Option W3a by also upgrading
package plants to AWT. Package plants currently handle about 27 % of wastewater flows outside the City of Key
West. AWT would reduce total nitrogen from the 40 mg/L range to less than 6 mg/L and total phosphorus from
about 8 mg/L to less than 4 mg/L. Applying these reductions to 27% of the wastewater flows would reduce total
nitrogen by 17% and total phosphorus by 7%. Adding these reductions to those obtained by upgrading to existing
standards (Option W3a) would yield a total reduction of 27% for nitrogen and 24% for phosphorus (Table 3-5).
Cost Effectiveness: This is the most cost-effective of the options for outside the City of Key West (Table 3-5);
however, overall nutrient reductions would still be low — about one-quarter of the wastewater total nitrogen and
total phosphorus.
3.3.2.3 OPTION W3c - UPGRADE ON-SITE SEWAGE DISPOSAL SYSTEMS TO ALTERNATE,
NUTRIENT-REMOVING SYSTEMS AND UPGRADE PACKAGE PLANTS TO ADVANCED
WASTEWATER TREATMENT
Description: Under this option, all cesspits would be identified and eliminated. In addition, the treatment level
of existing and future package plants would be upgraded to AWT to provide further nutrient removal, and all OSDSs
would be replaced with alternate, nutrient-removing systems.
Rationale: This option would also exceed the minimal approach described in Option W3a by upgrading OSDSs
to alternate, nutrient-removing systems, in addition to upgrading package plants to AWT as in Option W3b. This
is the most comprehensive option involving existing systems rather than the "community plant" approach (Section
3.3.2). In order for this option to be chosen, the OSDS Demonstration Project (Option Wl) would have identified
an efficient, reliable, and cost-effective alternate OSDS for widespread use in the Keys.
Cost: Initial construction costs are estimated at $306 million (Table 3-5). Estimated 20-year operating and
maintenance costs are $240 million, for a total 20-year cost of $546 million. Most of the construction costs and
nearly all of the operating and maintenance costs are because of OSDS upgrading rather than package plant
upgrading or cesspit elimination. However, the OSDS costs are tentative and would have to be reevaluated
following the OSDS Demonstration Project (Option Wl).
Nutrient Reduction: This option would improve the nutrient reduction obtained in Option W3a by also upgrading
package plants to AWT and OSDSs to alternate, nutrient-removing systems. Estimated reductions are 57 % for total
nitrogen and 43 % for total phosphorus (Table 3-5). These are the highest nutrient reduction percentages achieved
without going to the "community plant" approach.
Cost Effectiveness: The nutrient reductions are achieved at a very high cost, making this one of the least
cost-effective options (Table 3-5).
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3J.2.4 OPTION W3d - CONSTRUCT TWO COMMUNITY WASTEWATER SYSTEMS FOR
MARATHON AND KEY LARGO AND USE EXCESS CAPACITY OF KEY WEST WASTEWATER
TREATMENT PLANT IN LOWER KEYS
Description: This option would involve constructing two community wastewater systems to provide AWT for
Marathon and Key Largo. Boreholes would be used for effluent disposal from these plants. In the lower Keys,
a community wastewater collection system would be constructed to serve all areas between the City of Key West
WWTP service area and the east end of Big Coppitt Key. This wastewater flow would be conveyed to the City of
Key West WWTP. Beyond the areas served by these systems, all cesspits would be eliminated and all
non-complying OSDSs and package plants would be upgraded to meet current standards.
Rationale: Extending the service area for the City of Key West WWTP as far east as practical, coupled with
construction of community AWT systems for the two most populous communities in the upper and middle Keys
would provide central sewer service for about 73% of all Florida Keys wastewater flows and 52% of the flows
outside the City of Key West. Extension of the service area for the City of Key West WWTP is logical because
the plant is expected to increase its excess capacity to 1.9 MCD by 2010 as a result of reducing infiltration and
inflow (I/I). Outside the service area for these systems, upgrading the remaining OSDSs to existing standards
(rather than to alternate, nutrient-removing systems) would be logical because the selection of this option (W3d)
would mean that a cost-effective alternate OSDS had not been identified — i.e., to upgrade the remaining OSDSs,
it would be more cost-effective to build more AWT plants (as in Options W3e-g).
Cost: Initial construction costs are estimated at SI84 million (Table 3-5). Estimated 20-year operating and
maintenance costs are $105 million, for a total 20-year cost of $289 i illion.
Nutrient Reduction: For the 3.6 MGD combined flow of the Marathc a and Key Largo communities, the treatment
level would be upgraded from virtually no treatment (cesspits), OSD,'. treatment, or secondary treatment (package
plants) to AWT. Total nitrogen in these waste streams would be red. :ed from the 30-70 mg/L range to less than
6 mg/L, and total phosphorus from the 8-24 mg/L range to less ths. 4 mg/L. Estimated nutrient reductions are
43% for total nitrogen and 28% for total phosphorus (Table 3-5).
Cost Effectiveness: This option is the most cost-effective (in terms f nutrient reduction) of the options involving
community WWTPs (Table 3-5). Based on the existing data, it is a o more cost-effective than upgrading OSDSs
to alternate, nutrient-removing systems (as in Option W3c). Althou a this option is less cost-effective than the first
two minimal upgrade options (W3a and W3b), it would result in substantially greater nutrient reduction.
3.3.2.5 OPTION W3e - CONSTRUCT SEVEN COMMUNITY WASTEWATER TREATMENT PLANTS
FOR MOST DENSELY POPULATED AREAS
Description: This option would involve the construction of seven community WWTPs for the Key Largo,
Marathon, Stock Island to Key Haven, Plantation, Boca Chica, Big Pine, and Cudjoe/Summerland areas. These
seven WWTPs would accommodate about 73 % of the wastewater flows from the Keys areas, excluding the City
of Key West. Boreholes would be used for effluent disposal from these WWTPs. Beyond the areas served by these
systems, ail cesspits would be eliminated, and all non-complying OSDSs and package plants would be upgraded to
meet current standards.
Rationale: The service areas for the seven WWTPs were selected by starting with the highest flow ranking
(excluding the City of Key West) and adding areas with successively lower rankings until accounting for at least
70% of the flow. Outside the service area for these systems, upgrading the remaining OSDSs to existing standards
(rather than to alternate, nutrient-removing systems) would be logical because selection of this option (W3d) would
mean that a cost-effective alternate OSDS had not been identified — i.e., to upgrade the remaining OSDS. it would
be more cost-effective to build more AWT plants (as in Option W3f or W3g).
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Cost: Initial construction costs are estimated at $265 million (Table 3-5). Estimated 20-year operating and
maintenance costs are $154 milliun, for a total 20-year cost of $419 million.
Nutrient Reduction: For the 73% of wastewater flows connected, treatment level would be upgraded from
virtually no treatment (cesspits), OSDS treatment, or secondary treatment (package plants) to AWT. Total nitrogen
in these waste streams would be reduced from the 30-70 mg/L range to less than 6 mg/L, and total phosphorus from
the 8-24 mg/L range to less than 4 mg/L. Estimated nutrient reductions are 58% for total nitrogen and 35% for
total phosphorus (Table 3-5).
Cost Effectiveness: This option is in the middle in terms of cost-effectiveness among the "community plant"
options (W3d-g) (Table 3-5). Based on the existing data, it is also more cost-effective than upgrading OSDSs to
alternate, nutrient-removing systems (as in Option W3c), while producing comparable nutrient reduction.
3.3.2.6	OPTION W3f - CONSTRUCT 12 COMMUNITY WASTEWATER TREATMENT PLANTS FOR
ALL AREAS
Description: This option would involve constructing 12 AWT plants to serve nearly all (94%) of the wastewater
flows outside the City of Key West. Boreholes would be used for effluent disposal from these systems. Beyond
the areas served by these systems, all cesspits would be eliminated, all package plants would be upgraded to AWT,
and all OSDSs would be upgraded to alternate, nutnent-removing systems.
Rationale: This option represents the maximum use of community WWTPs in the Florida Keys, capturing about
94% of the wastewater flows. Essentially, OSDSs and package plants would continue to be used only in low-density
or remote areas. Because these remaining OSDSs and package plants would presumably never be connected to a
community treatment system, this option would require that they be upgraded to AWT or its equivalent (e.g.,
alternate, nutrient-removing OSDSs).
Cost: Initial construction costs are estimated at $368 million (Table 3-5). Estimated 20-year operating and
maintenance costs are $239 million, for a total 20-year cost of $607 million.
Nutrient Reduction: For the 94% of wastewater flows connected, treatment level would be upgraded from
virtually no treatment (cesspits), OSDS treatment, or secondary treatment (package plants) to AWT. Total nitrogen
in these waste streams would be reduced from the 30-70 mg/L range to less than 6 mg/L, and total phosphorus from
the 8-24 mg/L range to less than 4 mg/L. Estimated nutrient reductions are 72% for total nitrogen and 43% for
total phosphorus (Table 3-5).
Cost Effectiveness: This option and Option W3g provide the highest percentage of reductions in total nitrogen and
total phosphorus loadings, but at the highest cost. They are among the least cost-effective options (Table 3-5).
3.3.2.7	OPTION W3g — CONSTRUCT THREE SUBREGIONAL WASTEWATER TREATMENT PLANTS
Description: This option would involve constructing three subregional AWT plants to serve nearly all (94%) of
the wastewater flows outside the City of Key West. Boreholes would be used for effluent disposal from these
systems. Beyond the areas served by these systems, all cesspits would be eliminated, all package plants would be
upgraded to AWT, and all OSDSs would be upgraded to alternate, nutrient-removing systems.
Rationale: This option is similar to Option W3f, except that three large, subregional WWTPs would be used rather
than 12 smaller, community WWTPs. Selection of 3 subregional WWTPs rather than 12 community WWTPs might
be appropriate, for example, if it would be difficult to find suitable locations for 12 community WWTPs. Like
Option W3f, this option represents the maximum use of community WWTPs in the Florida Keys, capturing about
94% of the wastewater flows. Essentially, OSDSs and package plants would continued to be used only in
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low-density or remote areas. Because these remaining OSDSs and package plants would presumably never be
connected to a community treatment system, the option would require that they be upgraded to AWT or its
equivalent (e.g., alternate, nutrient-removing OSDSs).
Cost: Initial construction costs are estimated at $418 million (Table 3-5). Estimated 20-year operating and
maintenance costs are $272 million, for a total 20-year cost of $690 million.
Nutrient Reduction: The estimated nutrient reductions are identical to those for Option W3f; 72% for total
nitrogen and 43 % for total phosphorus (Table 3-5).
Cost Effectiveness: This option and Option W3f provide the highest percentage reductions in total nitrogen and
total phosphorus loadings, but at the highest cost. They are among the least cost-effective options (Table 3-5).
3.3.3 Effluent Disposal for the City of Key West
The City of Key West WWTP has excess capacity through the year 2010 and currently serves about 95% of the
wastewater flows generated within the City. Deficiencies in the system include high 1/1 into the collection system
and use of a nearshore ocean outfall that is not in compliance with current regulations. The City of Key West has
taken steps to correct both of these deficiencies. An I/I reduction program is in progress and the City's consultant
is examining deep well injection as a primary effluent disposal method.
During the assessment of potential engineering options for the City of Key West, it was assumed that long-term
use of the existing nearshore ocean outfall was not a viable option. Factors contributing to this assumption were
the discharge's close proximity to shore, the fact that the outfall does not come close to meeting current regulations
for ocean outfalls, the sensitive marine environment into which it is discharging, and the pressure from regulatory
agencies to cease the discharge. Reconstruction of the ocean outfall to meet current requirements was excluded from
consideration because it would be more costly than the other alternatives and obtaining permits would be difficult.
3.3.3.1 OPTION W4 - UPGRADE EFFLUENT DISPOSAL FOR THE CITY OF KEY WEST
WASTEWATER TREATMENT PLANT
Description: This option would upgrade effluent disposal for the City of Key West WWTP. Use of the ocean
outfall would be discontinued, and one of the following effluent disposal methods would be implemented:
•	Option W4a — deep well injection
•	Option W4b — reuse for irrigation outside the Keys
•	Option W4c — reuse for potable water
With any of these options, the existing ocean outfall would be used as an emergency, short-term disposal method.
Local reuse for irrigation would be included to the extent practical with each of these options, but because of the
limited number of application sites, it would accommodate only a small fraction of the total effluent.
Rationale: This option would reduce direct nutrient loadings to surface waters from the City of Key West WWTP.
Cost: Estimated construction costs range from $7 million to $80 million, depending on the effluent disposal method
chosen (Table 3-5). Operating and maintenance costs similarly range from $4.5 million to $60 million, and total
costs range from $12 million to $140 million. Deep well injection (Option W4a) is the least expensive effluent
disposal option, whereas reuse for irrigation (Option W4b) and reuse for potable water (Option W4c) are the most
expensive.
Nutrient Reduction: The estimated nutrient reductions (percentage of total Florida Keys wastewater nutrients) are
about 5% for total nitrogen and 9% for total phosphorus (Table 3-5).
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Cost Effectiveness: Deep well injection (Option W4a) is the most cost-effective disposal option, whereas reuse for
irrigation (Option W4b) and reuse for potable water (Option W4c) are not very cost-effective options (Table 3-5).
If revenues generated by the sale of potable water and lower pumping costs of using locally treated water were
considered, the cost-effectiveness of reuse for potable water would increase significantly. Potable reuse is also
attractive with respect to water conservation. However, in terms of overall reduction in wastewater nutrients, none
of the options would produce a substantial decrease in loadings.
3.4 MANAGEMENT OPTIONS
Three agencies have significant roles in wastewater permitting activities in the Florida Keys: EPA, FDER, and
FDHRS. EPA's responsibility is limited solely to surface water dischargers through the NPDES program There
are only 10 domestic wastewater plants still actively functioning. At this time, owners of these facilities must
receive an operating permit from both EPA and the FDER. Coordination of permit and compliance activities
between the two agencies occurs; however, the EPA permit is good for 5 years and the FDER permit approvals last
3 years. As a result of this complexity, owners are continually involved in the permitting process. Currently, the
state is trying to have the NPDES program delegated to FDER. If this is accomplished a duplication in the
permitting process can be eliminated.
FDER permits all WWTPs in the Florida Keys. The FDER has a Subdistnct office in Marathon which is primarily
responsible for compliance and enforcement activities. Until recently, the office operated a FDHRS-certified
laboratory; however, certification has lapsed and has jeopardized the enforcement and compliance abilities of the
local staff.
Eight management options were developed for domestic wastewater. These are summarized briefly in Table 3-4
and discussed individually below.
3.4.1 Option W5 — Develop Water Quality Standards
Description: Under this option, the FDER and EPA would work jointly to develop and monitor water quality
standards, including nitrogen and phosphorus standards and biocriteria, for the permitting of wastewater and
storm water discharges.
Rationale: The objective of regulating wastewater and stormwater discharges is to protect and preserve the marine
resources of the Sanctuary. Nutrients, particularly nitrogen and phosphorus, are suspected as the major contributors
to eutrophication of nearshore and confined waters in the Sanctuary. Water quality standards for nitrogen and
phosphorus should be adopted, based on the recognition that minor fluctuations in nutrients in Sanctuary coastal
waters may have a greater impact on water quality and marine resources than in most other coastal areas in Florida.
Biocriteria are "numerical values or narrative expressions that describe the reference biological integrity of aquatic
communities inhabiting waters of a given designated life use" (EPA 1990). Biocriteria are valuable because they
directly measure the condition of the resource at risk, detect problems that other methods (e.g., chemical analyses
of water quality) may miss or underestimate, and provide a systematic process for measuring progress resulting from
the implementation of water quality programs (EPA 1990). EPA is directing states to adopt narrative biological
criteria into state water quality standards over the next few years.
EPA, through its Ocean Discharge Program, has developed monitoring programs to determine the effects of sewage
discharges in the marine environment. Monitoring data provide information to determine the nature and extent of
the effects of sewage effluents on marine habitats and communities. The FDER Stormwater Management Division
has been studying methods, including biomonitoring, to monitor and assess the impacts of nonpoint sources. It has
long been known that resident biota in a water body are capable of detecting the effects of both episodic as well as
cumulative pollution and habitat alteration. While the Ocean Discharge Program deals with wastewater and the
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FDER bioassessment p' ogram concerns stormwater, the two approaches seem to provide the regulatory agencies
with a valuable tool to <ปซซ< the health of marine resource habitats.
Responsible Agency: The responsibility for implementing this option would be split. The bioassessment effort
should be an EPA responsibility. However, any change to the state's water quality standards will have to be
initiated by the FDER.
Implementation Mechanism: EPA annually funds the state of Florida Section 319(h) grants of the Clean Water
Act. A portion of the Section 319(h) funds should be allocated to cover staff time used for coordination between
the FDER and EPA bioassessment work efforts. Annual joint status reports describing the bioassessment work
efforts of the previous year by both the EPA and FDER should be prepared.
Implementation Requirements: Several actions are necessary to implement this option. First, the EPA and FDER
should coordinate their efforts with respect to their ongoing studies regarding resource-based standards (biocntena),
in an effort to avoid duplication and maximize the return on public investment. As part of the effort, new
information and knowledge should be disseminated through published reports and studies, as well as the annual
status report. Proposed research on indicators in the Research Program (Task 7) will provide additional data for
development of biocriteria.
Second, research will need to be conducted to establish water quality standards for nitrogen and phosphorus as
appropriate for the FKNMS. The research could become a part of the resource-based studies or could be
accomplished in an independent study. The inclusion of "no-take" zones should be considered in the study design.
These zones would provide reference areas for biomonitoring and assist in the development and implementation of
FDER's biological criteria. If performed independently, the study should evaluate the impacts on marine resources
by changes in water quality standards. If a conclusion is reached that water quality standards for the FKNMS need
to be revised or modified, the FDER will initiate formal rule-making in accordance with Chapter 120 FS —
Administrative Procedures Act. Once enacted, the new standards would be implemented at the time new permits
were being issued or existing permits reissued.
This rule change would not increase the need for additional staff. The monitoring costs would still be the
responsibility of the permittee; however, these costs would be somewhat higher because of the additional parameters
being monitored. Prior to the date the rule change would go into effect, the FDER would conduct a workshop for
its permitting and enforcement staff so that all staff understand the rule and are able to clearly explain it to
applicants and permittees.
3.4.2 Option VV6 — Delegate National Pollutant Discharge Elimination System Program to
the State of Florida
Description: This option would result in EPA delegating the NPDES program to the state of Florida.
Rationale: Currently, all surface water discharges must receive permits from both the EPA and FDER. In many
states where EPA has delegated NPDES authority, the duplicative permit approval process does not exist (as it does
in Florida). By becoming a delegated state, Florida would be able to streamline and eliminate unnecessary
duplication in the permitting process.
Responsible Agency: The responsible agency would be EPA.
Implementation Mechanism: The EPA and FDER should enter into an MOU that describes the roles and
responsibilities of each agency, and the standards of review (e.g., water quality criteria) that nftist be met by each
NPDES applicant.
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Implementation Requirements: EPA will need to approve Florida's NPDES application that outli-ies how the state
will implement the program. At this time, the application is being prepared by the FDER Bureau of Wastewater
Facilities Regulation.
Once Florida is a delegated NPDES state, there should be no major increase in staffing because Florida already
reviews all NPDES permits under the Clean Water Act 401 certification process. Shifting from a non-delegated
state to a delegated state should have no change on district and distnct branch office operations. Because of the shift
of responsibilities from federal to state, there may be some administrative changes; however, that will occur at the
FDER headquarters and EPA Region IV levels.
3.4.3 Option YV7 — Require Resource Monitoring
Description: Under this option, all NPDES-permitted surface water dischargers would be required to develop
resource monitoring programs.
Rationale: The NPDES permitting program for surface dischargers focuses on impacts on the water quality
standards set out in each NPDES permit. However, in the Florida Keys, where biological communities are highly
sensitive to changes in nitrogen and phosphorus levels, a resource-based monitoring approach may be more
appropriate. EPA's Ocean Discharge Program uses such a resource-based monitoring approach. However, the
Ocean Discharge Program only applies to those areas where surface discharges occur into oceanic waters, defined
as waters seaward of the "baseline" (mean low tide mark). This exempts all surface dischargers in the Flonda Keys
with the exception of the City of Key West WWTP. Requiring all surface dischargers to conduct resource
monitoring would provide additional protection of Sanctuary water quality and resources.
Responsible Agency: The responsible agencies would be EPA and FDER.
Implementation Mechanism: The goal of this option could be accomplished in one of two ways. One way would
be for EPA to eliminate the baseline exemption for resource monitoring under the Ocean Discharge Program, as
it applies to the Florida Keys. This would require a rule change in 40 CFR 125. A second way to accomplish the
same goal would be for FDER, through the state of Florida's permitting authority, to require resource monitoring
when individual NPDES permits come up for renewal. This approach probably would be easier because it could
be accomplished under existing rules.
Implementation Requirements: Implementation of this option would involve adding at least one or possibly two
EPA staff to develop a resource monitoring program for all the surface water dischargers remaining in the Flonda
Keys. The most significant costs would be associated with the ongoing monitoring programs. These costs would
be in addition to those already associated with meeting existing water quality monitoring programs as required by
NPDES permits.
3.4.4 Option W8 — Establish Permit Fees
Description: This option would establish permit fees to underwrite the administrative costs of the FDER Point
Source Evaluation Program. Staff involved with this program would conduct water quality-based effluent limitation
(WQBEL) modeling for proposed surface water discharges as compared to the present practice of applicants having
their engineering consultants undertake such modeling efforts.
Rationale: Currently, applicants provide the data' needed to set WQBEL standards for inclusion in wastewater
discharge permits to the FDER Point Source Evaluation Section. However, based on past performance, the FDER
staff would rather collect the data and conduct the water quality modeling themselves. These proposed permit fees
would assist in defraying staff costs and this method would facilitate the permitting process.
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Responsible Agency: The responsible agency should le the FDER.
Implementation Mechanism: The implementation mechanism is Chapter 17-650 FAC — Water Quality Based
Effluent Limitations.
Implementation Requirements: The FDER Point Source Evaluation Section would need to undertake a study
documenting what the agency's costs would be if FDER staff assumed responsibility for conducting WQBEL
modeling. The applicant would continue to collect the data necessary for the modeling as is currently the case, and
once the study is completed, the FDER would need to initiate formal rule-making in accordance with Chapter 120
FS — Florida Administrative Procedures Act. The FDER would modify the existing WQBEL administrative rule
set out in Chapter 17-650 FAC. Besides permit fees, the modified rule would need to describe the new procedures
and responsibilities of both the FDER and the applicant.
The need for staffing increases is unknown at this time; however, the study described above would address this
issue. The FDE& staff already conducts some WQBEL modeling in instance* where the FDER finds an applicant's
work unacceptable. If this option is implemented, technical training sessions should be incorporated into the Point
Source Evaluation Program.
3.4.5 Option W9 — Improve Interagency Coordination
Description This option would improve the interagency coordination process for industrial wastewater discharge
permitting.
Rationale: Coordination between the EPA and FDER needs improvement relative to industrial wastewater
discharge permitting and tracking. FDHRS would also be included for special cases such as seafood processing
plants discharging to septic systems.
Responsible Agency: The FDER, through the Intergovernmental Coordinating Council, needs to be the responsible
agency for implementing this option. Other agencies involved are the EPA, FDHRS, and the South Florida Water
Management District (SFWMD).
Implementation Mechanism: At present, much of the interagency coordination and tracking for permitted
industrial wastewater discharges are handled through a series of Memorandums of Agreement (MOA) and MOUs.
These agreements need to be reviewed, evaluated, and revised specifically with respect to the Florida Keys.
Centralization of the collection and tracking of monitoring data is particularly important in relationship to other
water quality and monitoring programs being planned within the FKNMS.
Implementation Requirements: No new rules or governmental structures are required to implement this option.
Based on the results of the FDER and Intergovernmental Coordinating Council review of the existing MOAs and
MOUs, these interagency agreements may need to be revised and updated specifically for the FKNMS area. The
data tracking and data management aspects of this program need to be centralized within the framework of the other
monitoring and management programs related to the FKNMS.
3.4.6 Option Wlu — improve un-site Sewage Disposal System Permitting
Based on information derived from the earlier program survey questionnaires and personal interviews with FDER
and FDHRS staff, it became apparent that a series of management strategies, either treated separately or combined
into an options package, could enhance the OSDS permitting program in the Florida Keys. .The four parts of this
option package are described below.
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3.4.6.1 OPTION WlOa — COMBINE ON-SITE SEWAGE DISPOSAL SYSTEM PERMITTING
RESPONSIBILITIES
Description: This option would combine the FDER and FDHRS wastewater permitting responsibilities for
commercial establishments, institutions, and multi-family residential establishment;' into one agency.
Rationale: Under current regulations, there is a gap in the OSDS regulatory/permitting process as it pertains to
aerobic wastewater treatment units. The Monroe County Public Health Unit is authorized to permit the aerobic
treatment unit, the filter unit, and the underground injection well (commonly called the borehole) for residential
units. For commercial establishments, institutions, and multi-family residential uses having total daily flows of no
more than 5,000 gallons, the Monroe County Public Health Unit has permit authority for the aerobic treatment unit
and the filter unit. The FDER permits the borehole for such facilities.
The effluent from aerobic systems permitted by the FDHRS does not meet the more stringent wastewater treatment
standards defined for secondary treatment facilities permitted by the FDER. The aerobic units meet the nationally
accepted wastewater quality standards set by the National Sanitation Foundation (a not-for-profit research, education,
and service organization that develops standards and criteria for equipment, products, and services that relate to
health).
Responsible Agency: The responsible agency would be the FDER.
Implementation Mechanism: The FDER and FDHRS need to enter into a MOU that delineates the roles and
responsibilities of each agency regarding OSDSs.
Implementation Requirements: The FDER and FDHRS would need to agree on the same requirements regarding
levels of treatment for existing and new or innovative OSDS units to be permitted in the Florida Keys. Once an
agreement is reached, the administrative rules regarding the quality of wastewater being discharged into underground
injection wells should be amended.
3.4.6.2 OPTION WlOb — REVIEW ON-SITE SEWAGE DISPOSAL SYSTEM PERMIT APPLICATIONS
FROM A "CARRYING CAPACITY" PERSPECTIVE
Description: Under this option, OSDS permit applications would be reviewed from a cumulative "carrying
capacity" perspective.
Rationale: In the Florida Keys there are an estimated 24,000 permitted OSDSs and 5,000 cesspits. Although one
OSDS may not have a dramatic impact on nearshore and confined waters, where there are concentrations of OSDSs,
a cumulative adverse impact on the adjoining water has been documented. If new OSDS units are continued to be
permitted, it should be based on some type of carrying capacity criteria that reflects the unique situation present in
the Florida Keys.
Responsible Agency: The FDCA currently has the commitment of funds for a federal research grant to undertake
a program that will address this option (T. Livingston, FDCA, personal communication, 1992). Monroe County
will soon have the OSDS database in a Geographic Information System (G1S) format that will allow review of OSDS
density patterns throughout the Florida Keys.
Implementation Mechanism: The first step in implementing this option is the development of an MOU between
the FDCA, FDHRS, and Monroe County for a joint research effort to assess the problems caused by high densities
of OSDSs at a specific site in the Florida Keys.
Implementation Requirements: As soon as the FDCA has the required funding available, it should begin work
with the Monroe County Health Department and FDHRS to select and implement the program.'
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3.4.6.3 OPTION WlOc - MODIFY ON-SITE SEWAGE DISPOSAL SYSTEM PERMIT FEES
This option has been deleted because administrative procedures have recently been changed to assure that OSDS
permitting fees that are collected by the Monroe County Public Health Unit are used to underwrite the costs of
enforcement and compliance activities of the Environmental Health Division.
Description: This option would modify the current FDHRS policy, relative to OSDS permitting fees, by having
a percentage of the fees returned directly to the county in which the fees were collected. This would provide local
public health units with some additional funding to increase enforcement and compliance activities.
3.4.6.4 OPTION WlOd - MONITOR REVISED ON-SITE SEWAGE DISPOSAL SYSTEM RULES
Description: This option would involve designing and implementing a monitoring program to determine the
effectiveness of recent revisions in Part II of Chapter 10D-6 FAC.
Rationale: Permitting standards for OSDSs have been changed in the past year. Data are needed to evaluate
whether these changes are achieving their desired effect. The two key rule changes specifically targeted to the
Flonda Keys include making the use of underground injection wells (boreholes) an option of last resort and requiring
placement of a minimum 12-in.-thick filter layer of quartz sand below the drainfield absorption surface of the
OSDS.
Responsible Agency: The responsible agency would be the FDHRS.
Implementation Mechanism: The implementation mechanism is the FDHRS budget. Specific funds in the FDHRS
budget should be earmarked to allow the Environmental Administrator of the State Health Office to implement the
suggested option.
Implementation Requirements: Under the supervision of the Environmental Administrator of the State Health
Office, a comparative study should be made that determines whether or not the rule modifications make a significant
difference. The study will require the identification of participants (homeowners) willing to allow their OSDS to
be a part of the study. Possibly, incentives might be awarded to those who participate. Because the study will need
to be conducted in the Florida Keys, and because the environmental health section of the Monroe County Public
Health Unit is understaffed to carry out its present mandates, an additional staff position should be created and
funded (possibly through special grant funds) to implement the research study.
3.4.7 Option Wll — Establish Interagency Laboratory
Description: Under this option, an interagency laboratory would be established in the Florida Keys with the
capability of processing compliance monitoring samples. The laboratory would be certified by FDHRS and/or the
quality assurance (QA) section of the FDER. The new state office building in Marathon has space allocated for
such facilities.
Rationale: The FDER Marathon District Branch Office and district laboratories are no longer FDHRS-certified.
All water quality samples taken by the FDER staff are sent for analysis to the FDER's only FDHRS-certified
laboratory located in Tallahassee. Because of the distance between Tallahassee and the Florida Keys, it routinely
takes longer than 24 h for samples to reach the Tallahassee laboratory. For laboratory analyses to be valid, they
must adhere to FDHRS-certified quality assurance/quality control (QA/QQ protocols. Certain water quality
parameters, such as fecal coliform and biological oxygen demand (BOD), must be analyzed within 24 h from the
time of sample collection according to FDHRS-certified QA/QC protocols. If these protocols are not followed, the
results of the tests can be jeopardized. Because there is no other governmental entity that operates FDHRS-certified
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laboratories in the Florida Keys, the only option, other than sending the samples to Tallahassee and hoping they
arrive in time to be tested according to QA/QC protocols, is to send the samples to a private laboratory in Miami
— an expensive alternative.
Further, the FDHRS Monroe County Public Health Unit has needs similar to those of the FDER, and it too has no
laboratory facilities within the Florida Keys. However, the FDER District Branch Office will be moving into the
new state office center that is currently under construction in Marathon and space within the new FDER District
Branch Office has been allocated for a laboratory. With funds being scarce, the FDER and FDHRS should consider
jointly funding a publicly-operated, FDHRS-certified (or equivalent) laboratory in the FDER offices in Marathon.
Responsible Agency: The responsible agency should be the FDER.
Implementation Mechanism: The implementation mechanism is the state budgetary process. If the facility is
operated jointly by the FDER and FDHRS, a MOU should be developed that defines the roles, technical
responsibilities, and method of cost sharing.
Implementation Requirements: The first and foremost implementation requirement is to have the FDER
laboratory re-certified according to FDHRS requirements. In terms of staffing, at a minimum, one qualified
technician needs to be hired. Additional staff would be added as demand warrants. In addition, some upgrading
of existing equipment will be necessary to ensure a quality field monitoring program.
3.4.8 Option W12 — Increase Wastewater Data Management Capacity
Description: This option would increase the data management capacity of both the FDER district and distnct
branch office levels to reduce lag time in updating the Groundwater Management System (GMS) and the Compliance
Enforcement Tracking System (CETS) databases.
Rationale: At present, the state's databases can be quit? out of date. This situation results primarily from the lack
of staff — more staff are needed to continually update - ad QC the databases. In addition, some type of enhanced
interaction among agency branches needs to be establis .ed to ensure all critical data are available and reviewed in
connection with new permit requests.
Responsible Agency: The responsible agency should )e the FDER.
Implementation Mechanism: This option does not rquire the creation of a new program, but it will expand the
department's existing data management capacity. Therefore, the implementation mechanism is the FDER budget.
Implementation Requirements: Based on interviews with FDER staff at district and district branch offices,
creating a new staff position at each office would enable data to be integrated more quickly into the two databases.
The district branch office is in need of a technical support position. One of the primary duties of this position would
be to assist in computer data entry and maintenance/updating of compliance tracking systems. A similar need exists
for the distnct office.
The Marathon Distnct Branch Office has only a rudimentary computer capability. At present, the office has one
word processing computer and is understaffed in terms of inspectors. By providing better computer facilities, the
limited staff would be able to work more efficiently and respond more quickly to resident's needs whether they be
complaints or requests for information about the FDER programs.
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3.5 INSTITUTIONAL OPTIONS
Most of the management options discussed in Section 3.4 are regulatory; they describe ways that existing i juiatory
agencies can improve the permitting, compliance, and enforcement activities. However, most of the proposed
engineering options will require an institutional nwKaniซm for implementation.
3.5.1 Existing Institutional Framework
Two local governments operate wastewater treatment facilities: the City of Key West and the City of Key Colony
Beach. The City of Key West operates the largest facility whose service area is limited primarily to the City;
however, if the City is able to correct the serious groundwater infiltration problem, the excess capacity could serve
much of the Lower Keys. For the City of Key Colony Beach facility, like the City of Key West facility, the service
area is limited to the City; however, because of the plant's small capacity, it cannot be expected to serve much more
than its own population. The other 207 wastewater package plants are owned and operated by individuals or
homeowner associations. Individual septic systems are handled differently. Throughout the Florida Keys, OSDSs
are permitted by the FDHRS Monroe County Public Health Unit.
The Florida Keys Aqueduct Authority (FKAA) has the legislative authority to provide wastewater treatment;
however, it has not exercised this portion of its legislative mandate. The FKAA provides potable water to the
Florida Keys.
Three institutional options are recommended for consideration. To implement either the community or regional
wastewater options effectively, a more centralized approach is desirable. The options outlined enable control to
remain local and, therefore, closer to the people the utility serves. We believe this encourages entities to be more
sensitive to its users. Consolidation also can achieve economies of scale, both in terms of maintenance as well as
administrative support.
3.5.2 Options
The following range of institutional options can be used to manage domestic wastewater treatment.
3.5.2.1 FLORIDA KEYS AQUEDUCT AUTHORITY
Description: Under this option, the FKAA would manage, operate, and maintain all wastewater treatment facilities
in the Florida Keys. OSDSs would still remain under FDHRS jurisdiction.
Rationale: The FKAA is the only existing governmental entity within the Florida Keys that has the statutory
authority to manage and/or provide central wastewater collection and treatment service to both the incorporated and
unincorporated areas of Monroe County.
Responsible Agency: The responsible agency would be the FKAA.
Implementation Mechanism: Although the FKAA has the legislative authority to operate centralized wastewater
treatment systems in the Florida Keys, it will not initiate action to become such a provider. To commence the
process will require that one of two actions be undertaken. Either local governments within the Florida Keys would
approach and petition the FKAA to become the wastewater provider to areas within their jurisdiction, or the Florida
Governor would direct the FKAA to initiate actions which would result in the FKAA assuming total responsibility
for the development and operation of neighborhood collection and treatment systems. Prior to local governments
approaching the FKAA, they could seek to place a referendum on the ballot to acquire a general sense of whether
or not this option is viable in the minds of the Florida Keys residents. This type of effort would also require a
well-devised public outreach effort.
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Imple nentation Requirements: A wastewater master plan that identifies operational standards and procedures for
package plants, collection systems, pump stations, and disposal wells needs to be developed. The plan would
include other operational aspects such as staffing needs, facilities maintenance strategy, interagency coordination
(e.g., involvement in the local government's site development review process), and billing procedures.
The FKAA would have to hire several technical staff to oversee the development and daily operation of the
wastewater treatment facilities and collection systems. Because the implementation of the various engineering
wastewater options would take place over a period of years, the hiring of staff would follow a similar pattern. For
each new wastewater facility, the FKAA would need to hire a treatment facility supervisor, two FDER-trained
operators, and a collection and distribution supervisor with a lift station mechanic. Because the FKAA has been
providing potable water to the Florida Keys residents for years, staff is already in place that could reduce start-up
costs. The FKAA has a director, a communications system, a billing and collection staff, as well as individuals
trained in vehicle and equipment repair.
3.5J.2 COUNTY WASTEWATER UTILITY - ADMINISTRATIVE AND OPERATIONAL
Description: Monroe County could develop an administrative and facility operational capacity for managing all
aspects of wastewater treatment in the unincorporated County. Selecting this option would require the County to
make a major commitment that is considerably more significant than the administrative-only option described in
Section 3.5.2.3. The administrative and operational option requires the County to develop an operational program
and hire and train staff to carry out administrative and planning activities and develop competency and adequate
support (staff and equipment) to cost-effectively operate the Keys-wide wastewater system. Currently, the Monroe
County Public Works Department has maintenance facilities based on Stock Island, Marathon, and Plantation Key.
The City of Key West and City of Key Colony Beach would continue to have management oversight responsibility
for their publicly-owned wastewater facilities. Private state-certified contractors would continue to operate and
maintain the municipality-owned wastewater facilities as well as the few privately-owned facilities still operating
in the City of Key West.
The OSDSs would still remain under FDHRS jurisdiction.
All the engineering options outlined in Section 3.3 (e.g., existing systems, subregional plants, regional plants) can
be accommodated by this proposed institutional option.
Rationale: By limiting wastewater facility management to Monroe County, the City of Key West, and the City of
Key Colony Beach, rather than for 209 individually operated and managed systems, this option provides a more
streamlined management scheme resulting in a higher degree of uniformity in service reliability. Historically,
publicly-owned wastewater facilities function more reliably, partly because of a better and more frequent schedule
of facility maintenance. This option also provides a more efficient institutional framework within which the FDER
and EPA can function. Currently, the FDER must handle 209 separate entities, while the EPA permits and monitors
compliance for approximately 10 active facilities that discharge domestic wastewater.
Responsible Agency: This option does not lend itself to a responsible agency; however, it does limit the
management of wastewater facilities to three local governments:
•	Monroe County (all unincorporated areas)
•	City of Key West
•	City of Key Colony Beach
Implementation Mechanism: This option does not require the City of Key West or the City of Key Colony Beach
to alter their operating procedures unless service by either system is expanded into unincorporated areas, or the
facilities are to be purchased by the County and brought under the auspices of the County. To initiate this option,
the County needs to authorize a feasibility study for implementing a wastewater treatment utility. If the results of
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the study support the implementation of the County wastewater utility concept, the Monroe County Commission
needs to authorize the creation of such an entity by an ordinance action.
Implementation Requirements: If this is the desired option, the Monroe County Commission should assign the
responsibility for the coordination of all activities related to the implementation of a County wastewater utility
program to a specific individual. Further, the commission needs to fund an operational implementation plan that
details exactly how the County will establish such service. This plan would include recommending where this
function should be located within the structural framework of County government. Options would be to house the
function within the Public Works Department or to create a new department that deals solely with wastewater
treatment. Hie plan should also specify staffing needs by expertise; equipment needs; a billing and collection
procedure; a long-range plan that identifies which existing wastewater plants will become a part of the Monroe
County sewer program and/or where new regional or sub regional plants will be located; a schedule of key
milestones identifying when facilities will be brought on line; and a funding program. Without a plan, it is difficult
to identify staffing needs for the department; however, if the County initiates service with one subregional WWTP,
the following rule of thumb provides a reasonable estimation of staffing needs.
Once a subregional plant comes "on-line," approximately 11 people would be needed: a utility director; a secretary;
a treatment facility supervisor with two FDER-trained and -certified operators and two operator trainees; a collection
and distribution supervisor with a lift station mechanic; and a billing supervisor and a cleric who would be
responsible for billings and collections. Certainly at the outset, some individuals would serve several functions;
however, as the wastewater operation expands, there would be an increase in specialization among plant personnel.
In staffing the plant, the County needs to make sure that at least one person has a Florida Professional Engineer
(PE) license. Engineered drawings are frequently needed and must be sealed by a PE. As additional plants are
added, staff will need to be increased accordingly, especially in the areas of plant operations, and maintenance of
collection and treatment.
To ensure quality and reliability in staff performance, the County needs to incorporate a training component.
Currently, the University of Florida Center for Training, Research and Education for Environmental Occupations,
commonly known as TREEO, as well as the Water Environment Federation and the Florida Water Pollution Control
Operators Association offer courses that update and expand the	knowledge of individuals working in the
wastewater treatment management arena.
Minimum equipment needs would include a car for the director. For each subregional facility, a complement of
vehicles might include two or three pickup trucks, one two-ton truck with a hydraulic lift, a backhoe on a trailer,
and a portable electric generator. Adequate computer equipment and software need to be available for general
administrative operations and for maintaining billing and collections records. The County is establishing a GIS and
the physical location and size of the wastewater facilities and collection systems should be made a part of that
system. The GIS would be a useful management tool for the utility.
3.5.2_3 COUNTY WASTEWATER UTILITY - ADMINISTRATIVE ONLY
Description: This option, like the one described in Section 3.5.2.2, would involve placing all wastewater plants
located in the unincorporated County under the management control of Monroe County. Hie wastewater facilities
would be operated by private, state-certified operators (as is currently done). The County would have responsibility
for long-range planning, responding to customer inquires, billing, submitting required discharge monitoring reports
to the EPA and/or FDER, as well as overseeing plant operations and dealing with individual plant operators. All
the engineering options outlined in Section 3.3 (e.g., existing systems, subregional plants, regional plants) can be
accommodated by the proposed management option.
The two publicly-owned wastewater treatment systems (City of Key West and City of Key Colony Beach) would
remain under the management authority of their respective jurisdictions. Both cities would continue to have
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management oversight responsibility. Private, state-certified contractors would continue to operate and maintain
the various wastewater facilities.
This option envisions OSDSs remaining under FDHRS jurisdiction with the Monroe County Public Health Unit
serving as the local permitting and compliance point of contact.
Rationale: There are only two publicly-owned wastewater treatment systems in the Keys, in the City of Key West
and the City of Key Colony Beach. All others are privately-owned, the vast majority by homeowners associations.
There are 209 wastewater treatment facilities located in unincorporated Monroe County. Creation of a centralized
wastewater management authority within unincorporated Monroe County would allow the County to have better
regulation and management control of package plants with minimal staffing costs.
Responsible Agency: This option does not lend itself to a responsible agency; however, it does limit the
management of wastewater facilities to three local governments as follows:
•	Monroe County (all unincorporated areas)
•	City of Key West
•	City of Key Colony Beach
Implementation Mechanism: This option does not require the City of Key West or the City of Key Colony Beach
to alter its operating procedures; therefore, no formal implementation mechanism is required. Prior to initiating
this option, the County should undertake a wastewater treatment feasibility implementation study. Because the
County has no operational responsibility for wastewater treatment, the County should enact an ordinance that
describes the roles and responsibilities of the County under this option.
Implementation Requirements: If this is the desired option, the Monroe County Commission should assign the
responsibility to coordinate all activities related to the implementation of a County wastewater treatment management
program to a specific individual. Further, the commission needs to fund an operational implementation plan that
details how this option will be executed. The plan needs to include where the function will be located in County
government, either within an existing department or within a new department. The plan should also specify staffing
needs by expertise; equipment needs; a billing and collection procedure; a long-range plan that identifies which
existing wastewater plants will become a part of the Monroe County sewer program and/or where new regional or
subregional plants will be located; a schedule identifying key milestones of when facilities will be brought on line;
and a funding program.
Because the actual operation of the facilities would be handled by the private, state-certified contractor operators,
staffing needs are more limited. Primarily, staffing needs fall in the area of administrative management. The entity
will need to have a utility director, secretary, billing supervisor and clerk, and possibly a state-certified facilities
operator who would oversee and coordinate with the private contractor operators. In this particular instance, with
a minimum of staff, the utility director should be a trained engineer with a Florida PH license. Engineered drawings
are frequently needed and must be sealed by a PE.
To ensure quality and reliability in staff performance, the County needs to incorporate a training component.
Currently, the University of Florida TREEO as well as the Water Environment Federation and the Florida Water
Pollution Control Operators Association offer courses that update and expand the technical knowledge of individuals
working in the wastewater treatment management arena.
Minimum equipment needs would include a car for the director and a small pickup truck for the individual
overseeing the contractor operators. Adequate computer equipment and software need to be available for general
administrative operations and for maintaining billing and collections records.
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4.0 STORMWATER
4.1 INTRODUCTION
There are few effective stormwater management systems in the Florida Keys, for several reasons:
*	Many of the larger subdivisions or developments were constructed before SFWMD stormwater
permitting requirements were in place.
*	Most developments constructed after SFWMD stormwater regulations were in place fell below the
thresholds for those regulations (10 acres total or 2 acres of impervious surface).
*	Prior to 1986, Monroe County had no ordinance regulating stormwater management. The 1986
ordinance was largely unenforceable because of its stringent requirements with insufficient guidelines
for implementation, and difficulties of enforcing compliance on residential lots.
*	The lack of available lands for detention or retention areas generally made voluntary stormwater
management difficult.
Typical drainage in many areas consists of direct runoff to the nearest surface water, with some attenuation provided
by high infiltration rates. There are several engineered stormwater management systems using one or more
boreholes for disposal; most of these systems are in the City of Key West or Marathon. In July 1992, there were
a total of 11 such systems using 43 boreholes. Most other noticeable stormwater management improvements are
in the U.S. 1 right-of-way, such as the extensive swales located throughout much of Key Largo.
Because of the limited regulation of stormwater management in the Keys, the end result is largely uncontrolled
stormwater runoff. If there is no organized effort toward the improvement of stormwater management in the Keys,
the degradation of nearshore waters by stormwater runoff will continue. The current estimate for average
stormwater pollutant loading from developed areas is 401 lbs/day total nitrogen, 364 lbs/day total phosphorus and
83 tons/day total suspended solids (see Table A-7, Appendix A). As noted previously, effective population of the
Keys should only increase about 8.5% over the next 20 years. Although stormwater pollutant loadings are not
directly proportional to population, it is reasonable to assume proportionality in the absence of other data. If the
intensity of stormwater management efforts is not increased, the projected population increase will result in a slight
increase in loading of sediment, toxics, and nutrients to nearshore waters of the Sanctuary.
Three related engineering options and three management options to improve stormwater pollution control in the
Florida Keys are presented below.
4.2 ENGINEERING OPTIONS
Engineering options presented in this section represent varying levels of intensity or commitment in using the
stormwater engineering methods discussed in Appendix D and summarized in Table 3-6. These methods are
commonly used throughout Florida.
Engineering options for stormwater management are described briefly below and in detail in Appendix E. Because
of the similarity of the options, they are discussed together, rather than separately as in Appendix E. Estimated
costs, reductions in nutrient and sediment loadings, and cost effectiveness of the stormwater engineering options
are presented in Table 3-7.
• Option Sla - Retrofit "Hot Spots"
Identify and retrofit hot spots by using grass parking, swales, exfiltration trenches, pollution control
structures, and detention/retention facilities. Eliminate stormwater runoff in areas handling toxic and
hazardous materials. Install swales and detention facilities along limited sections-of U.S. 1.
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Table 3-6. Engineering methods Tor storm wafer pollution control.
Details are provided in Appendix D.
Grassed Swales, Waterways, and Filter Strips
These controls ire applied as alternatives to curb and
gutter drainage systems. Grassed swales consist of
slightly sloped grassed valleys with dam-like structures
made of stone and railroad ties that increase infiltration
and flow attenuation. Filter strips consist of gTass or -
other close-growing vegetation designed to accept
overland sheet flows of runoff. They are usually
composed of dense vegetation such as grass or wood,
combined with underlying stone layers for infiltration.
Curb Elimination
Curb elimination allows runoff to disperse over a
greater area rather than being channeled into collection
facilities. This dispersal over adjoining land, which is
usually covered by vegetation, also aids in reducing
runoff velocity and sedimentation of solids.
Catch Basins
Catch basins are part of an underground stormwater
collection, treatment, and disposal system.
Stormwater runoff may be diverted to an inlet or catch
basin. They are designed to capture grit, gravel, and
debris and protect the remainder of the storm drainage
system. Combined with a swale system where the
inlet of the catch basin is raised above the surrounding
swale, the catch basin acts as a prctreatment device.
Exfiltration Trenches
These are below-grade trenches with perforated pipe
inside a rock envelope used to disperse stormwater
below grade. In many areas where land costs are so
prohibitive that the use of retention or detention basins
is excluded or severely limited, exfiltration trenches
are commonly used with catch basins or other types of
outlets to prevent clogging.
Pollution Control Structures
These are baffled, velocity-reducing structures used to
remove coarse sediment and floating pollutants from
parking lot and street runoff.
Detention/Retention Facilities
These are storage basins used to attenuate peak flows
and settle suspended solids. Detention facilities are
emptied slowly through a bleeder opening on the
control structure. Retention facilities discharge
contents by percolation. Some nutrient removal can be
attained if littoral vegetation is used.
Class V Injection Wells (Boreholes)
These are shallow (60 to 90 ft deep) wells used for
gravity disposal of stormwater.
Aquifer Storage and Recovery
This is a relatively new technique involving pumping
treated water to a confined shallow aquifer (about
500 ft deep) for future use. The pumped water forms
a bubble, displacing native saline water. Differences
in densities and restrictions of the aquifer formation
minimize mixing of pumped and native waters.
Recovery can take place either immediately or in the
future for irrigation or other use*.
Deep Injection Well
This is a deep (2,500 to 3,000 ft) well used for
disposal of stormwater or wastewater. Deep well
injection has historically been used primarily for
disposal of wastewater and reverse osmosis brine.
Cisterns
These are tanks used to hold rain water for subsequent
potable or irrigation uses. Cisterns can be a
stormwater retention device, storing the water for
irrigating during dry periods. Although cisterns
provide no stormwater treatment, the capture of runoff
and delayed application to surrounding vegetation
provides a beneficial use of water and the vegetation
provides treatment.
Porous Pavement
Porous pavement is an innovative stormwater practice
with limited applicability for parking areas not subject
to sand and mud carried on tires. Paving with porous
concrete allows water to percolate into the underlying
soil.
Pervious Surfaces
Grassed or other pervious areas such as grassed or
gravel parking lots allow infiltration of water.
Irrigation Reuse
This method involves storage of stormwater in a
retention basin or in aquifer storage and recovery
wells, with subsequent reuse for irrigation.
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Table 3-7. Nutrient and sediment reductions and cost estimates for stormwater engineering options.
Option
Reduction in Loading!
(*)
NulricnU
(Slormwalcr
Only)*
Nutrient*
(Stormwitcr
+
Waaewaier)*
Sediment
(Stormwater)
Eatimated Coil
Initial	20 yr Tout 20 yr
(S million!) O & M ($ millioiu)
($ millioiu)
Coซ Efleclivcneu*
Nutrient!
(Stormwater)
Nutrient!
(Stormwater
+
WaMcwaier)
Sediment
(Sloimwatf)
Sla - Retrofit hot qioti	0.2-0.5	0.04-0.1	0.5-1.0
Sib — Retrofit hot apou	5-12	1.0-2 4	20-50
and population center!
Sic — Retrofil stormwater
facilities throughout
Sanctuary
Borehole di^nual	20-50	4.0-10.0	40-60
Deep well diipoul	20-50	4.0-10.0	40-60
SO
370
530
680
120
440
680
1000
200
810
1210
1680
400-1000
67-162
24-60
34-84
2000-5000
337-810
121-302
168-420
200-400
16-40
20-30
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O Sl M: Operation and maintenance
'Nutrient reduction ii calculated aa a percentage of both itormwater and combined (rtotmwalcr + waatcwater) nutrient loading!. Stormwater nutrient loading! are enimated to
average about 20% of combined (Mormwater + wastewater) loading!, bated on Table 3-1.
bCoซt e(Tccliveneu = total coit/pcrcenl reduction in nutrient or lediment loading!. Nutrient reduction! arc calculated ai a percentage of both atormwaler and combined
(Mormwater + waatcwater) nutrient loading!.

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•	Option Sib - Retrofit Hot Spots and Population Centers
Identify hot spots, and retrofit hot spots and population centers by using grass parking, swales,
exfiltration trenches, pollution control structures, and detention/retention facilities. Eliminate
stonnwater runoff in areas handling toxic and hazardous materials. Install swales and detention
facilities along the majority (developed area) of U.S. 1.
•	Option Sic - Retrofit Stormwater Facilities Throughout Sanctuary
Identify hot spots, and retrofit hot spots, population centers, and other developed areas throughout the
Sanctuary by using grass parking, swales, exfiltration trenches, pollution control structures, and
detention/retention facilities. Eliminate stonnwater runoff in areas handling toxic and hazardous
materials. Install swales and detention facilities along U.S. 1. Include ultimate disposal of stonnwater
via boreholes or deep wells for high-flow areas.
Description: The options represent a range of applications for the same engineering methods. At the first level
(Option Sla) engineering methods are applied only to identifiable hot spots, where stormwater pollutant loadings
are high and degradation of receiving waters is obvious or already documented. In the mid-level option (Option
Sib), engineering methods are extended to population centers and other developed areas. In the highest level option
(Option Sic), the same methods are applied throughout the Keys in nearly all developed areas.
Rationale: Retrofitting of stormwater hot spots with control and treatment methods (Option Sla) would reduce
loadings of sediment, toxics, and nutrients to Sanctuary waters. Application of the same methods to population
centers and other developed areas (Option Sib) and Sanctuary-wide (Option Sic) would result in successively greater
pollution reductions.
Cost: Estimated construction costs and 20-year operating/maintenance costs for each option are summarized in
Table 3-7. Construction costs range from $80 million (Option Sla) to $680 million (Option Sic with deep well
disposal). Twenty-year operating/maintenance costs range from $120 million (Option Sla) to$l billion (Option Sic
with deep well disposal). Total costs range from $200 million (Option Sla) to $1.68 billion (Option Sic with deep
well disposal).
Pollution Reduction: The effectiveness of stormwater control/treatment facilities is not well known and is very
site specific. Nutrient removal is highly dependent on site conditions, engineering methods, and level of
maintenance, therefore, estimates in Table 3-7 are approximate.
Estimated reductions in nutrient loadings (percentage of total stonnwater nutrients) are 0.2-0.5% for Option Sla,
5-12% for Option Sib, and 20-50% for Option Sic. However, stonnwater nutrient loadings are much smaller than
wastewater nutrient loadings. In terms of total wastewater and stonnwater nutrients, the stonnwater engineering
options would result in a small reduction in nutrients, at a very high cost.
Estimated reductions in sediment loadings range from 0.5-1.0% for ptionSla, 20-50% for Option Sib, and
40-60% for Option Sic. Because stormwater runoff is probably a majc source of sediment loadings to Sanctuary
waters, these are significant reductions, albeit at a very high cost. Loadings of toxics (e.g., metals and
hydrocarbons) have not been estimated, and therefore the reductions cannot be quantified. However, stormwater
control methods would reduce loadings of toxics into Sanctuary waters.
Implementation: Section 4.4 discusses the existing and alternative institutional frameworks for stormwater
management in the Florida Keys that would be relevant to implementing Options Sla-Slc. While the FDER has
statewide responsibility for stormwater management, the department has delegated its responsibilities in the Florida
Keys to the SFWMD. Options for implementing Keys-wide stonnwater control would include continuing with
SFWMD as the responsible agency, creating an independent stormwater utility, and leaving stormwater management
to local governments (e.g., Monroe County, City of Key West). Other agencies that would be involved would
include the Florida Department of Transportation (FDOT), EPA, and FDER.
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4.3 MANAGEMENT OPTIONS
Three management options are presented for stormwater:
•	Option S2 — Eliminate Permitting Threshold
Eliminate the current minimum threshold acreage (less than 10 acres total or less than 2 acres of
impervious surface) required for developments to obtain a stormwater permit.
•	Option S3 — Enact Stormwater Management Ordinances and Master Plans
S3a — Require and set deadlines for local governments to enact and implement stormwater
management ordinances and comprehensive stormwater management master plans.
S3b — Require and set deadlines for local governments to enact and implement stormwater
management ordinances and comprehensive stormwater management master plans. As a backup in the
event that these ordinances and master plans are not enacted and implemented in a timely manner,
EPA would be petitioned to include the Florida Keys in the stormwater NPDES program.
•	Option S4 — Institute Best Management Practices
Institute a series of Best Management Practices (BMPs) and a public education program to prevent
pollutants from entering stormwater runoff. The programs include street sweeping; public education
and ordinances aimed at controlling fertilizer application on public and private landscaping; collection
locations and a public education program for the proper use and disposal of fertilizers, pesticides,
motor oil, and other hazardous chemicals; and strenuous litter control programs.
4J.1 Option S2 — Eliminate Permitting Threshold
Description: This option would require that stormwater management ordinances in the Florida Keys contain no
threshold (minimum) acreage for obtaining a stormwater management permit.
Rationale: Currently, the only stormwater runoff regulatory controls are those administered by the SFWMD.
Under the SFWMD's rules, development projects under 10 acres in size and/or having less than 2 acres of
impervious surface are exempt from the permitting process. Individuals or companies developing property must
adhere to all SFWMD stormwater management rules and regulations. However, because the SFWMD does not have
the staff or resources to monitor each single family home built in the Florida Keys, stormwater essentially goes
unregulated.
With no change in the existing SFWMD policy or adoption of stormwater management ordinances by local
governments, stormwater will continue to go unchecked and will continue to contnbute to the water quality
degradation. Some local governments are in the midst of implementing a stormwater management ordinance or
anticipate enacting one in the near future. Local ordinances should not exempt agg development from the
stormwater permitting process.
Responsible Agency: Each local government would be the responsible agency in implementing its own ordinance
within its jurisdictional limits. As the state land planning agency for a designated Area of. Critical State Concern
(ACSC), the FDCA has an oversight responsibility to ensure that local development regulations adequately protect
the area's natural resources and are consistent with those of their neighbors.
Implementation Mechanism: This option could be implemented through a change in SFWMD policy or through
local stormwater management ordinances.
Implementation Requirements: When drafting their stormwater management ordinances, local governments need
to avoid exempting any development from the regulatory processes dealing with stormwater runoff.
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4.3.2 Option S3 — Enact Storm water Management Ordinances and Master Plans
Description: This option consists of two parts. Option S3a would require and set deadlines for local governments
to enact and implement stormwater management ordinances and comprehensive stormwater management plans.
Option S3b would further provide that, in the event that these ordinances and master plans are not enacted and
implemented in a timely manner, the FDER would petition EPA to include the Florida Keys in the stormwater
NPDES program.
Rationale: All adopted government comprehensive plans have stated that local governments will prepare stormwater
management master plans. This option would require the development of and adherence to an implementation
schedule culminating in 1994. All stormwater plans should address not only water quantity but also water quality
issues. While few data exist, the comprehensive plans indicate that unregulated stormwater runoff has most likely
contributed to nearshore nutrient and sediment loading.
The possibility of petitioning EPA to include the Keys in the stormwater NPDES program has been included as a
backup in the event that local governments do not enact and implement stormwater management ordinances and
master plans in a timely manner. Due to its population size, Monroe County (which includes its municipalities) falls
below the population threshold which would trigger the County's inclusion into the EPA stormwater NPDES
program for municipal separate storm sewer systems. However, states may petition EPA to include a local
government in the stormwater NPDES program.
Responsible Agency: Under the authorities of Sections 163.3161 and 380.05 FS, the FDCA has the responsibility
for ensuring that programs and regulatory rules enacted by local governments in Monroe County are consistent with
the legislative growth management principles described in the above-mentioned sections of the Florida Statutes.
However, each local government will be responsible for developing their own stormwater management ordinance.
Subsequent modifications to each ordinance may be necessary once each local government adopts its stormwater
management master plan.
The responsible agency for petitioning EPA to include the Florida Keys in the stormwater NPDES program, should
that become necessary, would be the FDER.
Implementation Mechanism: Stormwater master plans have been recommended in each local government's
comprehensive plan. From a legal viewpoint, local comprehensive plans carry the force of law. This statutory
provision requires local governments to implement their policies and actions set forth in their comprehensive plans.
The local government stormwater ordinances will result from legislative actions taken by the governing board or
council.
If the NPDES route becomes necessary, the FDER would submit a petition that describes the existing situation and
identifies why Monroe County and its municipalities warrant inclusion in the program. EPA would make the
decision on whether or not the County and/or municipalities are brought under the stormwater NPDES permitting
process.
Implementation Requirements: A major implementation requirement is funding. No local government has the
capability of preparing such plans in-house. The use of consultants may be necessary; however, another option
could involve using FDER and SFWMD staff. This approach is more applicable to Monroe County and the City
of Key West, which already have a certain level of expertise on this issue. The SFWMD, FDER, FDCA, or EPA
would earmark funds that could serve as seed funds or an incentive to implement such a master plan and/or
regulation. This is not unusual; the SFWMD is providing funding to the City of Key Colony Beach to assist in the
development of its stormwater management master plan.
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4.3.3 Option S4 — Institute Best Management Practices
Description: This option would institute a series of BMPs and a public education program to prevent pollutants
from entering stormwater runoff. Programs would include street sweeping involving mechanical brush and vacuum
removal of grit, debris, and trash from highway surfaces; public education and ordinances aimed at controlling
fertilizer application on public and private landscaping; collection locations and a public education program for the
proper use and disposal of fertilizers, pesticides, motor oil, and other hazardous chemicals; and strenuous litter
control programs to remove leaves, lawn clippings, pet waste, and trash before they can be washed into marine
habitats.
Rationale: Relative to domestic wastewater, stormwater is not a significant pollution problem in the Florida Keys.
The problem results from the pollutants (nutrients, hydrocarbon products, toxic chemicals, etc.) in the waste stream
that generally discharge into mปrinป habitats. There are a number of terrestrial BMP-type programs which will
reduce the amount and types of pollutants available for stormwater transport.
Responsible Agency: The responsible agency should be Monroe County, in coordination with the municipalities.
Implementation Mechanism: The County and respective cities can initiate intensified street cleaning and litter
control programs. Fertilizer, herbicide, pesticide, and used oil programs aimed at the general public will require
public awareness and public education campaigns. NOAA, through the FKNMS Sanctuary Office, should assist
by including such elements in their general FKNMS-related public education efforts. In addition, the County and
the municipalities should seek FDER assistance. The FDER's Nonpoint Source Management Section has completed
extensive work dealing with BMPs, and has worked with local governments around the state in developing public
education programs.
Implementation Requirements: Some new funds will be required at the County and city levels if a vigorous street
cleaning program is to be undertaken. However, public education and public awareness is the single most important
element in initiating any BMP with respect to stormwater runoff.
4.4 INSTITUTIONAL OPTIONS
4.4.1 Existing Institutional Framework
While an existing institutional framework exists for stormwater management, in practice, only minimal attention
has been given to controlling this pollution source. No local government has developed either a stormwater master
plan (although the City of Key Colony Beach is currently doing so) or a stormwater management ordinance. While
there are no formally adopted rules regarding stormwater management, Monroe County, through its Development
Review Committee, addresses the issue for those projects that require site plan approval. The Planning Director
for the City of Key West addresses stormwater issues when deemed appropriate. As the coordinator for
development approvals, the Planning Director seeks the input of the City Engineer or other pertinent city officials
as needed.
From an operational viewpoint, Monroe County and the City of Key West are involved in stormwater management.
Each, through their public works departments, maintains the swales and drainage ditches in their corporate limits.
Monroe County Public Works Department headquarters is located on Stock Island with two branch operations
located in Marathon and Plantation Key.
While the FDER has statewide responsibility for stormwater management, it has delegated its responsibilities in the
Florida Keys to the SFWMD while retaining oversight responsibility. The SFWMD has regulatory responsibility
for stormwater management; however it exempts certain development from the permitting process. Development
projects under 10 acres in size and/or having less than 2 acres of impervious surface are exempt from SFWMD
review.
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4.4.2 Options
This section discusses three alternatives to the existing institutional framework for stonnwater management in the
Florida Keys.
4.4.2.1 SOUTH FLORIDA WATER MANAGEMENT DISTRICT
Description: Under this option,, the SFWMD would have the sole responsibility for permitting all stonnwater
activities in the Florida Keys. The SFWMD would also have the responsibility for maintaining all publicly-owned
stonnwater facilities in the unincorporated County.
Rationale: The SFWMD is currently responsible for permitting stonnwater management applications; however,
the SFWMD reviews only those developments 10 acres in size or greater or projects with greater than 2 acres of
impervious surface.	of each local government developing the capacity to permit stonnwater activities, the
SFWMD would review all site plans. The SFWMD also has responsibility for maintaining all stonnwater facilities
owned by the SFWMD.
The SFWMD recently established an office in Marathon. This location is relatively central for Florida Keys
residents, and more importantly makes the SFWMD more accessible.
Responsible Agency: The responsible agency would be the SFWMD.
Implementation Mechanism: The implementation mechanism would be a MOU between the SFWMD and each
local government or local governments as a group. It should descnbe the responsibilities of each government entity
and those of the SFWMD.
Implementation Requirements: Prior to implementing this option, the SFWMD and participating local
governments would need to prepare an operational management plan outlining the roles and responsibilities of all
parties (the plan should shape the contents of the MOU) and the permitting and review procedures. This is
especially important because the SFWMD would be reviewing stonnwater management plans for development
projects in four different governmental entities. Once the process is mutually agreeable to all parties, each local
government should enter into a five-party stonnwater management intergovernmental agreement or individual
agreements with the SFWMD.
The SFWMD would need to augment the present staff level at the Marathon office. Because most of the work
would be permitting, the office should include an engineer, technician, and secretary. In addition, the office should
have computer linkage to the SFWMD central facility in West Palm Beach. A truck should be assigned to the office
for compliance inspections.
4.4.2.2 STORMWATER UTILITY
Description: This option would establish a stonnwater utility to permit and manage all stonnwater matters in the
Keys. The utility would review all development applications for permits, operate and maintain stonnwater facilities,
submit all monitoring compliance reports to the appropriate state and federal agencies, and construct or oversee the
construction of all stonnwater facilities approved by the stonnwater utility. This entity would also have the
authority to set fees.
Rationale: The stonnwater utility would have Keys-wide responsibility. An advantage of this option is that entities
having a sole function generally provide a high level of service. However, there are disadvantages to this option.
First, it would require the establishment of a new entity, which would involve a major outlay of funds as compared
with building on an existing entity. The entity would have no organizational structure, physical equipment, or
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manpower already in place. Further, it is not clear whether stormwater is such a significant problem in the Florida
Keys that it warrants establishing a new entity to carry out stormwater management.
Responsible Agency: The responsible agency would be Monroe County.
Implementation Mechanism: Implementation could be accomplished either through a legislative act or a directive
of the Governor (the method by which the FKAA was created).
Implementation Requirements: The most feasible approach would be to implement this option by enacting state
legislation. Local governments, as a unified group, would need to petition the Monroe County state legislative
delegation and request that the delegation sponsor and introduce enabling legislation that would provide the authority
needed to establish a Keys-wide stormwater utility.
Before any commitment is made to implement this option, local governments would need to undertake a feasibility
study to determine the cost of setting up such a utility.
4.4.2J LOCAL GOVERNMENT MANAGEMENT
Description: Under this option, local governments would develop a stormwater management capability and
implement a local program.
Rationale: This option is based on the idea of maintaining local control. Instead of having either the FDER,
SFWMD, or a multi-jurisdictional authority (such as a stormwater utility) regulate stormwater discharges, the
County and each city would develop their own technical capability to regulate stormwater management.
While there is no department within either the City of Key West or Monroe County whose function is solely
stormwater management, both entities have departments that deal with stormwater concerns. Although there is no
stormwater management ordinance, the County and City consider stormwater ramifications when reviewing site
plans for development projects other than single family residences. In terms of the operational side of stormwater
management, the City of Key West Public Works Department has the responsibility for such matters. In Monroe
County, the Road Department within the Public Works Division maintains the swales and drainage ditches in the
unincorporated area other than those that are the responsibility of the FDOT (such as drainage areas along U.S. 1).
Also housed within the Public Works Division is the Engineering Department and Central Services Department
(vehicle maintenance). The division's main office is located on Stock Island, with branch locations in Marathon
and Plantation Key. Because of the small size of the City of Key Colony Beach and the City of Layton, in terms
of jurisdictional area as well as population, neither local government has a public works department.
Responsible Agency: This option does not lend itself to a responsible agency. Ail local governments would need
to be responsible for stormwater within their own jurisdictional limits
Implementation Mechanism: Because the City of Key West and Monroe County have particular sections within
local government carrying out stormwater management activities, it appears that no official ordinance action would
need to be taken to formally assign stormwater management responsibility. However, to formalize the assignment
of stormwater management, the elected boards of the City of Key West and Monroe County could take an ordinance
action formalizing the present arrangement. The City of Key Colony Beach and the City of Layton would continue
to contract for services when necessary, or contract with the County to provide such services.
Implementation Requirements: According to the various Monroe County local government comprehensive plans,
stormwater management ordinances will be enacted by 1993. Each local government should assess its capability
for implementing its ordinance in terms of staff (includes number and expertise needs), equipment, space needs,
and training requirements.
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Initially, thi City of Key West and Monroe County might be able to manage with their present resources because
both departments already deal with stonnwater management matters in terms of facility construction and
maintenance, engineering, and planning perspectives. The City of Layton and the City of Key Colony Beach could
continue to hire private contractors on an as-needed basis, or they might consider entering into an arrangement with
Monroe County. If one or both of the cities decide to do so, they would need to enter into an interlocal agreement
outlining both procedural and financial details.
5.0 MARINAS AND LIVE-ABOARDS
5.1 INTRODUCTION
A live-aboard is defined as "an individual(s) whose continual residence is a boat, not necessarily at a fixed location,
for a period of time of more than two months" (Antonini et al. 1990). As described in the Phase I report,
live-aboards can be found throughout the Florida Keys. Most are located in clusters in a few areas such as Card
Sound, Largo Sound, Matecumbe Harbor, Marathon, and Key West. There is currently- little regulation of
live-aboards; what regulation there is comes from the Florida Marine Patrol (FMP) and the U.S. Coast Guard
(USCC), but this has to do with seaworthiness and navigation more than wastewater discharge.
The live-aboard population in the Florida Keys has increased significantly in recent years. As discussed in the
Phase I report, local water quality problems have been detected in some confined waters where live-aboards
congregate, but there is no scientific evidence of widespread water quality degradation or adverse effects on
Sanctuary resources from live-aboards.
Marina operations with the potential for polluting water or sediments include boat bottom scraping and painting,
fueling operations, residual fuels and oils from engine repairs or bilge cleaning, and the use or disposal of resins
and solvents associated with fiberglass construction or repair. As noted in the Phase I report, a small number of
samples collected from paint scrapings and bottom sediments at marinas in the Florida Keys have indicated the
presence of metal contamination. Available data are insufficient to quantify pollutant loadings or to assess the
detrimental effects from bottom painting operations. There are no data documenting the detrimental effects from
other marina operations — only anecdotal evidence such as visible sheens on waters near fueling operations.
Based on the existing data, six management options have been developed that would help to reduce pollution from
marinas and live-aboards. Additional data concerning pollutant concentrations in water and sediments of mannas
and live-aboard areas will be collected through the monitoring program described under Task 6. These data should
indicate the severity and extent of water quality problems and whether there is a need for further pollution control
measures.
•	Option B1 — Establish No-Discharge Zones
Designate no-discharge zones where vessels congregate and there is also a history of water quality
violations.
•	Option B2 — Establish Mooring Fields
Establish mooring fields in places having significant concentrations of live-aboard vessels.
•	Option B3 — Increase Pump-Out Facilities and Usage
B3a — Increase the number and accessibility of pump-out facilities in the Florida Keys, including
permanent land-based facilities and/or mobile pump-out vessels.
B3b — Increase the number and accessibility of pump-out facilities in the Florida Keys, including
permanent land-based facilities and/or mobile pump-out vessels. Require boaters to use pump-out
facilities and develop an enforcement program to ensure that they use them.
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• Option B4 — Establish Containment Areas for Boat Maintenance
Establish paved and curbed containment areas for boat maintenance activities such as hull scraping and
repainting, mechanical repairs, fueling, and lubrication. Create secondary containment, generally in
the form of curbing or synthetic liners, for areas where significant quantities of hazardous or toxic
materials are stored. Evaluate procedures to avoid or reduce fuel spillage during refueling operations.
ฐ Option B5 — Require Marina Operating Permit
Require all marinas in the Florida Keys to obtain a single operating permit from the FDER. This
would simplify the existing permitting process and require older marinas to comply with new standards
for BMPs, thereby reducing pollution.
0 Option B6 — Implement Water Quality Environmental Awareness Program
Formalize and expand the existing FMP District 9 environmental education program to heighten
awareness of how human activities contribute to water quality problems.
The first three options apply to live-aboards and would attempt to reduce pollution by restricting areas where
discharges may occur (Option Bl), concentrating live-aboards in areas where wastewater treatment facilities can be
provided (Option B2), or increasing the availability and usage of pump-out facilities (Options B3a and B3b).
Options B4 and BS pertain to marinas; Option B4 would reduce pollution by requiring containment areas for boat
maintenance, whereas Option BS could lead to pollution reduction through simplified permitting. Option B6 pertains
to boaters and marinas in general, and would reduce pollution through education and increased environmental
awareness.
5.2 MANAGEMENT OPTIONS
5.2.1 Option Bl — Establish No-Discharge Zones
Description: Under this option, EPA would designate no-discharge zones in accordance with pro* ;ions of marine
sanitation devices where live-aboard vessels congregate and there is also a history of water qualit violations.
Rationale: This option is applicable to specific hot spot areas rather than to the FKNMS as i whole. This
management option could be used to reduce pollution in areas having severe water quality dep adation due to
concentrated boating activities.
Responsible Agency: EPA would be the responsible agency in designating the no-discharge zones, but the request
would have to come from the state of Florida or a private petitioner. Normally the USCG would enforce such
no-discharge zones, but in this case enforcement might be delegated to the state of Florida if the state so requests.
Implementation Mechanism: The legislative mechanism to implement this option is in place in terms of declaring
no-discharge zones. Enforcement procedures and responsibilities need to be worked out if the option is to be
effective; therefore, an MOU among the USCG, FMP, and the NOAA Sanctuary Office needs to be developed.
Implementation Requirements: The NOAA Sanctuary Office should undertake a study to evaluate the need for
no-discharge zones in the Florida Keys. Need should be based on the ability to achieve or maintain the
state-adopted water quality standards and/or a documented deterioration of habitat in the proposed zones. Other
aspects that should be considered include water circulation, concentration of boats in the area, percent of boats with
Type I or II manne sanitation devices, and impacts on fishing and swimming areas.
Implementation of this option will require adequate manpower, equipment (e.g., boats), and funding to achieve
adequate enforcement. The number of additional enforcement officers is dependent upon the number of
no-discharge zones established. This effort will require the cooperation and coordination among the USCG, FMP,
and NOAA Sanctuary Office.
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5.2.2 Option B2 — Establish Mooring Fields
Description: This option would establish designated mooring fields or anchorage areas in places having significant
concentrations of live-aboard vessels. Used in conjunction with shore-based or mobile pump-out facilities, mooring
fields could provide an effective means of controlling waste discharges from live-aboard boats.
Rationale: Mooring fields have been proposed to restrict non-marina live-aboards to certain anchorage areas in
order to concentrate waste collection efforts and reduce the areal extent of potential pollution sources. With the
ever-increasing number of live-aboards in the Florida Keys that do not use marinas, mooring fields would facilitate
waste collection and allow the monitoring of impacts created by this use of the FKNMS.
Mooring fields can be used to organize the live-aboards in a mannw that benefits the local governments as well as
the live-aboard population. Implementing this concept would make inspection and enforcement functions easier for
local government and could offer several advantages to the live-aboard boater as well. Currently, the live-aboard
community receives few or no public services. By adopting this concept, government can more easily plan for and
implement a package of public services that meets the needs of the live-aboard population. In addition to wastewater
collection, this may include such amenities as land access for dinghies, garbage collection, shower/toilet facilities,
and parking.
Responsible Agency: The FDER, Florida Department of Natural Resources (FDNR), and USCC would all have
to assist in implementing this option by providing sufficient technical expertise and jointly processing required
permits. Monroe County, the City of Key West, or the NOAA Sanctuary Office would have to take the lead in
attempting to set up designated mooring fields at specific locations.
Implementation Mechanism: Legal designation of mooring fields requires a permit or land lease from the FDNR
Bureau of Submerged Lands and Preserves. It also requires a USCG permit because it affects navigable waters.
The FDER interacts with the FDNR in terms of making environmental inspections of selected sites and issuing
resource evaluations and impact assessments to the FDNR.
Implementation Requirements: Implementing this option would require locating and permitting suitable sites,
designing mcoring fields, and acquiring and constructing the shore-based amenities mentioned above. Locations
for mooring nelds must have adequate depth and must be located where they will not impede navigation. Permanent
moorings an. bored to the bottom must be provided to prevent damage from boat anchors. There are also questions
of liability sud implied responsibility that need to be reviewed by the sponsoring entity before such a program is
undertaken. The live-aboard community should be involved in the implementation of this option.
5.2.3 Option B3 — Enhance Pump-Out Facilities and Usage
This option would reduce pollution by increasing the availability and usage of pump-out facilities in the FKNMS.
Two levels of the option are presented. The first (Option B3a) would simply increase the availability of pump-out
facilities, on the theory that if more facilities were available, more people would use them. The second (Option
B3b) would increase the facilities and require boaters to use them.
5.2.3.1 OPTION B3a - INCREASE PUMP-OUT FACILITIES
Description: This option would increase the number and accessibility of pump-out facilities in the Florida Keys,
including permanent land-based facilities and/or mobile pump-out vessels.
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Rationale: There are only eight pump-out facilities along the Florida Keys. Several are ldjcated in private marinas
aud are not available to the general public. If pump-out facilities were more numerous and accessible, presumably
more people would use them.
Both permanent, land-based pump-out facilities and a mobile pump-out service should be considered. A mobile
pump-out service would have two advantages:
*	It would make pumping out easy for live-aboard boaters or any vessel with a marine sanitation device.
•	It would establish a database that could help the FMP Environmental Crimes Unit, NOAA Sanctuary
Officers, or some other law enforcement agency, to identify and prosecute violators.
Responsible Agency: Because most of the land area along the Florida Keys is within the unincorporated County,
the responsible agency should be Monroe County, working in conjunction with the NOAA Sanctuary Office and
the FDNR.
Implementation Mechanism: This option could be implemented entirely by Monroe County. The County could
pass an ordinance requiring all marinas offering overnight docking to boats over a given length to have stationary
or mobile equipment to pump the holding tanks of such vessels. The same option could be implemented at the state
or even the federal level, but implementation at these levels would be legislatively more complex and would take
substantially longer to put into practice.
No new legislation or legal authority is needed for the County lo develop a mobile pump-out service. A prototype
study could be conducted to determine how many live-aboard boaters in a given area would voluntarily subscribe
to such a service. If the idea appeared to be economically viable, the County could advertise for suppliers of the
service and sell franchises on a bid basis.
Implementation Requirements: The development and operation of pump-out facilities would be the responsibility
of the individual marina owners. The operational costs could be recovered by user fees. These fees could also
defray development costs. If the user fee approach is considered to be a desirable alternative, the County should
incorporate protection against the setting of unreasonable user fees by ™rina owners. Another possible funding
source to assist in the development of these facilities was recently enacted. In November 1992, the Congress
enacted the Clean Vessel Act. This legislation has authorized funds for the development of pump-out facilities.
Administrative responsibility of this program rests with the FWS.
To be effective, the pump-out facility should be easily accessed. Ultimate accessibility can be provided by a mobile
pump-out cart with capability to traverse docks and pump from moored boats. A less convenient option would be
to require all live-aboards to move their vessels to dockside pump-out facilities at specified intervals. Solid waste
collection facilities should be provided in conjunction with all sanitary waste collection facilities.
To implement a mobile pump-out service, the County would have to provide some form of centralized collection
and treatment for the sewage collected by the mobile pump-out vessels.
5.2.3.2 OPTION B3b - ENFORCE PUMP-OUT USE
Description: Under this option, an enforcement program would be developed to ensure that pump-out facilities are
used. The FMP, Monroe County ShenfFs Department, and FKNMS officers would develop an enforcement
program to ensure that all vessels with marine sanitation devices use available pump-out facilities. Prior to
beginning such a program, more pump-out facilities would have to be made available (as in Option B3a) so that
conscientious boaters would be able to comply with the law.
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Rationale: Even where pump-out facilities exist, minimal use of the facilities occurs. Laws exist which allow the
USCG to restrict discharges from marine sanitation devices, but a workable system of coordinated enforcement
procedures has never been developed. There are several ways to approach this problem, but essentially all involve
funding for additional law enforcement.
Responsible Agency: Considering this situation as a FKNMS-wide problem, the NOAA Sanctuary Office is the
logical agency to take the responsibility for this issue. This office will need close coordination with the USCG,
FMP, and "boating rights" representatives from the Florida Keys.
Implementation Mechanism: Developing the legal framework to implement this option would be relatively simple
if the EPA's powers of delegating no-discharge zones were used. The state of Florida in conjunction with the
NOAA Sanctuary Office could request that the entire FKNMS be declared a no-discharge zone. Enforcement,
however, would still be a difficult task.
Implementation Requirements: For this option to be effective, a carefully thought-out enforcement strategy must
be developed. This strategy development effort must include the boating public as well as the agencies that will
ultimately be responsible for the law enforcement. One possible enforcement tool is to issue a large visible sticker
to all boats anchored or passing through the FKNMS. Each time a vessel's holding tanks were pumped out, the
sticker would be stamped with the date and time of pump-^u If the vessel had not had its holding tanks pumped
out within a given length of time based on its size and carrying capacity, a citation could be issued. A variation
of this option would be to set up a number of public or private mobile pump-out vessels throughout the Keys that
could visit anchored vessels and pump the holding tanks onsite for a reasonable fee.
5.2.4 Option B4 — Establish Containment Areas for Boat Maintenance
Description: This option would involve establishing of containment areas wherever boat hulls are scraped and
repainted, or mechanical repairs are made. Secondary containment, generally in the form of curbing or synthetic
liners, would be constructed for areas where significant quantities of hazardous or toxic materials are stored.
Procedures to avoid or reduce fuel spillage during refueling operations would be evaluated.
Rationale: There are more than 180 marinas in the Florida Keys and the services provided by each vary widely.
Some only sell food provisions, boating supplies, and/or contain a restaurant; however, others offer boat
maintenance services such as scraping and repainting of boat hulls, mechanical repairs, as well as fueling services.
Independently, these activities may not have a significant impact; however, the cumulative effect, especially where
there are a number of marinas in close proximity, can definitely affect water quality unless special precautions have
been taken to eliminate such pollutants from reaching coastal waters.
Little effort is now directed toward containing and collecting wastes associated with bottom scraping and painting
or mechanical repairs. Providing a curbed area would contain paint chips or dust and other wastes so that they
could be removed and disposed of properly.
Responsible Agency: The responsible agency should be EPA.
Implementation Mechanism: The EPA NPDES stormwater discharge rule is the mechanism to implement this
option. In 1990, EPA	rules to control stormwater discharges from a variety of uses. The rule is known
as the NPDES Permit Application Regulations for Stormwater Discharges. Marinas that are involved in boat
maintenance activities (including vessel rehabilitation, mechanical repairs, painting, fueling, and lubrication) or
equipment cleaning operations are considered industrial activities according to 40 CFR 122.26. Therefore, all
marinas involved in such activities must apply for an NPDES stormwater permit. These permits require applicants
to address how they plan to eliminate pollutants such as toxics from the stormwater runoff generated as a result of
their marina activities. The applicants have to identify the BMPs they intend to use. One alternative is to construct
containment areas, and restrict all marine repair and boat hull reconstruction to the containment areas.
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Implementation Requirements: Outdoor containment areas would require drains, sumps, and pollution control
devices (grease traps) and should be swept at regular intervals to minimize pollutants in runoff discharge. Detention
or retention between pollution control devices and the outlet to surface water or groundwater (borehole) would
provide a high level of treatment for these areas. Secondary containment, generally in the form of curbing or
synthetic liners, would need to be constructed for areas where significant quantities of hazardous or toxic materials
are stored. Outdoor areas would require valved drains that are normally closed, but could be opened to remove
stormwater in the absence of any spills. Indoor areas would not have drains or outlets, but should provide means
of absorbing or collecting spills. The County should work with	operators to ensure that there are means
available to them, at a reasonable cost, to have their hazardous waste by-products collected and transported to an
authorized hazardous waste disposal facility.
5.2.5 Option B5 — Require Marina Operating Permit
Description: All mnrinag in the Florida Keys would be required to have an operating permit.
Rationale: The coastal waters in the Florida Keys are environmentally sensitive to impacts from marina activities
such as uncontrolled wastewater discharges from vessels, scraping and repainting of boat hulls, and gas and oil spills
resulting from fueling operations. Marina operations are already subjected to numerous permits and permit review
processes. One overall FDER operating permit would simplify matters for the manna operator, allow the
implementation of BMPs, and help reduce pollutant loadings reaching adjacent coastal waters.
Responsible Agency: The responsible agency should be the FDER.
Implementation Mechanism: New nrtnrinn
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Implementation Mechanism: Nothing is required to implement this option other than additional funding al owing
the FMP to improve and increase the range of its existing program.
Implementation Requirements: This option is tied directly to an existing water quality and environmental
awareness program directed at the general boating public. All that is required to expand the program is additional
funding and management directive from the FDNR. All water quality and public awareness programs should be
coordinated with the efforts of the NOAA Sanctuary Office.
6.0 LANDFILLS
6.1 INTRODUCTION
According to the Phase I report, there is only one active landfill operation in the FKNMS, at Stock Island (serving
the City of Key West). This facility will cease its operations by November 1993. Three other landfills, at Cudjoe
Key, Long Key, and Key Largo, were active in 1990 but have ceased accepting waste. As of December 1990,
Monroe County contracted Waste Management, Inc. to haul solid waste out of the County, and the closed landfills
serve as subdistnet transfer locations. A seven-acre, synthetically lined expansion of the Cudjoe Key landfill,
completed in December 1990, is being kept in reserve for emergency or future use.
In addition to these four recently active landfills, FDER files indicate that there are four older landfills that have
been closed for some time. These are the old Key Largo, Saddlebunch Key, Fleming Key, and Boot Key landfills.
Four U.S. Navy landfills in the Keys are being assessed and, if necessary, will be remediated under the Navy's
Installation Restoration Program. Also, according to knowledgeable state and local government personnel, there
are a number of smaller abandoned landfills and casual dumping sites, many on private property, within the Florida
Keys.
All landfill sites in the Florida Keys (with the exception of the Cudjoe Key expansion) were developed prior to
current regulations requiring bottom liners and leachate collection. At many sites, filling with solid waste probably
occurred below the water table in the early stages. Consistent with common practice at the time, there was probably
little or no control over materials deposited in these landfills. These conditions indicate a significant potential for
contamination of groundwater and surface waters from these inactive landfills.
Although the potential exists for problems, monitoring data do not indicate leaching from landfills or water quality
degradation in areas adjacent to landfills. Therefore, no corrective actions are proposed. However, two
investigative management options are proposed to ensure that landfills are not causing water quality problems:
•	Option LI — Conduct Historical Landfill Search
Conduct a comprehensive search for abandoned landfills and dumps. Evaluate each site to determine
if they contain hazardous materials or are causing environmental problems. If problems are
discovered, evaluate and implement appropriate remedial actions such as boring or mining, upgrading
closure, collecting and treating leachate, constructing slurry walls, or excavating and hauling landfill
contents.
•	Option L2 — Intensify Landfill Monitoring
Intensify existing monitoring programs around landfills to ensure that no leaching is occurring into
marine waters. Identify and monitor ,old landfills that were never permitted and therefore have no
closure plans or closure permits. If problems are discovered, evaluate and implement appropriate
remedial actions such as boring or mining, upgrading closure, collecting and treating leachate,
constructing slurry walls, or excavating and hauling landfill contents.
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These two options are described below in Section 6.2. Based 01 the findings of these investigations, additional
monitoring and/or options for remedial action could be designed (n a case-by-case basis. Section 6.3 presents an
overview of engineering methods that could be used if problems are discovered.
6.2 MANAGEMENT OPTIONS
6.2.1 Option LI — Conduct Historical Landfill Search
Description: This option would involve conducting a comprehensive search for abandoned landfills and dumps.
Each site would be evaluated to determine if it contains hazardous materials or is causing environmental problems.
If problems were discovered, appropriate remedial actions would be evaluated and implemented.
Rationale: According to knowledgeable state and local government personnel, there are a number of abandoned
landfills and dumps, many on private property, within the Florida Keys. A comprehensive program needs to be
set up to locate, map, and evaluate these historic casual dump sites to determine if they contain hazardous materials
or are causing environmental problems.
Responsible Agency: The responsible agency should be Monroe County in conjunction with the FDER.
Implementation Mechanism: Monroe County already has a fairly complete inventory of historic landfill sites
within the Florida Keys. The old sites where significant amounts of casual dumping have taken place are less' all
known. This option would be implemented by searching historical data and conducting interviews with long- ne
residents to locate and map the potential problem sites. A one-time survey of all sites would then be made to x
if they are actually causing environmental problems. For those sites where problems are detected, or those that b ve
a high potential for causing problems in the future, long-term monitoring programs could be designed. If necessr y,
remedial actions could be taken.
Implementation Requirements: No new statutes or legislative authority are required for this option. All th: is
required is either a reassignment of agency management priorities (in the form of staff time dedicated to this is. 2)
or additional funding to hire new staff for this purpose.
6.2.2 Option L2 — Intensify Landfill Monitoring
Description: This option would involve intensifying the existing monitoring programs around landfills to ec re
that no leaching is occurring into marine waters. Old landfills that were never permitted and therefore hav ao
closure plans or closure permits would be identified and monitored, as appropriate. If problems were discovered,
appropriate remedial actions would be evaluated and implemented.
Rationale: Monitoring data from existing landfills in the Florida Keys do not indicate a leaching problem.
However, the number of monitoring locations is small and the number of locations should be increased to ensure
that no leaching is occurring around these landfills.
Responsible Agency: The responsible agencies should be the FDER and Monroe County.
Implementation Mechanism: Several activities need to take place to successfully and cost-effectively implement
this option. First, all closure permits for the existing landfills need to be reviewed to determine if their proposed
monitoring plans are adequate. Because almost all landfill areas in the Florida Keys are adjacent to marine waters,
monitoring programs should consider the study of adjacent marine waters and habitats for signs of contamination.
Closure permits should include an adequate number of paired monitoring wells with one drilled to shallow depths
and the other into deeper strata. A one-time, intensive baseline program should be conducted" immediately after
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closing a landfill. Then, depending on those results, a long-term, low-intensity monitoring plan should be put into
place. The need for additional manpower is unknown until an assessment of the adequacy of the closure permits
is completed.
Many of the old landfills in the Florida Keys were never permitted. Consequently, there are no closure plans or
closure permits. These landfills should be identified and monitored as well.
Implementation Requirements: No new legislative authority is required to implement this option. However, if
this option is to be implemented, it will require a shift in agency staff time and management priorities or additional
funding to hire more staff.
6.3 REMEDIAL ENGINEERING METHODS
Engineering methods for controlling pollutant migration from landfills are most effective when incorporated into
landfill design. Methods such as use of impervious bottom liners, leachate collection systems, leachate treatment
and disposal systems, and control of stormwater runoff from active and inactive areas are effective in controlling
pollution from landfills.
With inactive or closed landfills, the pollution control objectives are similar to those for new landfills, but the
objectives are much more difficult to accomplish. Containment or collection of leachate at landfills without a bottom
liner requires construction of slurry walls, collection trenches, wells (vertical or horizontal), or a combination of
these facilities. Leachate treatment is generally feasible, but the volume of groundwater treated is generally greater
than if it was collected above an impervious liner. Proper closure, including impervious top liner, vegetative cover,
gas venting, and stormwater control can significantly reduce the pollution potential of landfills that are not designed
to current standards. If proper closure and leachate containment or withdrawal/treatment are not sufficient to reduce
pollutant loadings from landfills, excavation of the site may be necessary.
Engineering methods for controlling the migration of pollutants from existing landfill sites are described below.
These methods may be used in future engineering options addressing pollution from landfills. They are included
here for discussion poses only, because existing landfill monitoring data have not indicated a need for remedial
action.
6.3.1 Boring or Mining
Landfill boring and mining are investigative procedures to determine the types of wastes or materials contained in
she fill. Use of either method is usually considered only when landfill monitoring data indicate that a significant
problems exists.
Landfill boring is analogous to soil boring investigations; samples of the fill can be collected and analyzed at discrete
depth intervals. Leachate entering the borehole can also be analyzed. Boring is of limited value in landfill areas
containing numerous large objects such as automobiles.
Landfill mining is a more intensive investigative procedure. Portions of the landfill are excavated and contents of
the fill are analyzed. A qualitative assessment of materials contained in the landfill is obtained, as well as soil and
leachate samples.
Landfill boring and mining can be useful for determining corrective methods that may be appropriate for a particular
landfill site. Either method should be used with caution because disturbing the landfill can, in some cases,
accelerate leachate generation by stirring up pollutants or releasing liquids from previously confined areas.
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6.3.2 Upgrading Landfill Closure
Closure of the older inactive landfill sites in the Florida Keys generally consisted of applying whatever local cover
materials were available. Little consideration was given to perviousness of the cover, grassing, or overall drainage
at the sites. Exceptions to this are the recently closed landfill sites at Stock Island, Long Key, Cudjoe Key and Key
Largo. Closure plans for these sites are nearly complete and all will include top liners and runoff control.
With older landfill sites, basic closure can usually be accomplished with minimal difficulty. This would include
re grading the site (which may require fill from off-site), installing an impervious top liner, gas venting, and runoff
control. If basic closure does not reduce leachate migration to acceptable levels, additional engineering methods
may be necessary.
6.3.3 Leachate Collection and Treatment
Leachate from the landfill can be captured through a subsurface collection system. A collection system containing
a series of horizontal or vertical perforated pipes designed to intercept leachate flow is installed around the landfill.
Leachate is then collected and pumped to a treatment facility, which reduces the contaminants to acceptable levels.
Treatment methods would depend on the specific types of contaminants to be removed.
6.3.4 Construction of Slurry Walls
Another method of containing leachate movement is by constructing slurry walls. Slurry walls are formed by
systematic pressure grouting. The grout is injected into a series of boreholes and the concrete forms a wall or
barrier in place. The use of slurry walls is a difficult and expensive, but effective option. Their use might be
limited because of the large areas and volumes of the landfills.
6.3.5 Excavation
Another possible remedial option is to relocate a landfill to a less environmentally sensitive area. The waste and
fill would be excavated and hauled offsite. With this method, it is possible to recycle and reclaim part of the waste
either before or after relocation.
7.0 HAZARDOUS MATERIALS STORAGE, TRANSPORT, AND SPILLS
7.1 INTRODUCTION
The Florida Keys are surrounded by environmentally sensitive marine resources. The handling, storing and
managing of hazardous materials in this type of environment poses a heightened level of risk. As described in the
Phase I report, small vessel spills, small facility spills, tanker tnlck spills, and leaching from underground storage
tanks do occur in the FKNMS. Because of the island structure of the Florida Keys, even small spills can potentially
have a significant impact on groundwater and siirface water contamination. In addition, there is a risk of
catastrophic oil spills from tankers passing through the Straits of Florida.
The present management arrangement appears to be functioning adequately; however, based on the interviews
conducted during the Phase II effort, there are some actions that could be taken to further reduce the potential for
accidental spills. These management options would enhance spill response efficiency, improve data documentation,
and heighten enforcement effectiveness.
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•	Option HI — Continue Response and Preparedness Planning
Continue current measures to improve response and preparedness planning. Expand the use of
interactive computer modeling as a decision-making tool for response scenarios (e.g., dispersant use
on oil spills). Bring more oil spill containment equipment into staging areas in or near the Sanctuary.
•	Option H2 — Improve Hazardous Materials Database
Improve recordkeeping and location mapping of all industries using or stockpiling hazardous materials
in the Florida Keys. Enter locations in the Monroe County GIS and tie into the Florida Emergency
Response Program in the Keys.
•	Option H3 — Improve Small Spill Reporting
Update and standardize criteria for documenting small spills. Establish a method of conveniently
tracking small spills within the Sanctuary.
•	Option H4 — Speed Up Storage Tank Inspection
Increase funding and personnel for the FDER Marathon District Branch Office and the Monroe County
Public Health Unit to speed up inspecting, enforcing, and retrofitting of surface and underground
storage tanks.
•	Option H5 — Change Environmental Crimes from Misdemeanors and Felonies to Civil Offenses
Change the environmental crimes category associated with small spills from a misdemeanor or felony
to a civil offense, thereby removing the need to prove criminal intent.
•	Option H6 — Increase Funding for Environmental Crimes Program
Increase the funding for and the status of the Environmental Crimes Program within both the Monroe
County Sheriffs Office and the FMP.
7.2 MANAGEMENT OPTIONS
7.2.1 Option HI — Continue Response and Preparedness Planning
Description: This option would continue current measures to improve response and preparedness planning; expand
the use of interactive computer modeling as a decision-making tool for response scenarios (e.g., dispersant use on
oil spills); and bring more oil spill containment equipment into staging areas in or near the Sanctuary.
Rationale: Some improvements could be made in spill response planning and preparedness with respect to (1) the
predetermined use of dispersants under specific conditions and (2) equipment in place to handle an oil spill.
Interactive modeling is an effective technique for developing and testing the decision-making process. Because the
FKNMS is an environmentally sensitive area with unique marine resources, techniques need to be implemented to
increase spill preparedness and reduce response time should a spill occur.
Responsible Agency: The responsible agency would be the USCG in coordination with the South Florida
Environmental Task Force and the Florida Emergency Response Program.
Implementation Mechanism: The interagency coordination mechanism to implement this option is already in place
and appears to be functioning well. Steps are already in progress to develop area-specific response plans for the
FKNMS. All that is necessary to implement this option are selected policy decisions on the part of the USCG and
representatives of the Florida Emergency Response Program.
Implementation Requirements: The USCG must designate specific sites within the Florida Keys as storage and
staging areas for spill response equipment. A USCG Marine Safety Office is also needed within the Keys, rather
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than in Miami as is the present situation. A Marine Safety Office once existed in the Keys; however, it receatiy
was closed because of budgetary cutbacks.
7.2.2 Option H2 — Improve Hazardous Materials Database
Description: This option would improve recordkeeping and location mapping of all industries using or stockpiling
hazardous materials in the Florida Keys. Locations would be entered in the Monroe County GIS and. tied into the
Florida Emergency Response Program in the Keys.
Rationale: The 1983 Water Quality Assurance Act required each county to conduct a local hazardous waste
assessment. The assessment provided an inventory of information on the quantity of hazardous waste generated by
both small and large quantity generators, and the management practices used by these generators. This is an
ongoing activity and information is updated annually. However, information regarding hazardous materials is
liminvl and needs to be expanded. Expansion of the	could help to answer questions about temporal or
spatial considerations, or compliance and enforcement efforts. Improvements in record keeping, inspections, and
mapping of all industries using or storing hazardous materials within the Florida Keys is needed. Existing Monroe
County programs need to be expanded and hazardous material locations entered on the Monroe County (and possibly
FDNR) GIS databases covering the Florida Keys and FKNMS.
Responsible Agency: The County through its Planning Department should have the responsibility; however, its
efforts must be coordinated closely with the FDER, FDHRS, and Monroe County Health Department.
Implementation Mechanism: Monroe County currently maintains lists of most businesses generating or using
hazardous materials in normal operations. These lists need to be reviewed and updated with the exact addresses
and geographic coordinates assigned so that they may be entered into the County's GIS and tied into the Flonda
Emergency Response Program in the Florida Keys. There is little additional expense associated with implementing
this option. Monroe County is already in the process of establishing a GIS, and the additional data can be entered
along with the other databases already planned. Updating and obtaining exact locations of businesses generating
or using hazardous materials can be done in conjunction with the normal licensing and inspection services performed
by the Monroe County Public Health Unit.
Implementation Requirements: Depending upon the time frame desired to implement this option, additional staff
at the County level may or may not be required. No additional legislative authority is necessary. Because Monroe
County is already establishing its GIS, no additional major capital outlay for equipment is required.
7.2.3 Option H3 — Improve Small Spill Reporting
Description: This option would focus more attention on the problem of small spills (e.g., petroleum products).
Criteria for documenting small spills within the Sanctuary would be updated and standardized.
Rationale: Small spills of petroleum products occur frequently in the Florida Keys and may be a significant factor
in degrading habitat quality within confined waters. More attention needs to be focused on this problem, and better
methods for documenting such small spills need to be developed to better understand the scope and severity of the
- problem. While some data is collected regarding spills, many experts during Phase 1 testified that there is a need
for substantial improvement in spill documentation. Establishing a comprehensive database could help to answer
questions about temporal and spatial considerations, severity, major spill constituents, water quality effects, and
compliance and enforcement efforts. This would enable those responsible for responding to such events to have
a better understanding and increase the speed and effectiveness of the cleanup effort.
Responsible Agency: The responsible agency would be the FDNR through its Office of Coastal Protection.
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Implementation Mechanism: The FDNR is already moving toward adopting this option. The FDNR has now
established the Office of Coastal Protection (moving this program from the FMP) and has developed new and more
effective reporting forms for use in the field. The FDNR, primarily through its Marine Patrol District
Commanders, needs to stress the importance of gaining accurate information of all reported small spills to field
officers.
Implementation Requirements: No new legislation or policy is required to implement this option. The importance
of completely and accurately filling out the new Pollution Discharge Reports and investigating all small spills to the
wMTimnm extent possible must be stressed. This is essentially the responsibility of the Commanders of the various
FMP districts, but a coordinated program between the Office of Coastal Protection and the FMP environmental
crimes offices explaining the importance of the small spill reporting program would be the best way to achieve
maximum cooperation at the patrolling officer level.
If data collected by the small spill reporting program are to be used effectively, additional computerization of the
database, must be undertaken by the Office of Coastal Protection. Information to identify hot spots of possible
petroleum pollution needs to be available on a HataKao management system. Such data would also make it possible
to identify chronic offenders, such as marinas where a high number of small spills occur, for corrective action.
7.2.4 Option H4 — Speed Up Storage Tank Inspection
Description: This option would speed up existing efforts to inspect and retrofit surface and underground fuel
storage tanks and to clean up contaminated areas. It would increase funding and the number of personnel available
to the FDER Marathon District Branch Office and Monroe County Public Health Unit to speed up inspection,
enforcement, and retrofitting.
Rationale: This program currently exists and is functioning well. With increased funding, the overall objective
of inspecting and retrofitting fuel storage tanks throughout the Keys could be accomplished more quickly.
Responsible Agency: The responsible agency should be the FDER. Inspection and compliance is subcontracted
to the FDHRS through the Monroe County Public Health Unit.
Implementation Mechanism: This program already exists and appears to be functioning well. Interagency
coordination is reported to be good. This option only requires additional funding for implementation.
Implementation Requirements: The key to accelerating the inspection program is funding. With increased
funding, the existing inspection staff could be augmented, thus increasing the rate of storage tank inspections. The
benefit of implementing this option is that the inspection, retrofitting, and cleanup of contaminated sites could be
accomplished more rapidly.
7.2.5 Option H5 — Change Environmental Crimes from Misdemeanors and Felonies to Civil Oflenses
Description: This option would change the environmental crimes category associated with small spills from a
misdemeanor or felony crime to a civil offense, thereby removing the need to prove criminal intent.
Rationale: Currently, it is difficult to prove criminal intent for actions such as accidently discharging fuel or
pumping out a shipboard sewage holding tank. Therefore, in practice, law enforcement officers focus more
attention on other crimes that require a less rigorous burden of proof. By shifting environmental crimes from being
a misdemeanor or felony crime to a civil offense, an increased level of enforcement of environmental laws could
be expected. This conclusion was supported by the law enforcement community in the Florida Keys. Civil penalties
could take the form of major fines for such accidents without considering the intent of the individual involved.
Major fines would encourage chronic offenders to be more careful.
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Before revising any Florida Statutes specific to environmental crimes, careful consideration needs to be taken before
changing it from a misdemeanor or felony crime to a civil crime. There needs to be avenues to prosecute serious
repeat offenders under criminal penalty. In addition, fines collected for environmental crimes should be redirected
to where the violation occurred and used to restore the resource that was damaged.
Responsible Agency: The responsible agency should be the FDNR through the FMP.
Implementation Mechanism: This option would require changes in the Florida Statutes and the Florida
Administrative Code.
Implementation Requirements: Implementation of this option would require changes in Florida legislation. Mr.
Billy Causey (NOAA FKNMS, personal communication, 1992) has pointed out that FKNMS public laws involving
environmental crimes are already civil rather ปhปn felony statutes. Therefore, cross-deputization of FKNMS officers
and Florida law enforcement officers may be a simpler way of achieving the same goal. However, there is no
guarantee that fines assessed under Federal Statutes would be returned to Florida or to the FKNMS itself. Under
current policy, fines assessed under federal statutes are not returned to the specific slate where the offense took
place. The question of who receives fines assessed for environmental crimes in Florida and the FKNMS needs to
be resolved if the cross-deputization route is chosen for implementing this option.
7.2.6 Option H6 — Increase Funding for Environmental Crimes Program
Description: This option would seek to reduce pollution by enhancing the existing Environmental Crimes Program.
Through a process of increased funding and public education, environmental crimes enforcement efforts would be
made more visible in the Sanctuary.
Rationale: Within Monroe County there has been an effort to heighten the awareness and effectiveness of enforcing
environmental laws and regulations. This new emphasis is reflected by the creation of an interagency Environmental
Crimes Task Force (representation consists of all law enforcement organizations in the Florida Keys), and the
creation of a specialized environmental section within the FMP Marathon District office. These programs could
be expanded through NOAA funding. In addition, the status of environmental crimes as a law enforcement priority
within the Florida Keys should continue to rise in importance with both officers and the general public.
Responsible Agency: The FDNR and Monroe County, as the agencies responsible for the FMP and Monroe
County Sheriffs Department, would take the responsibility in implementing this option. Environmental crime is
such a key area of law enforcement within the FKNMS that NOAA should aid in implementing this option through
"pass-through" funding and any other means available.
Implementation Mechanism: The Monroe County Sheriffs Department Environmental Crimes Task Force and
the FMP District 9 Environmental Crimes Program are working well in coordinating efforts with other agencies
responsible for enforcing environmental law within the Florida Keys (U.S. Fish and Wildlife Service [FWS], FDER,
FDHRS, etc.). Through a process of public education, increased funding, and increased visibility, environmental
crimes enforcement efforts need to become more visible in the FKNMS.
Implementation Requirements: The Monroe County Sheriffs's Department, FMP, and NOAA need to coordinate
efforts and work out details for heightening the Awareness of the importance of preventing environmental crimes
both among individual law enforcement officers and among the general public. Enforcement procedures and funding
for presenting enviromnental crimes should be divided among local, state, and federal agents to achieve maximum,
use of existing infrastructure without duplication of effort.
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8.0 MOSQUITO CONTROL PROGRAM
8.1 INTRODUCTION
As described in the Phase I report, ground spraying by truck is the present method of choice for controlling the
adult mosquito population in Monroe County. Aerial spraying is used only when the mosquito population reaches
a specific threshold as determined by mosquito landing counts per minute at given test sites within the County. The
Mosquito Control Program is administered by the Monroe County Mosquito Control District.
There are no data indicating that the Mosquito Control Program is causing water quality problems in the FKNMS.
However, there is little existing information on environmental concentrations and/or effects of pesticides in the
FKNMS. Additional data concerning pesticide concentrations in sediments and biological tissue throughout the
FKNMS will be collected through the Water Quality Monitoring Program (Task 6). In addition, the Research
Program (Task 7) includes proposed.research on biological effects of water quality parameters, including pesticides.
These monitoring and research efforts should show whether mosquito spraying is affecting water quality or
biological resources in the FKNMS.
Based on the considerations discussed above, options for major changes to the Mosquito Control Program are not
appropriate at this time. Additional data from the monitoring and research programs will help to determine whether
major changes are warranted. Two mutually exclusive management options are presented below — one to continue
the existing program with refinements, the other to temporarily ban aerial spraying while pesticide effects are
studied:
•	Option Mia — Reduce Aerial Spraying Over Marine Areas
Refine the aerial spraying program to further reduce aerial spraying over marine areas. This includes
a review of threshold levels used to initiate aerial spraying, development of a more refined plan for
flight lines, and use of improved equipment. Further, as is done in nearly all Florida counties,
eliminate thermal fog for aerial spraying and replace it with one known as ultra low volume (ULV).
Reconsider the use of mosquito larvicides in breeding areas, including those in currently restricted
areas, to reduce the need for aerial spraying of adult mosquito populations.
•	Option Mlb — Temporarily Ban Aerial Spraying
Ban all aerial spraying of mosquito adulticides for a 2-year period (with exceptions in the event of a
health emergency) to collect and review data on both mosquito populations and pesticides appropriate
for use in the Sanctuary and around sensitive terrestrial arthropod and gastropod populations. Modify
the Mosquito Control Program on the basis of research findings as necessary.
8.2 MANAGEMENT OPTIONS
8.2.1 Option Mia — Reduce Aerial Spraying over Marine Areas
Description: The Monroe County Mosquito Control Program would be refined to minimize spraying of marine
areas. This could include switching from thermal fog to ULV, reviewing (and possibly raising) threshold levels
used to initiate aerial spraying, and purchasing equipment to give pilots better navigational control and faster
response time in shut-ofF mechanisms for adulticide release. In addition, all agencies involved in mosquito control
would reconsider using ground spraying of mosquito larvicides in breeding areas, even those on state and federal
lands.
Rationale: Although the Monroe County Mosquito Control District attempts to avoid marine areas when aerially
spraying, it is believed that with a more refined plan for flight lines and use of improved equipment, the amount
of spray released over water could be reduced. The agency could also reduce aerial spraying over marine areas
by reviewing the statutory threshold for initiating aerial spraying. If a change would be warranted,-legislation would
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need t) be enacted to modify the threshold. Presently, Monroe County is one of the only counties in Florida still
aerial spraying utilizing the thermal fog technique. Most counties now employ the ULV technique. By switching
techniques, the fog oil and diesel fuel that is presently mixed with the Dibrom would be completely eliminated,
although the amount of insecticide will remain the same. Dr. John Mulrennen of the Florida Department of
Agriculture and Entomology indicated that Dibrom by itself decomposes rather quickly. However, when combined
with diesel fuel and fog oil, the insecticide remains in the environment longer. Thus the benefit would be two-fold:
less toxics would enter the coastal waters and the insecticide would decompose more rapidly. Because Dibrom is
clear, unlike the thermal fog which leaves a cloud, a training program would be needed to allow the pilots working
for the District to work with pilots experienced in ULV applications.
Responsible Agency: The responsible agency for refining the aerial spraying program should be Monroe County
through the Mosquito Control District. For a reconsideration of Iarvicide use, the FDCA should be the responsible
agency to coordinate affected agencies. The Florida Department of Agriculture Bureau of Entomology and Pest
Control should organize and present data on available larvicides and the desirability of using larvicides in state and
federal lands currently off-limits to mosquito control. State agencies that will need to be involved in this decision
include the Monroe County Mosquito Control Program, Florida Department of Parks, and Bureau of State Lands.
An additional group that should be represented at such discussions is the Citizens of Monroe County.
Implementation Mechanism: The implementation mechanism for refining the aerial spraying program is policy
review and planning by the Monroe County Mosquito Control District. For a reconsideration of Iarvicide use. one
key agency needs to organize a meeting to discuss this issue. The FDCA is recommended because of the
overview-type function it serves in coordinating various state agencies responsible for the comprehensive planning
process. The FDCA has functioned as an interagency coordinating group on Florida Keys issues in the past. It
is mandatory that the Florida Coordinating Council on Mosquito Control be involved in this effort because the group
has the greatest amount of technical expertise with mosquito control matters.
Implementation Requirements: Following a review by the Mosquito Control District, some additional equipment
may need to be purchased to give pilots better navigational control when on a designated flight line, and fast
response time in shut-off mechanisms for adulticide release.
8.2.2 Option Mlb — Temporarily Ban Aerial Spraying
Description: Aerial spraying of mosquito adulticides would be banned for a 2-year period (with exceptions in the
event of a health emergency) in order to collect and review data on both mosquito populations and on pesticides
appropriate for use within the FKNMS and around sensitive terrestrial arthropod and gastropod populations. The
Mosquito Control Program would be modified as necessary on the basis of research findings.
Rationale: There are a number of pesticide-sensitive arthropod and gastropod species living in the Florida Keys.
Aerial spraying of mosquito adulticides would be stopped for 2 years to review the possible adverse effects that
pesticides may have on these populations. This moratorium on aerial spraying may also be used to review other
possible control strategies in areas currently off-limits to mosquito control.
Responsible Agency: The FDER should take the responsibility in requesting the 2-year ban. The Florida
Department of Agriculture Bureau of Entomology and Pest Control should coordinate pesticide review and
evaluation with the FDER, while the FDCA and Monroe County Mosquito Control District should work together
to evaluate alternative methods of mosquito control.
Implementation Mechanism: The proposed ban would have to be requested by the FDER and approved by the
Bureau of Entomology and Pest Control as well as the Monroe County Mosquito Control District. The FDHRS,
through the Monroe County Public Health Unit, would have the authority to declare a health emergency and request
the Mosquito Control District to begin aerial spraying again.
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Implementation Requirements: The purpose of this proposed 2-year ban or moratorium on aerial spraying is to
evaluate possibly threatened species populations and to conduct research in more environmentally sound methods
of mosquito control in the Florida Keys. If this ban is to be beneficial, specif1 research projects addressing the
stated problems need to be designed and funded as part of the Research Progrv i (Task 7).
9.0 FLORIDA BAY/EXTERNAL INFLUENCES
The Phase I report indicates that there are potentially significant external influences on water quality in the
Sanctuary. Potentially significant influences in terms of advection (water transport) include Florida Bay, Biscayne
Bay, and the Florida Current. In addition, atmospheric loadings could be a substantial contributor to the nutrient
budget. These external influences require further study, and are therefore included in the Research Program
described under Task 7. However, the need for action to deal with water delivery problems in Florida Bay has been
strongly stressed by workshop participants and other scientists during the development of the Water Quality
Protection Program. Therefore, a management option for working to restore freshwater flow to Florida Bay is
included here. In addition. Task 7 includes proposed research to further document the influence of Florida Bay on
water quality and biological resources in the Sanctuary. This research should supply additional scientific evidence
to support the need for action.
• Option El — Restore Freshwater Flow to Florida Bay
The Steering Committee for the Water Quality Protection Program should take a leading role in
restoring historical freshwater flow to Florida Bay. In addition. Sanctuary representatives should work
with appropriate federal, state, and local agencies to ensure that restoration plans and surface water
improvement and management plans for South Florida and the Everglades are compatible with efforts
to maintain water quality within the Sanctuary.
Description: Under this option, the Steering Committee for the Water Quality Protection Program would take a
leading role in water management issues affecting Florida Bay. The Steering Committee includes high-level
representatives of all relevant agencies dealing with these water management issues. In addition, the FKNMS
Advisory Council would state clearly its concerns over the issue of freshwater allocations to Florida Bay to the
Governor and Cabinet of the state of Florida as well as state and federal agencies. Both short- and long-term
solutions would be pursued at high levels of management in both state and federal agencies.
Also under this option, Sanctuary representatives would participate in the review and revision of restoration plans
and water management plans for Florida Bay and adjacent areas to ensure that these proposals and/or actions will
enhance and complement water quality improvement efforts undertaken in the Sanctuary. These plans include, but
are not limited to. the Shark River Slough GDM, C-lll basin, Taylor Slough Restoration. West Dade Wellfield,
U.S. 1 widening, National Park Service Everglades Restoration Plan, Lower East Coast Water Supply Plan, and
Everglades Surface Water Management and Improvement Plan.
Rationale: Severe water quality and ecological problems have developed in Florida Bay in recent years. Problems
include a massive seagrass die-off, phytoplankton blooms, sponge die-offs, mangrove die-backs, and all of the
potential cascading ecological effects of these phenomena. Since 1987, much of Florida Bay has been affected by
a massive, unprecedented seagrass die-off that has left tens of thousands of acres of denuded sediments. Through
the resulting sediment resuspension and nutrient release, the seagrass die-off may be the cause of massive
phytoplankton blooms that have affected the Bay during recent years. Sponge die-offs caused by phytoplankton
blooms may have serious impacts on juvenile spiny lobsters, which reside by day under sponges for protection from
predation.
Many experts believe that recent ecological problems in Florida Bay are the result of long-term reduction in
freshwater flow from the Everglades. The mechanism has not been documented, but high salinities per se and a
long-term change from an estuarine to a marine system may be contributing factors.
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These problems in Florida Bay must be viewed as a potential threat to water quality and resources in the Sanctuary.
Water quality and natural resources in Florida Bay are tightly linked to those of the Sanctuary. The Florida Institute
of Oceanography haa documented boluses or filaments of Florida Bay water, identified by slightly elevated
temperature and salinity, moving across Hawk Channel onto the reef tract. The indications of these filaments are
sporadic, and there does not appear to be a regular stream of Florida Bay water across Hawk Channel. According
to coral expert Dr. James Porter, this water may be contributing to coral declines on the reef tract, but the degree
of stress is unknown at this time.
Responsible Agency: The responsible agencies will be EPA and FDER, which administer the Water Quality
Protection Program. NOAA will have a primary role because of its overall responsibility for managing the
Sanctuary. All other agencies represented on the Steering Committee will have a primary role. These are the
National Park Service, FWS, U.S. Army Corps of Engineers (USACE), FDCA, SFWMD, and FKAA.
Implementation Mechanism: This option could be implemented by actions of the Steering Committee for the
Water Quality Protection Program. Because the Steering Committee includes high-level representatives of all
relevant agencies, it could therefore take a leading role. The Steering Committee may also need to designate
individuals or a subcommittee to participate in various discussions regarding individual restoration plans and surface
water improvement and management plans. NOAA's FKNMS Advisory Council would take the lead in presenting
concerns about water management issues to the Governor and Cabinet of the state of Flonda.
Implementation Requirements: Both the Steering Committee and the Advisory Council are existing entities.
Additional costs and staffing requirements for representing the Sanctuary's concerns about water management issues
and Florida Bay are expected to be minimal.
10.0 REFERENCES
Antonini, G.A., L. Zobler, H. Tupper, and R. Ryder. 1990. Boat live-aboards in the Florida Keys: a new factor
in waterfront development. Fla. Sea Grant Rep. No. 98.
EPA. 1990. Biological Criteria: National Program Guidance for Surface Waters. U.S. Environmental Protection
Agency, Criteria and Standards Division, Office of Water Regulations and Standards, Washington, DC.
EPA-440/5-90-004. 57 pp.
EPA. 1992. Water Quality Protection Program for the Florida Keys National Marine Sanctuary: Phase I Report.
Final report submitted to the Environmental Protection Agency under Work Assignment 3-225, Contract
No. 68-C8-0105. Battelle Ocean Sciences, Duxbury, MA and Continental Shelf Associates, Inc., Jupiter,
FL.
Fanning, K. 1992. Atmospheric deposition. Pp. 2-11 to 2-18 in Tampa Bay National Estuary Program, review
of Tampa Bay information for interim nutrient budgets and historical loadings of bay segments. Final
Report. Tech. Publ. No. 03-92. St. Petersburg, FL.
Keating, D. 1992. Decline of corals blamed on b&y. Miami Herald, September 29, 1992, page Bl.
Solin. 1991. City of Key West Comprehensive Plan: Data Inventory and Analysis. Solin and Associates, Inc.
Swarthout. 1992. 1990 Comprehensive Plan for the City of Key Colony Beach. Robert K. Swarthout, Inc.
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Wallace Roberts & Todd; Barton Aschman iAssociates, Inc.; Haben, Culpepper, Dunbar & French, P. A.; Henigar
& Ray; Keith and Schnars, P.A.; and Price Waterfaouse. 1991. Monroe County Year 2010
Comprehensive Plan, Working Paper 2. Inventory and analysis, proposed levels Of service, measures of
carrying capacity. Prepared for Monroe County Board of County Commissioners.
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APPENDIX A
Pollution Source Inventory and Loadings

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POLLUTION SOURCE INVENTORY AND LOADINGS
A.1 BACKGROUND AND APPROACH
An extensive inventory of existing pollution sources in and adjacent to the Florida Keys National Marine Sanctuary
(FKNMS) is given in Task 2, Section 3.0 of the Phase I report. This Phase II pollution source inventory
summarizes that information and provides additional information on the operational characteristics and pollution
potential of each source. The Phase I pollution source inventory was updated concurrently with the preparation of
this Appendix.
Pollution sources can be categorized as either point sources or nonpoint sources. Point sources are generally defined
as pollutants emanating from a single location or point. Examples are discharges from pipes or other outlet
structures, such as domestic wastewater treatment plants (WWTPs), and stormwater from an outlet structure, ditch,
or canal. Nonpoint pollution sources are more diffuse and enter a receiving body over a widespread and often
undefinable interface or boundary. Examples of nonpoint pollution sources are sheet flow runoff, atmosphenc
deposition, nutrient loadings from aquatic vegetation die-off, and all groundwater discharges. Though some
groundwater discharges originate at a single point (e.g., an injection well), the discharge to a receiving water body
is diffuse and influenced by a number of variables.
Pollutants discharging to surface waters from both point and nonpoint sources can be grouped into six general
categories: nutrients, oxygen-demanding constituents, toxic constituents, sediment, salinity changes, and thermal
changes. Nitrogen and phosphorus are the major nutrients required for plant growth and one or the other is
typically the limiting nutrient in marine or aquatic systems. Marine systems within the FKNMS are phosphorus
limited. Nutrients can degrade water quality by stimulating algal blooms, which in turn can create toxic by-
products, increase turbidity, and deplete oxygen as they decay. The presence of oxygen-demanding constituents
in a discharge is measured as biochemical oxygen demand (BODj) or chemical oxygen demand (COD). With
significant amounts of BOD or COD in a discharge, biochemical or chemical processes will exert that demand and
result in lower levels of dissolved oxygen (DO) in the water column. Sediment is generally associated with
stormwater discharges and its harmful effects include increased turbidity, decreased light penetration, and covering
of benthic flora and fauna. Toxic constituents can be present in any discharge, and estimating effects or loadings
requires site-specific data for specific toxic compounds. Salinity is a consideration for freshwater or hypersaline
discharges into marine waters, where some marine flora and fauna have a narrow range of salinity tolerance.
Thermal pollution is the result of elevated temperature in process or cooling waters and can stimulate algal blooms
or affect the distribution of species with narrow ranges of thermal tolerance.
For each source identified in this report, loadings are quantified for only those pollutants that are of primary concern
with respect to adverse effects on receiving water quality, and that can be estimated by reliable means. This
approach lays the groundwork for the subsequent development of engineering options that focus on removal of the
most significant pollutant loadings associated with the various sources. Targeted pollutant categories associated with
the two major source categories are:
Toxic constituents in stormwater runoff have a relatively high potential for adversely impacting nearshore marine
waters, particularly in confined areas. However, because of the great variety of toxic materials, the wide range of
concentrations at which specific constituents are toxic, the high variability from site to site, and the lack of
significant stormwater data in the Keys, toxic loadings cannot be quantified with any degree of confidence. Toxic
materials are not targeted for pollution sources other than stormwater because there are no data indicating significant
or persistent toxicity problems associated with those sources. Oxygen demand is not targeted because oxygen
depletion has not been demonstrated to be a significant problem, with the possible exception of some confined
waters. There is only one cooling water discharge identified within the FKNMS (Stock Island Steam Plant), and
Source Category
Domestic wastewater
Stormwater
Pollutant Category
Nutrients
Sediment, Nutrients, (Toxic constituents)
3A-1

-------
it has not been demonstrated to have adverse thermal or toxic impacts on receiving waters. Toxicity testing will
be required with the pending Florida Department of Environmental Regulation (FDER) permit for the Stock Island
Steam Plant. No adverse salinity effects have been attributed to discharges originating within the FKNMS.
Calculations of nutrient loadings from various groundwater pollution sources in the following sections assume that
no significant attenuation of nutrients occurs in the shallow surface soils or underlying limestone formations. While
there is some evidence that certain forms of phosphorus are absorbed within the limestones, the evidence is not
conclusive and the overall, long-term retention of phosphorus within the formation has not been shown to be
significant.
The Monroe County Year 2010 Comprehensive Plan divided unincorporated Monroe County into 22 "Planning Area
Analysis/Enumeration Districts" (PAEDs), shown in Figures A-l through A-3. These PAEDs are utilized to
distribute population and wastewater flows for the pollutant loading estimates in this section.
A.2 POINT SOURCES
Point sources addressed in this section are limited to regulated (permitted) point sources. All significant point
sources are assumed to be regulated. Numerous, small, unregulated point sources associated primarily with local
drainage, swimming pool overflows, etc. are certain to be present throughout the Florida Keys. Identification or
characterization of these minor point sources is not within the scope of this report. The great majority of
unpermitted point sources are believed to be associated with stormwater. Loadings of sediment and nutrients from
these point sources are included with overall nonpoint source stormwater loadings for the Keys, discussed in Section
AJ.2 of this appendix.
Twenty-four point sources were inventoried in the Phase 1 report (see Phase I report, Tables 2-2 and 2-3). All of
these facilities were identified through their National Pollutant Discharge Elimination System (NPDES) permits.
Of the 24 permitted facilities, 10 are institutional, municipal, or tourist-related wastewater facilities; 6 are federal
(U.S. Coast Guard or U.S. Navy) facilities, and 8 are commercial/industrial facilities. Only 19 of the 24 facilities
were actively discharging as of November 1991, and several of these were planning to cease surface water
discharges in the near future.
With the exception of the Key West WWTP and the Key West Utilities Stock Island Steam Plant, all of these 24
surface water discharges are relatively small. The Key West WWTP reports a flow range of 5.6 to 7.5 million
gallons per day (MGD). The Stock Island steam facility is a cooling water discharge with flows in the 15 to 36
MCD range. Of the remaining 22 facilities, only five discharges are in excess of 0.1 MGD.
A.2.1 Domestic Wastewater National Pollutant Discharge Elimination System Discharges
The Phase I report identified five non-federal and five federal facilities that discharge treated domestic wastewater
to surface waters. These facilities typically use the extended aeration or contact stabilization activated sludge
process to treat wastewater to meet secondary standards (mean annual BOD and total suspended solids (TSS) of
effluent less than 20 mg/L). The total average daily flow for the 10 facilities is 6.9 MGD. The Key West WWTP
and U.S. Navy Sigsbee Park WWTP (soon to be connected to the Key West WWTP) account for 6.6 MGD, or 94%
of the total combined flow. Of the remaining 8 facilities, only the Key Colony Beach WWTP (0.175 MGD) and
U.S. Navy Boca Chica WWTP (0.131 MGD) exceed 0.035 MGD flow. Typical effluent quality and loading rates
for the 10 domestic wastewater facilities that discharge to surface waters are shown in Table A-l.
3A-2

-------
tty of
ey West


* J
o •*ป."* ^
\ •?
n
. #
i
J3oco ChicQ Key
K
' At" Cappttt
y
y
.ซ? • / •
•	> l''
4.ฐ/j
i,
Cud/00
<€/
Lower Svgorloaf Keyj
\Summeriondl
Key'
O Ramrod^
Kty ซo
\
*7)

Big Pine
Key
ฆ Bohio Honda Key
\
5,
Lower Keys
Rn..rซ *-i Mnnrw Cnnntv pinnnin* Area Analysis/Enumeration Districts - Lower Keys (Scale: 1" ฆ 6000').

-------
Upper Keys
Figure A-3. Monroe County Planning Area AnaJjrsis/Ei ition Districts - Upper Keys (Scale: 1" ฆ 6000').

-------
ITIn	ฆ?..	nป	ป 1
Middle Keys
ฆ	ฆ II. — (Rrr* - *ฆ m

-------
Table A-l. Summary of estimated pollutant loadings from sanitary
WWTPs discharging to surface waters within the FKNMS.'
PAED0
Kay Anas
Namhor of
WWTP.
Total Deafo Total
Capacity' Average
EAinj
dad Pollutant ]
(fee/day)*1
1 —|




(MCD) (MGD) TSS
BOD
NHj-N
NO3-N
1

LOWER KEYS






NA
City of Key Weal
4
10.627 6.112 440
329
109
98
137
1
Stock Ishad. Cow & Key Haven
0





2
Boca Chica. Portland. Bi| Coppn & Geifer
1
0.400 0.131 22
22
}
IS
9
)
Saddlebuncb. Upper A Lower Sufarloaf
0





4
Cudjoe. Summerlaod. Ramrod. Torch Kcya St No Name
Keya
1
0.070 0.031 6
6
1
10
2
5
Big Pine Key
1
0.002 0.001 neg.e
e
KM C


6
Spanish Harbor. Bahia Hoada. Ohio. Moaoun. Little Duck
6 Pigesa
0






SUBTOTAL
7
11.099 6.747 461
357
IIS
146
I4S

MIDDLE KEYS






7
Knight Vaca (Marathon). Stirrup & Boot
1
0 003 0.002 0.3
0.3
0.1
06
0.1
ป
Frt Deer (including Coca Phim). Crawls & Li ale Crawl
1
0 200 0.175 29
29
7
51
12
9
Ciiasy
0





10
Duck A Coach
0





11
Lco( A Fiesta
0





12
Lower Malccumbe. Cmg A Wind ley
0





11
Upper Matacinbe
0






SUBTOTAL
2
0.201 0.177 29
29
7
SI
12

UPPER KEYS






14
Planminn
1
0.005 0.002 0.1
0.1
0.1
0.6

13
Lower Key Largo (Taveraier)
0





16
Key Largo (Dave)
0





17
Key Largo (Rock Harbor)
0





IS
Key Largo (Tarpon Baain)
0





19
Key Largo (Largo Sound)
0





20
Key Largo (Blackwater Sound)
0





21
N. Key Largo (Pott Bouganvdle to AngclTiah). Cape Sable
0





22
Craaa Key to Dade County Line
0






SUBTOTAL
I
0.005 0.002 0.3
0.3
0.1
0.6
0.1

TOTAL
10
11.107 6.926 497
1ซ6
122
199
160
NA: Not applicable
"Recent mfonnatiaa	from FDER indicates that then are 250 active WWTP permits m the Keys and another 20 facilitie* that an permitted but oo< oo line. Upon rccervmf
appropriate FDER docunentaitoa refexdinf the number of WWTPs and cormpoodinf flow, th* table may be revised accoidiogly.
^Ptaoaoig Ana Aoaiyi a/Enumeration Dntnct aa rirlinratrrl ia Moaroe County Year 2010 Comprehensive Ptaa
'Source: City o{ Key Wert Comprehensive Ptaa and Moaroe County Year 2010 Comprehensrve Plaa
^F—Mr-'-	Bw Aseunud pollutant concentrations discharged lo aurface water arc
Ajaumad Cosceotratioa
Polhlaal Cily of Key Wart WWTP.	Macro* Cou*y WWTP.
TSS	8	20
BOD	6	20
2	I
I.S	3}
2.3	I
Source City of Key Wert Comp. Plan FKNMS Fhaae I Report. Table 2-6
'Negligible
3 A-6

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A.2.2 Other National Pollutant Discharge Elimination System Discharges
Other (non-domestic) NPDES wastewater discharges are identified as "Industrial" discharges in the Phase I report
(Table 2-2), with the exception of the U.S. Naval Air Station Key West facility ("federal" designation). Of the
seven non-domestic NPDES discharges, four have ceased surface water discharge or have never discharged, two
provide emergency or stormwater discharges, and one (the Key West Utilities Stock Island Steam Plant) discharges
regularly (see Phase I report. Table 2-3). The desalination plant brine discharge from the Ocean Reef Club (0.287
to 0.411 MGD) is the most.recent NPDES discharge that has been eliminated. That facility now discharges to Class
V injection wells (boreholes).
The Stock Island Steam Plant utilizes shallow saline groundwater for cooling purposes and discharges between 14.8
and 36.0 MGD. Water quality data for this discharge do not indicate any significant potential for adverse toxic or
thermal effects. The pending FDER permit for this facility will require toxicity testing quarterly for the first year
to further evaluate potential toxicity associated with this discharge.
A.2.3 Stormwater Discharges
Point source stormwater discharges consist of outlet structures associated with South Florida Water Management
District (SFWMD) surface water management permits and unpermitted stormwater discharge structures. The Phase
I report listed 58 SFWMD surface water management permits in unincorporated Monroe County and summarized
location, acreage, land use, and receiving water bodies for 47 permits located in SFWMD files (see Phase 1 report.
Table 2-14). Listed acreages ranged from less than one acre to 197 acres. No water quality or discharge quantity
data were available for these point sources.
In addition to SFWMD-permitted stormwater facilities, there are numerous unpermitted culverts and other control
structures discharging stormwater into the FKNMS. No records of structure types, numbers, or drainage areas
served are available for these structures.
The City of Key West Comprehensive Plan indicates that approximately 37 stormwater outfalls serve the city's
drainage system (see City of Key West Comprehensive Plan, Map IV-3). No information is available at this time
on drainage areas or water quality for these outfalls. Several SFWMD surface water management permits exist
within the City of Key West, but information on these permits was not obtained. The total area served by these
permits is relatively small.
Because of the lack of adequate data for point source stormwater discharges, no attempt was made to specifically
quantify pollutant loadings from these sources. A general analysis of stormwater nutnent loadings for the entire
Keys is discussed in Section A.3.2 of this appendix.
A.3 NONPOBMT SOURCES
Nonpoint sources of pollution affecting the FKNMS include sources that are internal and external to the FKNMS.
Each source can be further categorized as anthropogenic (man-induced), natural, or a combination of anthropogenic
and natural inputs. The discussion in this section deals with anthropogenic, internal, nonpoint sources. These
include Class V injection wells (boreholes), absorption fields, cesspits, stormwater runoff, waste discharges from
boats, mosquito spraying, landfills, and spills of toxic or hazardous materials. Detailed descriptions of these sources
are given in Task 2, Section 3.2 of the Phase 1 report.
Additional internal nonpoint pollution sources that may be significant from an overall loading standpoint include
atmospheric deposition and release of nutrients into the water column from decomposition of organic material. Data
are not available to quantify inputs from these sources.
3A-7

-------
External nonpoi jt pollution sources potentially affecting the FKNMS include freshwater discharges from mainland
Florida (e.g., Canal-111 and Model Land Canal), marine waters surrounding the FKNMS, and atmospheric
deposition from frontal or other regional air mass movements. Marine waters with significant potential for affecting
water quality within the FKNMS include Florida Bay, Biscayne Bay, the Gulf Stream, and nearshore ocean waters
of the lower east coast and lower west coast of Florida. Data are not sufficient to allow characterization of pollutant
loadings from these potential pollution sources.
A.3.1 Groundwater Discharges
AJ.1.1 CLASS V INJECTION WELLS
The Phase I report indicates that 557 Class V injection wells, commonly referred to as boreholes, are used for
wastewater and stonnwater disposal within the FKNMS. A typical borehole is an 8-in. diameter hole drilled to a
total depth of 60 to 90 ft and cased to a depth of 30 to 60 ft. Current FDER rules require boreholes to be drilled
to a depth of 90 ft and cased to 60 ft. All boreholes are permitted by the FDER. Of the 557 permitted boreholes
in July, 1992, 324 were used by package wastewater treatment plants, 186 by aerobic on-site sewage disposal
systems (OSDS), 43 for stormwater disposal, and 4 for laundry waste disposal. Since these figures were tabulated,
the Ocean Reef Club desalination plant brine discharge (0.287 to 0.411 MGD) has been converted from surface
water discharge to borehole discharge.
According to the Phase I report, there are 209 wastewater treatment facilities operating within close proximity to
the FKNMS (see Phase I report. Table 2-5 and note below), 199 of which discharge to groundwater via 324
boreholes. The remaining 10 plants discharge to surface waters and are discussed in Section A.2.1 of this appendix.
In addition to these facilities in unincorporated Monroe County and Key Colony Beach, there are seven active
package plants within the City of Key West that discharge to groundwater. A summary of estimated pollutant
loadings for all 199 wastewater treatment plants discharging to groundwater is given in Table A-2. Total estimated
nutrient loadings for these plants are 152 lbs/day orthophosphate, 96 lbs/day ammonia nitrogen and 660 lbs/day
nitrate nitrogen.
Class V injection wells are also used as an effluent disposal method for 186 aerobic OSDSs. Each aerobic OSDS
is typically served by a single borehole. With the exception of two boreholes in Marathon and eight in Tavemier,
all boreholes serving aerobic OSDSs are located in the Big Pine Key to lower Sugarloaf Key area. This area
corresponds to Monroe County PAEDs 3, 4, and 5. Pollutant loading associated with aerobic systems discharging
to boreholes is included with overall OSDS loadings discussed in the following section.
Note: Information received in FDER comments on the Phase I report indicates that there are 270 WWTP permits
and 250 active WWTPs in the Keys. Because updated information on the additional WWTPs has not been
received, this appendix and all calculations of nutrient removals and costs will address the 209 WWTPs
identified in the Phase I report. The additional WWTPs will affect nutrient removals and costs associated
with some engineering options, but only by a relatively small percentage (less than 5% for most options).
Overall strategies and structure of the engineering options will not be affected.
A.3.1.2 ABSORPTION FIELDS
Absorption fields, commonly referred to as drainfields, are the most common means of effluent disposal for
traditional OSDSs. According to the Monroe County Year 2010 Comprehensive Plan, there are an estimated 29,000
OSDSs in the Keys. Of these, 24,000 are Florida Department of Health and Rehabilitative Services (FDHRS)
permitted septic tank or aerobic systems and 5,000 are cesspits. The Phase I report figures show that of the 24,000
permitted OSDSs, only 350 are aerobic systems and that 164 of these systems discharge to absorption fields. The
remaining 186 aerobic systems discharge to boreholes. In order to simplify calculation of overall OSDS nutrient
3A-8

-------
Table A-2. Est mated pollutant loadings from sanitary
WWTPs discharging to groundwaters within the FKNMS".
PAED0
Kaj Ana*
Number
ef
WWTPs
Total
IVan
Capnc*yc
Total
Average
Daily
Flowฎ

Eaiouted Pollutant Lowiitt|
(lbs/day)^*ฎ



(MGD)
(MGD)
(MOD)
TSS A
BOD
NHj-N
NOj-N
fo4

LOWES KEYS







NA
City of Key Wot
7
0.36Sr
0.294r
49
12
16
20
1
Slock Island. Cow A Key Havea
7
0.1S1
0.14S
24
6
42
9
2
Boca Chin. Rockland. Bit Coppit A Gcifcr
1
0.445
0.143
24
6
42
10
)
Ssddlebocfe. Upper A Lower Sugarloaf
5
0.071
0.023
4
1
7
2
4
Cudjoe, Sisnmcriud, Ramrod. Torch Key* A No Name Key*
3
0.0M
0.041
7
2
12
3
s
Bi( Key
4
0.043
0.020
3
1
6
I
6
Spanish Harbor, Bahia Honda. Ohio. Miwiiin Lisle Duck A
Pigeon
4
0.077
0.049
1
2
14
3

SUBTOTAL
33
1.269
0.717
119
30
209
48

MIDDLE KEYS







7
Knight. Vaca (Marathon). Sunup A Boot
31
0.7JO
0.251
42
10
73
17
1
Fat Deer (isc haling Coca Ptum). Crawls A Little Crawl
4
0.073
0.020
3
I
6
1
9
Gravy
2
0.04}
0.012
2
0.5
4
I
10
Duck A Conch
1
0.050
0.045
1
2
13
3
11
L
-------
loadings, the 186 aerobic systems discharging t j boreholes are not addressed separately and are included with
systems discharging to absorption fields.
To distribute OSDS pollutant loading geographically, it is assumed that OSDS use in a given area is proportional
to resident population (a study currently underway by Monroe County to map all OSDSs within the Keys was not
complete as of this writing). Estimated pollutant loadings for FDHRS-permitted OSDSs in Key West and all
Monroe County PAEDs are given in Table A-3. The total estimated nutrient loadings from absorption fields are
377 lbs/day orthophosphate and 1,553 lbs/day ammonia nitrogen.
A.3.1J CESSPITS
According to the Monroe County Year 2010 Comprehensive Plan, there are an estimated 5,000 active cesspits in
the Keys. Cesspits are typically excavated into the Key Largo Limestone or Miami Oolite at the ground surface.
Cesspits vary in size from 100 cu ft to more than 1,000 cu ft and are generally 4 to 8 ft deep. The pit is usually
covered with a concrete slab and receives raw, untreated waste. Liquid waste components are discharged through
the porous limestone formations toward outlets typically at shorelines or canals, and solid wastes are retained in the
cesspit. Though some pumping of solid wastes from cesspits may occur, it is believed that when solid wastes
accumulate to the point where function is impeded, the cesspit is abandoned and a new one is constructed.
Because there is presently no useful information on geographic distribution of cesspits throughout the Keys, it is
assumed that cesspit distribution is proportional to resident population in the various PAEDs. Table A-4 is a
tabulation of estimated pollutant loadings from cesspits throughout the Keys. Pollutant loadings are based on typical
residential raw wastewater characteristics as listed in Table 2-10 of the Phase I report and footnote "e" of Table
A-4.
Nutrient loading estimates for cesspits include 127 lbs/day ammonia nitrogen, 12 lbs/day nitrate nitrogen, 709
lbs/day total nitrogen, 156 lbs/day phosphate, and 250 lbs/day total phosphorus. There is also a high potential for
bacteriological contamination from cesspits. Raw wastes come into direct contact with the porous soils or rock into
which the pits are excavated. The potential for migration of bacteriological contamination to surface soils or
adjacent surface waters is high.
A.3.2 Stormwater
Nonpoint source stormwater discharges are defined as discharges to surface waters by overland flow, not through
structures. The vast majority of stormwater discharges throughout the FKNMS are nonpoint. Land uses with a
high potential for stormwater pollutant loading include highways, commercial areas, high-density residential areas,
and construction areas.
Very little information is available on the quantity or quality of stormwater runoff in the Keys. In the interest of
estimating the significance of nutrient loadings to the FKNMS from stormwater runoff, typical runoff coefficients
and literature values of nutrient concentrations for stormwater mnoff from general land use categories were used.
Nutrient concentrations and runoff coefficients used in this analysis are summarized in Table A-5. A breakdown
of general land use categories for the upper, middle, and lower Keys is given in Table A-6. Table A-7 summarizes
estimated stormwater loadings of nitrates, total nitrogen, orthophosphate total phosphate, and total suspended
sediment for general land use categories in the upper, middle, and lower Keys. Total estimated loadings from all
land areas are 635 lbs/day total nitrogen, 364 lbs/day total phosphorus, and 124 tons/day TSS. Total estimated
loadings from all developed areas are 410 lk. Jay total nitrogen, 364 lbs/day total phosphorus, and 85 tons/day TSS.
3A-10

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Table A-3. Summary of estimated pollutant loadings from FDHRS-permiUed
on-site sewage disposal systems to groundwaters within the FKNMS.
>aed*
Ksj Areas
1990
R sarin*
Popuissioo
Projection**
Ed totaled
Number
Stpuc
Tanka4
E*imeted
SopLic
Tanks'


Polhtam
(Ae/day)
Loading^





(MGD)
TSS
BOD
NHj-N 1
NOj-N
P0ซ

L0WER ^CEys








N/A
City of Hey West
NAC
SO6
0.013
4
6
3
0
1
1
Stodt Iskod. Cow & Key Hsvta
454!
2089
0.522
156
244
135
0
33
2
Boca fTiirs. Rockland. Bi( Cappa t Geifcr
3106
1429
0.357
108
167
92
0
22
J
WrtHnas U. Upper * Lower Sugarioaf
1716
ฆ23
0.203
61
96
53
0
12
4
Orfjon. Siaamertaad. Ramrod. Torek ICcya A No Name Keys
1913
1833
0.439
138
214
119
0
29
5
Bag Fine Key
4208
1937
0.484
143
226
125
0
31
6
ฆIpsui^ Hsrbnr. Bahia Honda. Ohio. Miasoun, ' Duck &
Pigeon
441
203
0.031
15
24
13
0
3

SUBTOTAL
18063h
8366
2.091
627
977
$40
0
131

MIDDLE KEYS








7
Knigbl. Vaca (Marathon). Slinup Sl Boot
8861
4079
1.019
306
476
264
0
63
a
Fat Deer Including Coco Plum). Crawls A Liale Crawl
697
321
0.081
24
37
31
0
5
9
Grsasy
I0S6
500
0.125
37
59
33
0
8
10
Duett Coach
629
290
0.072
22
34
18
0
3
11
Long* Fan
336
164
0.041
12
19
11
0
3
12
Lower Craig A Wadlcy
1096
303
0.126
37
59
33
0
8
11
Upfw UmcqbIk
1220
362
0.140
42
63
36
0
9

SUBTOTAL
13943
6421
1.604
480
749
416
0
101

UPPER KEYS








14
Phatatm
4403
2027
0.507
153
237
132
0
12
13
Lower Key Largo (Tavcnuer)
2433
1120
0.280
84
131
72
0
17
16
Key Largo (Dove)
22S7
1033
0.263
79
123
68
0
16
17
Key Largo (Rock Harbor)
2463
1133
0.284
85
132
74
0
II
IS
Key Largo (Tarpon Basm)
4127
1900
0.473
143
222
123
0
10
19
Key Lsigo (Largo Sound)
90S
418
0.105
32
49
27
0
7
20
Key Largo (Blsckwster Sound)
1349
713
0.179
34
84
46
0
12
21
N. Key Largo (Port Boaganvilleto Aagelfish). Cspe Sable
1787
823
0.203
61
96
53
0
13
22
Crass Key to Dade Cotaly Line
61
28
0.007
2
3
2
0
0.4

SUBTOTAL
20025
9127
2.303
693
1077
597
0
143

TOTAL
32032
24004
6.000
1800
2803
1553
0
377
NA: Not applicable
•Plsnnjng Area AasJysis/Enumtrsuoo District ss delineated tn Monroe County Year 2010 Comprehensive Plan
^Source: Monroe Cotaty Year 2010 Comprehensive Plan. Tahle 3-27
cEปtimaled number of septic links m the City of Key West m aM based on population
d Assumes 23.000 sepcactsnfc systems throughout the FKNMS. distributed proportional lo n*'1"1—
eSซim: FKNMS Am J report
'Assumes 100 GPO per capita sad 2.3 ix-g^ann per una. or 230 GPD per dwellint una
ฆ Jr-Uniajซ utilizes average daily flow Assume followฎ* poUutsm concentrations which in averages of mates liven m Tsble 2-11 of the Phsss 1 report; 36 m|/L TO.
mg/LBOD. 31 mg/LNHrN (70* of Totsl Nitroปen). 13 mg/L NOyN (30* of Total Nte>|en). sod 7 J mj/L P04.
rwer Keys ปubsnซal does not include Ifas City of Key West
3 A-11

-------
Table A-4. Summary of estimated pollutant loac ings
from cesspits to groundwaters within FKNMS.
*JED*
KiyAm
1990
Riiilinl
Population
Project ion**
Elimated
Number of
Caapu'
EMinuted
Total of
Caanau
Flowd

E*im
atad Pollutant
Oa/day*
1





(MGD)
TSS A
BOD
NHj-N
NOj-N
TN .
TP P04

LOWER KEYS








NA
City of Key Wot
NA
20
0.005
10
1
0.04
3
1 1
I
Slock Uland. Cow A Key Haven
4541
435
0.109
222
11
1
62
14 22
2
Boca Cluca. Rockland. Big Coppit A Gci|tr
3106
297
0.074
152
7
1
42
9 15
3
Seddkfaunch. Upper A Lower Sugarloaf
1786
171
0.043
87
4
0.04
24
5 9
4
Cudjoc. Sununerland, Ramrod. Torch Keya A
No Name Key*
39S3
311
0.095
195
10
1
54
12 19
5
Bif Pine Key
4208
403
0.101
206
10
1
57
1) 20
ซ
Spaniah Harbor. Bahia Honda. Ohio.
MiaKxin. Little Duck A Pigeon
441
42
0.011
22
1
0 1
6
1 2

SUBTOTAL
18065
1749
0 438
894
44
4
248
55 88

MIDDLE KEVS








7
Knight. Vaca (Maiathoo). Sunup A Boot
1861
848
0.212
433
21
2
120
27 42
S
Fat Deer (including Coca Ptum). Cnwli A
Link Crawl
697
67
0.017
34
2
0.1
9
2 J
9
Gnaey
1086
104
0.026
53
3
0.2
15
) 5
to
Duck A Coach
629
60
0.015
31
2
0.1
9
2 3
11
Long A Fna
3S6
34
0.009
17
1
0.1
5
1 2
12
Lower Malecwnbe. Craig A WiadVey
1096
10S
0.026
54
3
0.2
15
\
I)
Upper Malmimtwi
1220
117
0.029
60
3
0.2
17
1
4 6

SUBTOTAL
13941
1135
0.334
682
35
3
190
42 M

UPPER KEYS








14
Plantation
4405
422
0.105
215
II
1
60
13 21
1)
Lower Key Largo (Tavenuer)
2433
233
0.058
119
6
0.4
33
7 12
16
Key Larjo (Dove)
22*7
219
0.055
112
5

31
7 11
17
Key Largo (Rock Harbor)
2465
236
0 059
121
6

33
7 12
11
. Key Largo (Tarpon Bum)
4127
395
0.099
202
10
1
56
12 20
19
Key Largo (Largo Sound)
90S
87
0.022
44
2
0.2
12
) 4
20
Key Largo (Blackwaier Sound)
1549
148
0.037
76
4

21
5 7
21
N. Key Largo (Port Bouganville 10 Angelfiah).
Cape Sable
17*7
171
0.043
87
4
0.4
24
5 ป
22
Craaa Key to Dvic County Lisa
61
6
0.002
3
0.1
0.01
1
0.2 0.3

SUBTOTAL
20022
1917
0.480
979
4$
4
271
59 96

TOTAL
52032
5001
1.252
2555
127
12
709
156 250
NA: Not applicable
*Pluuun| Area Anatysie/Enumeriuoo District as delineated m Monroe County Year 2010 Comprehensive Plan
^Source: Monroe County Year 2010 Comprehensive Plan. Table 3-27
cEitunaled number of cesspits for the City of Key West is baaed on 1992 pereonal communwitKWi with Chris Williams. FDHRS. For uuncorporaiad Monroe County, the distribution
of cesspits ta assumed proportional to population. It if iiinmrrl thai 5.000 cesspits exist m the Keys, aa staled in the Monroe County Year 2010 Comprehensive plan.
^Assumes 250 GPD per ctaap*
'Assumes following poUutsolcoacentratioae which ere Averages of ranges given in Table 2-8 of the Huh 1 report: 245 mg/LTSS, 245 mg/L BOD. 12 mg/L VHj-N. 1 mg/L NOyN
68 mg/L Total N. 15 mg/L P04, and 24 mg/L Total P
3A-12

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Table A-5. Typical stormwater runoff coefficients and storm water
pollutant concentrations for general land use categories.
Typical Pollutant Concentration1	Average Runoff Coefficient'3
(mg/L)
Land Use Category
NO3-N
TNฎ
ro4
Total P
TSS
Surface Runof!*'
Shallow Infiltration
Total
Single Family
0.75
1.5
0J1
1.76
400
0.35
0.25
0.60
Multi-Family
0.89
1.8
0J8
2.68
600
0.J0
0.15
0.65
Commercial/Public
0.78
1.6
0.28
0.62
900
0.70
0.05
0.75
Open
0.32
0.6
0.16
0.19
200
0.15
0.25
0.40
'Sources: City of Key West Comprehensive Plan, Table IV-21 and SFWMD St. Lucie Baiin Assessment, Table 4-1
^Source: FDER Florida Development Manual — Stormwater Management (February 1992)
ฐTN: NO3-N ratio is assumed to be 2:1
3A-13

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Table A-6. General land use distribution for Lower, Middle and Upper Keys.1
Areas of General La ad Use Categories
(acres)
Keys Area
Single Family
Multi-Family
Commercial
Open
Lower Keys
2951
689
4337
22151
Middle Keys
2037
S10
1467
4446
Upper Keys
3391
1212
1135
17017
TOTAL
8379
2411
6939
43614
•Source: Monroe County Year 2010 Comprehensive Plan, Table 3.1
3A-14

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Table A-7. Estimated stormwater pollutant loading to waters of the FKNMS
from the Lower, Middle and Upper Keys.
Kay Area*


Total N
(fea/day




TatalP
(Ibt/day)




TSS
(looa/day)



SF
MF
COMM
OPEN
TOTAL
SF
MF
COMM
OPEN
TOTAL
SF
MF
COMM
OPEN
TOTAL
Lower
J9
14
116
119
308
70
27
45
38
110
7.9
3.0
32.7
19.8
63
Middle
41
10
19
24
114
48
20
13
8
91
S.J
2.2
11.1
4.0
23
Upper
ซS
24
30
91
213
SO
47
12
29
168
9.1
S.3
8.6
15.2
38
TOTAL
its
48
1SS
234
633
198
94
72
7J
439
23
10
32
39
124
Total1*
DmhH




401




364




15
SF: Safte faniJy
MF: MulU-family
COMM: Comammi/pufalic
aKey areas are as drlinraffri in fee Monroe County Year 2010 Comprehensive Plan
t>NuiraBi Loading isiimsira utilita nutneni conccntrmitona and ninoff/inftlinuon coefficients in Table A-5 tnd feneral land use distribution in Table A-6 The loul annual precipiiauoo is
to be 36 in.
cExchadea "open* land areas
3A-15

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A.3.3 Marinas and Live-Aboards
The Phase I report indicates that there are 192 marinas in the Keys with a total of 2,707 wet slips. An additional
2,295 dry slips were reported. Because of the generally smaller size of boats using dry slips and the more
intermittent nature of their use, dry slips present a much lower potential for waste discharge than wet slips. The
Phase I report also showed that in 1988 there were 1,410 live-aboard boats in the Keys with a total live-aboard
population of 3,000 individuals. Of this total number of live-aboard boats, approximately 300 were anchored at
various locations throughout the Keys and the remainder were tied up in marinas.
General marina operations can also contribute to water quality degradation. Marina operations with the potential
to contribute to pollutant loadings include fueling operations, mechanical repairs, boat-bottom scraping and painting,
and die use or disposal of fiberglass resins and solvents.
A.3.3.1 LIVE-ABOARD WASTE DISPOSAL
Of the 192 mannas listed in the Phase I report, only 8 have waste pumpout facilities. Because of the lack of
pumpout facilities, the great majority of live-aboards must use whatever waste treatment and disposal systems they
have on board. Standard practices include on-board pretreatment and discharge, holding tank storage with
subsequent shore-side pumpout, and direct discharge of raw waste. Because of the limited number of pumpout
facilities, shore-side pumpout probably accounts for a very small percentage of live-aboard waste volume. The
Phase 1 report states that pretreatment devices typically attain 30% BODj reduction. Improper disposal of solid
waste by live-aboards also contributes to the accumulation of trash in nearshore waters.
Estimates of nutrient loadings to the FKNMS from live-aboard waste disposal practices were obtained by assuming
a daily wastewater generation rate of 25 gallons per day and by multiplying the literature concentrations for raw
domestic wastewater (as stated in the Phase 1 report) by a factor of 4.0. The rationale behind this approach is that
live-aboards use much less water for flushing, but produce nearly the same mass of waste solids as their shoreside
counterparts. The distnbution of nutnent loadings between the lower, middle, and upper Keys was proportioned
according to the number of wet slips in each area, as noted in the Phase I report. A summary of this nutnent loading
estimate is given in Table A-8.
A.3.3.2 MARINA OPERATIONS
Data are not sufficient to quantify pollutant loadings from marina operations. The most significant pollutants are
heavy metals from leaching and scraping of bottom paints; spilled fuel from fueling operations; fuel, oil and grease
from bilge pumping; and resins or solvents used for fiberglass repair or construction.
A.3.4 MOSQUITO CONTROL PROGRAM
A description of the Mosquito Control Program in the Florida Keys is given in Task 2, Section 3.2.4 of the Phase
I report. Aerial and ground applications dispense insecticides over developed areas and areas of standing water.
Application of insecticides is restricted or prohibited on nearly all federal properties, national recreational parks,
and state fish and wildlife preserves within the Keys. These "no spray" areas are discussed in the Phase I report.
Total insecticide usage for mosquito control in the Keys during 1990 is summarized in Table A-9. A total, which
reflects repeat applications, of 80,654 gallons of liquid insecticides was applied during the year to a cumulative total
of 47,677 square miles. Additional solid insecticides in briquet, pellet, or powder form were applied to 63 square
miles (cumulative). Some general toxic effects of several pesticides are discussed in the Phase I report, but little
definitive data exist to permit evaluation of the effects of the Mosquito Control Program on deteriorating ecological
or environmental systems within the FKNMS.
3A-16

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Table A-8. Estimated wastewater nutrient loadings from live-aboard
boats to surface waters of the FKNMS.
Key Number of Estimated	Estimated Pollutant Loading
Areaa Wet SIipsa Number of Live-	(lbs/day)c


Aboard Boats
TSS & BOD
nh3-n
NO3-N
TN
P04
TP
Lower
589
326
67
3
0.3
18
4
7
Middle
1284
712
145
7
0.6
40
9
14
Upper
834
462
94
5
0.4
26
6
9
TOTAL
2707
1500
306
15
1
84
19
30
'Source: FKNMS Phase I Report
''Number of live-aboards in each area is assumed to be proportional to the number of wet slips. A total of 1500 live-aboard
boats in the Keys is assumed.
cAssumes pollutant concentrations are four times the midpoint of the ranges given in Table 2-8 of the FKNMS Phase I report
for raw domestic wastewater (which were 245 mg/L TSS, 245 mg/L BOD, 12 mg/L NH3-N, 1 mg/L N03-N, 68 mg/L TN,
15 mg/L PO4, and 24 mg/L TP). An average discharge of 25 GPD per boat is assumed. This approach assumes that live-
aboards discharge the same quantity of solids as shore-side residents, but in a reduced volume of wastewater.
3A-17

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Table A-9. Quantities of insecticides used for mosquito control
in the Florida Keys during 1990.*
Insecticide
Quantity
Area Treated
Baytex
290,460 oz
39,209 mi
Scourge (180)
36,054 oz
1,878 sq. mi
Malathion
3,492 oz
129 mi
Biomist
1,680 oz
46 mi
Pennanol
897 oz
17 mi
Vectobac 12
655 oz
41 acres
Dibrom 14 - Diesel fuel (4:100)
55,401 gal
443,208 acres
Vectobac G
22,000 gal
2,998 acres
Abate SG
650 gal
260 acres
Altosid briquets
608,874 briquets
33,811 mi
Bactimos briquets
19,183 briquets
165 acres
Teknar concentrate


(2 oz/gal)
4 briquets
1 acre
(8 oz/gal)
88 briquets
11 acres
(16 oz/gal)
1,294 briquets
58 acres
(8.5 oz/gal)
128 briquets
15 acres
(10.6 oz/gal)
16 briquets
2 acres
Altosid pellets
472 briquets
229 acres
aSource: FKNMS Phase I Report, Table 2-13
3A-18

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A.3.5 LANDFILLS
A total of 12 landfill sites has been identified within the Keys. A summary of the approximate location, area,
capacity, status, and ownership of these sites is given in Table A-10. Three sites are owned by Monroe County,
one by the City of Key West, five by the U.S. Navy, and three by private interests. None of these landfills has
a bottom liner or a leachate collection system. Because of the unlined construction, close proximity to the water
table, and poor control over types of waste placed in these landfills, all have significant potential to degrade
groundwater and adjacent surface waters.
Because of declining landfill capacity and the difficulty in permitting new landfill sites within the Keys, both the
City of Key West and Monroe County have decided to have all solid waste and most incinerator ash hauled out of
the Keys by contractors. As a result of this decision, the three Monroe County landfills (Cudjoe Key, Long Key,
and Key Largo) recently have been deactivated. The City of Key West Stock Island landfill is only used for
disposal of relatively small quantities of incinerator ash. All four of these landfills are in the closure process.
Closure plans for the Monroe County landfills were submitted to the FDER in June 1992, but were not approved
as of this writing. Closure of the Stock Island landfill is scheduled to be completed by May 1993. Closure plans
for all four landfills include installation of a membrane top liner to reduce leachate production.
All four Monroe County and City of Key West landfills have active groundwater monitoring programs. Three to
five shallow monitoring wells are installed at each site (see Table A-10). Some additional sampling of adjacent
surface waters has occurred, but no surface water locations are monitored on a regular basis. Monitoring data
collected to date do not indicate any significant potential for degradation of groundwater or adjacent surface waters.
However, because of the small number of monitor wells at each site, there may be some questions as to the level
of confidence that can be placed on groundwater monitoring data for these sites.
Five of the landfill sites listed in Table A-10 are owned by the U.S. Navy. Four of these sites (Truman Annex,
Fleming Key North, Fleming Key South, and Boca Chica) are being assessed under the U.S. Navy's Installation
Restoration Program. The initial assessment phase of the program indicated metal contamination at all four sites
and some isolated occurrences of polychlorinated biphenyls (PCB), organics, and pesticides. Data are insufficient
to determine overall loading of pollutants to groundwaters or surface waters. As of this writing, contracts were
being prepared to proceed with remedial action investigations for all four sites. Assessment and cleanup of these
four U.S. Navy landfill sites will continue to be pursuit under the Installation Restoration Program.
The fifth U.S. Navy-owned site on Saddle Bunch Key is not being investigated under the Installation Restoration
Program. Though the site is owned by the U.S. Navy, it was operated by a private contractor. No records of
disposal practices, storage area, closure, or monitoring were found.
The remaining three landfills listed in Table A-10 (Middle Torch and Boot Key 1 and 2) are in private ownership.
No records of disposal practices, storage area, closure, or monitoring were found. These three landfills and the
Saddle Bunch Key landfill apparently have inadequate, pervious cover and are not monitored. Because of the high
variability of leachate between different landfill sites, it is not practical to estimate pollutant loadings from these
inactive sites.
A.3.6 Toxic or Hazardous Material Spills
Spills of toxic or hazardous materials have the potential to create nonpoint source pollutant loading to the FKNMS.
Because of the unpredictability of such spills, assessment of their pollution potential can not be quantified. Likely
source areas are transportation over waterways and roads, and facilities that handle or store toxic or hazardous
materials.
3A-19

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Table 4-10. Capacities, areas, and status of landfill sites in the Florida Keys.
Ste
M3t
Marker
Area
(acres)
Facility Type
Previous Capacity
(tons/day)
Status
Ownership
Numberซ
Monitor Wi
Long Key
68
30
Landfill/Incinerator
112
Inactive*
Monroe County
3b
Cud joe Key
• 21
20
Landfill/Incinerator
75
Inactive*
Monroe County
5b
Key Largo
c
IS
Landfill/Incinerator
112
Inactive*
Monroe County
3b
Stock Island
5
19
Landfill/Incinerator
150
Active*1
City of Key West
3*>
Tniman Annex
0
7
Landfill
Unknown
Inactive
U.S. Navy
7e
Fleming Key North
0
30
Landfill
15
Inactive
U.S. Navy
8e
Fleming Key South
0
43
Landfill
25
Inactive
U.S. Navy
10e
Boca Chic*
8
Unknown
Landfill
Unknown
Inactive
U.S. Navy
9*
Saddle Bunch
li
Unknown
Landfill
Unknown
Inactive
U.S. Navy'
' 0
Middle Torch
27
Unknown
Landfill
Unknown
Inactive
Private
0
Boot Key 1
48
Unknown
Landfill
Unknown
Inactive
Private
0
Boot Key 2
48
5-10
Landfill
Unknown
Inactive
Private
0
* Land fills at these sites are currently inactive, but litcs are being utilized as transfer facilities.
^Wells an monitored quarterly with results submitted to FDER
cNo data available
*The current operating cell of the Stock Island Landfill is utilized only for disposal of some ash from the adjacent incinerator
'Wells are utilized for initial assessment and follow-up monitoring under the U.S. Navy Installation Restoration Program. These landfills are not in
the FDER quarterly monitoring program.
^This site is owned by the U.S. Navy, but a private contractor operates the Saddle Bunch Landfill
3A-20

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A.3.7 Underground Tanks
Underground tanks that were constructed prior to current FDER requirements for secondary containment and
monitoring have the potential to adversely affect groundwater and surface waters in the FKNMS. The majority of
such fnlra are fuel tanks associated with service stations or marinas. In 1984, the FDER initiated a program to
retrofit all stationary tanks to provide leak detection capability, and to install monitoring systems and overfill
protection. All identified facilities were to have monitoring systems in place by 1989. Lining or replacement of
non-approved tanks commenced in 198S and is scheduled to be completed by 1998. Existing tanks are now required
to have secondary containment by 1998. All stationary underground tanks are presumed to be included in this
retrofitting program.
The locations of nearly all underground storage are known and some leaking tanks have been identified.
When leaking or old fuel tanks are replaced under the FDER retrofitting program, soil samples are analyzed and
any fuel contamination from the tank is required to be cleaned (e.g., soil excavation and incineration, floating fuel
recovery, etc.). The FDER underground storage tanlr program represents a considerable effort towards resolving
problems associated with leaking underground storage tanks and additional efforts in this area are not warranted.
A.4 EXTERNAL SOURCES
External sources of pollutant loading to the FKNMS are described in Task 2, Section 3.3 of the Phase 1 report.
These external sources have the potential to degrade water quality within the Sanctuary by transporting pollutants
advectively through Florida Bay or the Atlantic Ocean, or by atmospheric deposition. Pollutants may include
suspended solids, thermal changes, nutrients, salinity changes, or toxic materials.
A.4.1 Areas Adjacent to the Sanctuary
A.4.1.1 FLORIDA BAY AND EVERGLADES NATIONAL PARK
Florida Bay is a potential source of poor water quality that could adversely affect waters of the FKNMS. Causes
of poor water quality within Florida Bay include wind-driven transport of suspended particulates, the presence of
soluble nutrients, decomposition of seagrass, and low dissolved oxygen at night resulting from plant respiration.
The information available is not sufficient to quantify the effects poor water quality in Florida Bay may have on the
Sanctuary's reef tract. The Phase I report indicates that the reduced flow of freshwater from the Everglades and
its probable effect on increased hypersalinity in Florida Bay is a prevalent anthropogenic water quality problem in
Florida Bay.
A.4.1.2 BISCAYNEBAY
North Biscayne Bay receives runoff from large urban areas, including manufacturing and large boat building and
repair facilities. This portion of the Bay receives flow from numerous tributaries with heavily-developed urban
watersheds, including the severely-degraded Miami River. If-the proposed plans to dredge the Miami River and
dispose of sediments offshore are implemented, w^ter quality within the FKNMS may be affected. The Metro-Dade
County offshore sewage outfall also has the potential to adversely affect waters of the FKNMS.
South Biscayne Bay receives inputs from agricultural areas in South Dade County, the Homestead Air Force Base
and the Black Point Landfill site. The Phase I report documented heavy nitrate loading and the presence of
pesticides in two of the major agricultural canals discharging to the south bay. Homestead Air Force Base and
Military Canal were identified as significant sources of metals and organic compounds. Plans to dredge Military
3A-21

-------
ran a I by the U.S. Air Force have been delayed indefi aitely, but if the plans move forward, dredging would pose
a significant threat to water quality within the FKNM >.
A.4.1J ATMOSPHERIC DEPOSITION
Wet or dry atmospheric deposition may be a significant source for loadings of nutrients and other pollutants to
waters of the FKNMS. Studies in Tampa Bay indicate atmospheric nitrogen loading is within the range of 546 to
1466 mg N/m^/yr. Application of these figures to the water surface area of the FKNMS (9.811 x 1CP m2), yields
an atmospheric nitrogen loading estimate of 32,000 to 87,000 lb N/d .
A.4.2. Areas Distant from the Sanctuary
As discussed in Task 2, Section 3.3.2 of the Phase I report, there is some potential for contaminant loading in the
FKNMS transported from distant sources via gulf or ocean currents. Pollutant sources as distant as the Mississippi
River and the Orinoco River (South America) may be major sources of contaminants. These contaminants may at
times be entrained by the Loop Current, which flows from the Yucatan Peninsula generally clockwise around the
Gulf of Mexico to the Florida Straits, where it flows east and north as the Florida Current. Data are not sufficient
to quantify pollutant loadings from these distant sources.
3A-22

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APPENDIX B
Engineering Methods for Domestic Wastewater
Collection, Treatment, and Disposal

-------
ENGINEERING METHODS FOR DOMESTIC WASTEWATER
COLLECTION, TREATMENT, AND DISPOSAL
This Appendix examines engineering methods available for reduction of wastewater pollutant loadings into waters
of the Florida Keys National Marine Sanctuary (FKNMS). Methods discussed include most of those used in
common engineering practice for collection, treatment, and disposal of domestic wastewater. Also included are
some proven methods that have not been widely applied in the state of Florida.
Management of wastewater is an important environmental factor for the Florida Keys. The treatment and disposal
of wastewater within unincorporated Monroe County has traditionally been accomplished through septic tanks or
package plants. These two on-site treatment schemes have been used by single households, housing developments,
condominiums, hotels, and commercial developments. Population growth in the Florida Keys and the reliance upon
private development have led to a proliferation of small package treatment plants and a large inventory of individual
septic tanks. Current wastewater treatment practices combined with soils in the Keys that have high porosity and
low organic content, and high land use densities have resulted in increased potential for groundwater and surface
water contamination.
B.1 EXISTING FACILnTES
Sanitary sewer facilities operating in unincorporated Monroe County consist of regulated and unregulated on-site
sewage disposal systems (OSDS) and package treatment plants. The City of Key West uses a 10-million gallons
per day (MGD) central system for collection and treatment of its wastewater. At the present time approximately
44% of all Florida Keys wastewater flow is treated by OSDSs, 16% is treated by package treatment plants, and 40%
is treated by the City of Key West wastewater treatment plant (WWTP). The City of Key Colony Beach owns and
operates the only other municipal WWTP in the Florida Keys, a 0.175 MGD facility.
Existing sewage treatment/collection facilities in the Keys are characterized below:
Type Approximate Regulatory
	 Number	 AXSDSI	
Septic Tanks	24,000	Florida Department of Health
and Rehabilitative
Services (FDHRS)
Small Package
Plants	200	Florida Department of
Environmental Regulation
(FDER)
Cesspits	5,000	Unpermitted & unregulated
Many facilities (such as restaurants, motels, and campgrounds) and multiple-family dwellings (condominium and
apartment buildings) are served by package plants, ranging in capacity from 0.0008 to 0.4S MGD. With the
exception of the City of Key Colony Beach WWTP, all of these package plants serve site-specific projects and are
privately owned, operated, and maintained. One- and two-family dwellings commonly use septic tanks, as do many
campgrounds and mobile home parks.
3B-1

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B.2 WASTEWATER TREATMENT METHODS
Two general issues must be addressed when considering wastewater treatment methods for an area. The first issue
is whether central or local treatment facilities will be used. The second issue is the level of treatment that will be
attained by treatment facilities.
B.2.1 Centralization of Facilities
The Florida Keys are a unique string of islands formed by an ancient coral reef system. The Florida Keys straddle
two worlds, one of fragile Caribbean-type islands and the other of busy tourist resorts with vehicular access.
As development in the Keys occurred, the methods used for treating wastewater evolved. The first methods used
were cesspits and septic tanks. As larger development moved in, package plants began being used. Finally, in Key
West, the only area where the population density was large enough, a single municipal wastewater treatment plant
was constructed and used.
The choices for facility centralization are:
•	Continue the existing level of service.
•	Construct community facilities to serve moderate size service areas.
•	Construct subregional facilities to serve large service areas.
B.2.1.1 CONTINUE THE EXISTING LEVEL OF SERVICE
Factors that have contributed to tfc- existing level of service include:
•	Ease of facility constructic
•	Present and past regulator ;ontrols or lack of controls
•	Topography of the land
•	Development patterns
•	Best available and most ec-: lomical technologies at the time of development
•	Site conditions (soil, vegec ion)
•	Adjacent development
•	Availability of infrastructur to support new development, or lack of that availability
Factors that may contribute to the xision to continue with the existing level of services are:
•	Perception that existing facilities and current methods are adequate
•	Represents the lowest cost option in terms of initial capital cost outlay
•	Decision to wait for definitive scientific solutions to sewage and stormwater handling concerns
•	Delay decision until a more politically opportune time
•	Environmental impacts may be perceived to be unproven without other concrete evidence
Factors that may contribute to the decision to change the existing level of service are:
•	Prices for capital improvements may be inflated in the future
•	More stringent regulation in future may drive costs higher
•	Continued pollutant loadings in surface waters and groundwaters
•	Impacts to native flora, fauna, and coral reefs
•	Loss of tourist dollars because of pollution degradation of Florida Keys and reefs
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1
B.2.1.2 CONSTRUCT COMMUNITY FACILITIES
With the exception of Key West, the population in the Florida Keys is widely distributed. In order to centralize
the facilities, many miles of force mninc and numerous lift stations would have to be constructed. The balance
between constructing force mains and lift stations for central facilities versus using smaller, local treatment facilities
is demonstrated by the centralization approaches discussed in the following sections.
Central sewer service areas may potentially serve the largest population centers. The top 12 population centers
(communities) are listed in Table B-l. The community rankings and groupings are discussed in more detail with
option descriptions in Appendix C. The remaining areas that are not ranked as potential central sewer service areas
could be developed as smaller collection and treatment zones or allowed to develop as currently regulated. The
advantages of a centralized system with community plants include:
•	Centralized systems provide for better wastewater treatment and reduction of nutrient loadings.
•	The unit cost per gallon of treated wastewater is lower for larger plants versus smaller plants.
•	Larger plants require less staff for operation and maintenance per gallon of treated wastewater.
•	Larger plants tend to be more reliable with respect to final effluent quality and are less likely to be upset
by varying flows and treatment loadings.
•	Larger plants have the staffing necessary to effectively accomplish reuse water treatment for irrigation
•	Community or subregional plants and their collection systems tend to eliminate the use of septic tanks and
stop the proliferation of package plants.
The disadvantages of the centralization of collection and treatment facilities for the Florida Keys include:
•	Requires the public to eliminate septic systems and hook-up to sanitary sewer (greater cost and
inconvenience)
•	Construction and maintenance costs associated with larger wastewater collection systems, including
transmission from source, force mains, and lift stations.
B.2.1J SUBREGIONAL FACILITIES
Further centralization of collection and treatment can be accomplished by-constructing three new subregional
facilities in addition to the plant at Key West. Areas served by these facilities are:
purposes.
Subregional Proposed
Facility
Potential
Service Areas
Lower Keys
(Except Key
West)
Upper Sugarloaf Stock Island, Cow, Key Haven,
Boca Chica, Rockland, Big Coppitt,
Geiger, Saddlebunch, Upper &
Lower Sugarloaf, Cudjoe, Summerland,
Ramrod, Torch, No Name, and Big Pine Keys
Middle Keys
Marathon	Knight, Vaca (Marathon), Stirrup,
Boot, Fat Deer, Lower and Upper Matecumbe
and Windley Keys
Upper Keys
Tavernier	Plantation Key, Lower Key Largo
(Tavemier), Key Largo (Dove,
Rock Harbor, Tarpon Basin, Largo
Sound, Blackwater Sound, N. Key
Largo) Port Bouganville to
Angiefish, Cape Sable
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Table B-l. Ranking of the top 12 Monroe County planning
area/enumeration districts (PAED)a by population.
Top U
Ccntcn
PAEO
Key Anai
1990
Popnlatinn Projection
10
6
9
2
II
NA
4
2
3
1
5
6
7
8
9
10
11
12 & 13
14
15
16, 17. IS.
19 & 20
21
22
LOWER KEYS
City of Key Wea
Cudjoe. Summeriand, Ramrod, Torch Keyi & No Name Kcyi
Boca Chica, Rockland, Big Coppit & Geiger
Saddlebunch, Upper & Lower Sugarloaf
Stock Iiland, Cow & Key Haven
Big Pine Key
Spaniah Hirbor, Bahia Honda, Ohio, Miaaouri, Little Duck & Pigeon
MIDDLE KEYS
Knight. ' i (Marathon), Slimip Sl Boot
Fat Dec. ;luding Coco Plum), Crawl & Little Crawl
Gniay
Duck Sl <ฆ >ch
Long & Ft ta
Lower & ' per Matecumbe, Craig 3t Windley
UTTER keys
SUBTOTAL
SUBTOTAL
Planution
Lower Kc. .argo (Tivernier)
Key Largo Jove. Rock Haibor, Tarpon Basin. Largo Sound & Blackwater Sound)
N. Key I o (Port Bouganville to Angelfiih), Cape Sable
Crota K a Dade County Line
SUBTOTAL
TOTAL
24.6S2
4,983
3,106
1.786
4.541
4,208
441
42,717
8.861
697
I.086
629
356
2 J16
13,945
4,405
2,433
II.336
1.787
61
20,022
79,684
NA: Not applicable
'Planning Area Anaiyni/Emimention Diatrict aa delineated in Monroe County Year 1020 Comprehebnsive Plan
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Areas that might not be included in the three new subregional facilities are Spanish Harbor, Bahia Honda, Ohio,
Missouri, Little Duck, Pigeon, Crawl & Little Crawl, Grassy, Duck & Conch, Long & Fiesta, Craig and Cross
Key to Dade County Line.
The strong possibility exists that once the Key West WWTP controls and reduces infiltration and inflow to its
collection system, it could handle flows from Stock Island to Big Coppitt Key. The sizes and configurations of
subregional WWTPs are subject to further planning and study. With any proposed centralization of facilities a
certain portion of the population living in outlying and sparsely populated areas would not be served. These remote
units would have to rely on OSDSs or package plants for treatment of wastewater.
B.2.2 Treatment Level
The wastewater treatment process is designed to remove solid and organic constituents from raw sewage by
physical/chemical and biological means. The essential differences between treatment types are the final product or
system effluent. Depending on the proportion of materials removed, treatment processes are generally grouped into
one of the following levels:
•	Primary Treatment — Primary treatment involves the physical removal of solids from the waste stream
by screening and sedimentation. Primary treatment physically removes discrete particles (rocks, pebbles,
sand, grit, etc.), 35 to 65% of suspended solids, and between 30 to 36% of organic materials. Biological
or chemical degradation in primary treatment is usually unintentional and incidental.
*	Secondary Treatment — Secondary treatment follows primary treatment and generally requires multiple
steps involving one biological process and one or more physical processes to remove suspended solids.
Secondary treatment removes between 85 to 95 % of total organic materials and suspended solids from raw
sewage. The actual removal capability of secondary treatment is affected by the type of process units chosen
for each application, design of units, hydraulic loading rates, organic loading rates, and system operation.
Secondary treatment is more expensive than primary treatment.
*	Irrigation Quality Treatment — Irrigation quality treatment is used for effluent that will be used to irrigate
areas with public access. Additional treatment steps beyond secondary treatment include high-level
disinfection and filtration to achieve TSS below 5 mg/L.
•	Advanced Wastewater Treatment (AWT) — AWT follows secondary treatment and is also referred to as
tertiary treatment. The most common applications of tertiary processes are nutrient removal and the removal
of soluble phosphorous and nitrogen compounds. The release of treated wastewater containing high
concentrations of these compounds to an environment that has little ability to absorb and assimilate them
may degrade water quality. Tertiary treatment may involve one or more unit process such as chemical
addition, coagulation, sedimentation, filtration, or activated carbon.
AWT may produce treated water of sufficient purity to be acceptable for discharge directly into surface
waters. Standards for AWT are set by law (Section 403.086 Florida Statutes [FS]) in Florida. While AWT
standards are very stringent, achieving this level of treatment gives a utility certain legal rights to discharge
directly into surface waters. Currently, less than 0.05 % of wastewater treatment facilities in the state of
Florida meet the AWT treatment standards. AWT is the most expensive method of treatment, because of
the additional plant and operations costs. The expense of AWT is dependent on the effluent treatment
removal/level desired and the type and amount of pollutants in the influent wastewater stream.
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B.2.3 Wastewater Treatment Facilities
B.2J.1 ON-SITE SEWAGE DISPOSAL SYSTEMS
The OSDS is the most common treatment method used in the Florida Keys. If designed, installed, operated and
maintained properly, OSDSs generally treat wastewater to near secondary standards. OSDSs can be categorized
into one of the following:
•	Cesspits
•	Conventional Septic Tanks
•	Alternative OSDSs
B.2.3.1.1 Cesspit Systems
Cesspits are used throughout the Florida Keys for domestic wastewater disposal. It is estimated that 3,000
unregulated and unpermitted cesspits exist today. Most of these are unlined and were constructed by cutting or
excavating a pit out of the native limestone and covering it with a concrete lid. The sewage is allowed to collect,
digest, and seep underground. Liquid waste components are discharged through the porous limestone formations
toward outlets typically at shorelines or canals, and solid wastes are retained in the cesspit. Though some pumping
of solid wastes from cesspits may occur, it is believed that when solid wastes accumulate to the point where function
of the cesspit is impeded, the pit is abandoned and a new one is constructed. Cesspits can be differentiated from
outhouses and latrines only because they are connected to indoor plumbing. Cesspits can be considered out-dated
for developed districts and environmentally sensitive areas and are not considered an acceptable engineering
treatment method for wastewater.
B.2.3.1.2 Conventional Septic Tank Systems
A septic tank system usually consists of a house sewer, a septic tank, a distribution device, and a sc-'. absorption
system. The septic tank itself has three functions:
•	Solid waste removal (solid wastes settle to the bottom or float at the top of the tank)
•	Biological treatment (solid wastes decompose in the tank)
•	Solid waste storage (sludge and floating scum accumulations are stored in the tank until proper disposal
following pump-outs).
Septic tanks and drainfields typically produce effluents that can be characterized as less than secondary treatment
but better than primary treatment. Nutrient removals are highly variable, being dependent on design of the tank
and drainfield. Literature values for removal of nitrogen and phosphorous can be overly-optimistic for drainfields
in the Florida Keys. Soil type is the primary cause for the differences in the reported values. Typical Florida Keys
conditions, including tidal pumping, high groundwater, prevalence of sand/limerock, rainfall patterns and drainage
conditions, are not found on the mainland. Because septic tanks themselves provide only minimal treatment,
additional components that provide .reatment by means of polishing and/or disposal are vital and are integral parts
of a properly-functioning treatment/disposal system. These components may include units such as sand filters and
soil absorption systems. Factors affecting septic tank performance include tank geometry, hydraulic loading, inlet
and outlet arrangements, the number of compartments, temperature, and operation and maintenance practices.
Prior to 1984, the predominant type of OSDS installed in Monroe County was the conventional septic tank with
absorption beds. While the use of absorption beds has decreased in recent years, use of conventional systems with
elevated absorption beds or mounds has increased as has the use of alternate home aerobic units that utilize
drainfields or boreholes. Since 1986, FDHRS has required use of aerobic units where site conditions are not
favorable for conventional OSDSs.
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Septic tank systems, if properly designed, constructed, and maintained, can be efficient and economical alt itives
to centralized wastewater treatment systems when site conditions are favorable and unit densities are low. lab1'
B-2 summarizes effluent concentrations and removal efficiencies for a "typical" septic tank system. Under
unfavorable site conditions, such as high septic tank density, high seasonal rainfall, shallow groundwater, or highly
permeable soils, OSDSs can be a significant source of nutrient and bacterial groundwater contamination. Studies
in the Florida Keys have indicated that virtually 100% of the soils in Monroe County are severely limited for
conventional OSDS practices.
In Florida, the most common alternative to the conventional soil absorption system is the mound system. A
properly constructed mound system, using acceptable fill material, may be more efficient than an equally well
constructed conventional system in marginal or unsatisfactory natural subsurface soils. The objective of the mound
system is to effectively treat sewage before it reaches groundwaters or surface waters. This is done by raising the
absorption field above natural soils and increasing the distance between the water table and the dnunfield by using
suitable fill material. Mounds can be used to provide effluent treatment and disposal from a septic tank, aerobic
unit, or other treatment unit. Minimum requirements for construction and criteria for the location of mounds are
contained in Chapter 10D-6 Florida Administrative Code (FAQ.
Mound systems have certain advantages, including:
•	Creation of a deeper aerobic zone in which nutrient uptake can occur.
•	Leaving a mound, percolating effluent enters the more permeable natural upper soil over a large area and
can spread laterally until it is absorbed by the less permeable subsoil (not applicable to the Keys).
•	The clogging zone that eventually develops at the bottom of a drainfield may not clog the sand mound fill
as rapidly as it would in naturally very fine textured soils (not applicable to the Keys).
•	Smearing and compacting, which can occur when excavating wet fine textured subsoils, can be avoided (not
applicable to the Keys).
It should be pointed out that FDHRS requires excavation and replacement of natural soils that are not considered
suitable for receiving effluent from mound systems. This is because the typical Florida systems are not technically
mound systems but, in most cases, are elevated drain fields.
As reported by FDER in the 1988 Wastewater Treatment and Design Manual: "When able to percolate downward
through suitable soils, most pollutants are removed from effluents within relatively short distances. If there is
insufficient depth of suitable soil between the drainfield and the groundwater table or an impervious layer, the
partially treated effluent will enter the groundwater system or flow laterally and break out into surface waters or
drainage ditches. Pollutants have been found to travel great distances from their source when aided by the flow of
groundwater."
B.2J.1.3 Alternative On-site Sewage Disposal Systems
Alternative on-site wastewater disposal systems have been developed to enhance or replace the conventional septic
tank. Figure B-l illustrates schematic diagrams of typical alternative OSDS systems. An in-depth discussion of
the Alternative OSDS components, design and performance will not be given here. Some of these systems are:
•	Aerobic Treatment Units
•	Rotating Biological Contractors
•	Incinerating Toilets
•	Composting Toilets
•	Peat Filters
•	RUCK Systems
•	Recirculating Sand Filters
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Table B-2. Typical effluent concentrations from septic tank systems
[From Canter and Knox 1985].
Parameters
(mg/L)
Septic Trait
Effluent
Drainage System
Efiiueut Drain System
Percent Removed
from Drain System
Suspended Solids
75
18-33
29-76
BODj
140
28-84
40-80
COD
300
57-142
53-81
Total Nitrogen
40
10-78ฎ
—
Total Phosphorous
IS
6-9
40-60
'Reported as ammonia nitrogen
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(a) AEROBIC TREATMENT UNITS
(b) ROTATING BIOLOGICAL CONTACTORS (RBC)
(c) INCINERATING OR COMPOSTING TOILETS
(d) PEAT FILTER
(e) RUCK SYSTEM
(f) RECIRCULATORY SAND FILTERS
Figure B-l. Alternative OSDS process schematics.
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Alternative OSDSs produce secondary treated effluents. Some systems use fixed sand filters to improve the quality
of typical septic tank effluents. These systems are characterized as advanced secondary treatment. Higher treatment
levels have been reported for these systems in studies conducted in controlled areas outside the Florida Keys. A
sun^iary of reported nutrient reduction capabilities and costs for selected alternative OSDSs is given in Table B-3.
Additional information is needed to verify whether any OSDSs can consistently produce nutrient levels below 4 to
6 mg/L in the Florida Keys. The costs to install and operate these systems must be weighed against the costs to
build central sewer systems and compared to the appropriate treatment levels.
Wastewater treatment plants can consistently produce AWT quality effluent. It is yet to be demonstrated that OSDSs
can produce the same treatment level with the same reliability for less cost per household over extended periods of
use in field conditions. The sheer number of existing septic tanks and cesspits argues against their widespread use
because of the difficulty in regulating and controlling them to ensure adequate treatment. If installation and
operation costs are nearly equal to or greater than those for a centralized system, and OSDS treatment level cannot
match that of central WWTPs, OSDS use should be limited to isolated areas.
Aerobic treatment units have been touted as nutrient removal systems that use soil absorption systems or injection
wells and are sometimes used in place of conventional septic tanks. Fixed media filters can be used in combination
with either septic tanks or aerobic units for providing additional treatment of effluent. Several types of sand filter
systems are currently available. The performance of individual aerobic wastewater treatment units generally meet
FDER secondary treatment standards, producing effluent having a 30-day average of 20 mg/L for BOD5, 20 mg/L
for total suspended solids (TSS), and a pH range of 6.0 to 9.0. There are no state or federal nutnent reduction
requirements for these units.
Alternative OSDSs have been shown to generally provide improved treatment of sewage relative to conventional
septic tanks (see Table B-2 and B-3). Nitrogen and phosphorous concentrations in wastewater may be reduced
through specifically designed systems, but removals are not necessarily guaranteed. Such systems may be used for
OSDSs. They must be carefully designed, constructed, operated, and maintain^ to achieve the desired results.
They are inherently more sophisticated and require a substantially higher level of care than conventional OSDSs and
small treatment plants.
B.2.3.2 SECONDARY WASTEWATER TREATMENT PLANTS
The most common type of centralized treatment system used in the Florida Keys is the "package plant." These
plants range in capacity from 800 GPD to 0.45 MGD. All package treatment plants are required to provide
secondary treatment of wastewater. There are 209 permitted package treatment plants operating in Monroe County,
198 of which are in unincorporated parts of the county.
Package treatment plants are regulated by FDER under provisions of Chapter 17-600 FAC, which provides
minimum design, waste treatment, and disinfection standards. Wastewater treatment plants permitted for
construction after January 1, 1982 and plants existing prior to January 1, 1982 that have had modifications requiring
compliance for reclaimed water under 17-600 FAC must be operated by Rules 17-600.440 and 17-600(1) FAC.
Treatment plants existing prior to January 1, 1982 must, at a minimum, meet reclaimed water effluent limitations
as specified in the facilities permit.
At a minimum, all new domestic facilities and modifications to existing facilities are required to be designed to
achieve a 90% removal of BODj and TSS from,the wastewater, or to produce an after-disinfection effluent
containing not more than 20 mg/L BODj and 20 mg/L TSS, whichever is more stringent.
The activated sludge treatment process, which provides the resident biological organisms with an environment in
which they can digest the organic materials contained in the effluent, is the most common process used.
Modifications of the activated sludge process include conventional activated sludge, step aeration, contact
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Table B-3. Literature values for nutrient reduction capabilities of alternate on-site
sewage disposal systems (OSDSs) and estimated retrofitting costs.a
Alternate System	Total System Retrofit Costb	Nutrient Removal
			Ranges0
Initial	20 Year O&M Total 20 Year	(%)
($)	($) (S)
Routing Biological Contactor* or
Aerobic Treatment Units
10,000
8,000
18,000
60-90
Incinerating Toilet

36,400
42,900
60-90
Composting Toilet
7,500d
4,000
11.500
60-90
Peat Filter
4,800
2,000*
6,800
30-90
RUCK
9,800
4,000*
13,800
40-80
Recirculating Sand Filter
7,400
2,600ฎ
10,000
40-70
Recirculating Sand Filter with Anaerobic
12.300
10,000
22,300
60-95
Filter and Carbon Source
O&M: Operation and maintenance
'Adapted (ram literature searches, a* well ai, Nitrogen
Feburary 1992
''Retrofit of existing residential plumbing to separate g.
anumed to require no maintenance regardless of desk
cHigher values have been reported for systems in oihe
Eooditioas.
'For 2 uaita—Costa shown assume existing OSDS is u
Assumed media replacement every 10 years
naval On-Site Wastewater Treatment Syttems by WBNERR. Nitrogen Removal Conference.
-water and blackwater is sssumed to be S2.500 per house. Existing septic tsnki sit
ror sge.
:ologic areas with better soil conditions snd specificslly designed for tightly controlled
' for greywater disposal.
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stabilization, extended aeration oxidation ditches, and sequencing batch reactors. The primary process used by
package treatment plants is the extended aeration process, which provides an aeration detention time of at least 24
h.
B.2J.3 REUSE/IRRIGATION QUALITY-WATER WASTEWATER TREATMENT PLANTS
The reuse of treated wastewater for irrigation purposes is becoming commonplace throughout Florida, and is
encouraged by FDER and the South Florida Water Management District (SFWMD). Because potable water is
imported from the mainland and groundwater is virtually non-existent, reuse water is the most convenient source
of irrigation water in the Florida Keys, especially for golf courses, parks, playgrounds, traffic medians, and other
public areas.
Irrigation offers the advantages of conserving potable water supplies while recharging the groundwater system. The
technical requirements of Chapters 17-6 and 17-610 FAC govern development, permitting and implementation of
reuse projects. Recent revisions to Chapter 17-40 FAC provide for a program of mandatory reuse of reclaimed
water. Reuse is required within areas having existing critical water supply problems and in those areas where water
supply problems are projected to develop within the next 20 years. The SFWMD is responsible for identifying these
areas (such as the Florida Keys) through its management planning process.
Requirements for reuse/iirigation-quaiity water are:
•	A high level of disinfection shall be obtained.
—	Daily sampling for fecal coliforms must occur.
—	At least 75 % of the samples shall have no detectable fecal coliform.
—	No sample shall contain more than 25 fecal coliforms/mL.
•	TSS shall be less than 5 mg/L.
•	Treatment plants cannot be smaller than 0.1 MGD.
•	Treatment plants must have Class I reliability.
•	An operator must be in attendance during irhgation-quality water discharge from plants.
•	Continuous on-line turbidity and disinfectant residual monitors must be in operation.
•	Automatic rejection of water not meeting monitored parameters must occur.
•	Treatment plants must provide for three-day wet weather storage of effluent.
•	Treatment plants having an approved alternate disposal method must provide for one-day storage of rejected
water, plants not having another alternate disposal method must provide for up to 30 days of storage.
•	Buffer zones, backflow prevention, cross-correction cor.rol programs, limited access, groundwater
monitoring, etc. for the irrigation system must be provided.
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B.2.3.4 ADVANCED WASTEWATER TREATMENT
The following list su^omanzes possible AWT processes to attain desired pollutant removals.
Pollutant
Unit Process
Suspended solids Polishing filter beds — microstrainers
Phosphorous	Chemical precipitation — alum, ferric chloride, lime
Nitrogen
Ammonia air stripping by pH adjustment and carbonation; nitrification and denitrification
with addition of methanol or other carbon source; breakpoint chlorination; amon/ion
exchange (softening) algal ponds
Inorganic salts Reverse osmosis or membrane softening, electrodialysis
Dissolved solids Activated carbon filtration (trace organics or ozonation refractory substances)
Within this appendix, AWT will refer only to nutrient (nitrogen and phosphorus) removal. Below are descriptions
of AWT schemes which are most commonly used for nutrient removal.
*	Ammonia stripping (air s pping) method — Lime is added to water to increase its pH. The water is
passed through a packed . wer into which air is blown, stripping the ammonia out of the water.
Recarbonation follows to re: ove the excess lime.
*	Nitrification and denitrifk. ion process — Bacteria oxidize ammonium ions to nitrate and nitrite in an
aeration tank kept at low BC )5 loading ratios. The nitrites are further oxidized to nitrates, which are then
reduced to molecular nitrog ; in an anoxic environment.
*	Chemical precipitation of hosphorus — Common additives used are alum, ferric chloride and lime.
Disposal of this additional s dge must be addressed when using chemical precipitation.
The basic types of collection systt ,s available include gravity sewers, force mains, septic tank effluent pumping
(STEP) systems, grinder pump sy; ;ms, vacuum systems, individual/OSDSs.
A gravity sewer collection system is composed of a network of sewer pipes that collect wastewater from individual
establishments and convey it to a central location for treatment. The collection network is generally laid out in a
pattern roughly analogous to the branching of a tree. Sewage flow within the network is from the periphery toward
the treatment plant. Sewers are identified according to their location within the network Interceptors are defined as
sewers that connect directly to and convey sewage to the treatment plant. Trunk mains are defined as sewers that
connect directly to and convey to an interceptor.
Gravity sewer systems work best in areas with hilly terrain and low groundwater. For level terrain, pumping
systems are required to "lift" wastewater to create additional gravity flow or to convey sewage under pressure.
Gravity sewers have very limited use in the Florida Keys because of the region's high groundwater, the high cost
of excavation, infiltration problems, and the long distance between many service areas.
B.3 ASTEWATER COLLECTION METHODS
B.3.1 Gravity Sewers
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B.3.2 Force Mains
Force mains carry wastewater from lift or pumping stations to a treatment plant, another lift station, or another point
in the collection system. Practically all wastewater systems in Florida contain force mains because of the relatively
flat topography in the state. The use of force mains will be an important tool in conveying wastewater to the point
of treatment in any option using community or subregional wastewater systems.
B.3.3 Septic Tank Effluent Pump Systems
Septic tank effluent pump (STEP) systems take advantage of existing on-site equipment and are attached to the
downstream side of septic tanks. These systems pump septic tank effluent through a low pressure force main to
the point of treatment or to another higher pressure lift station that conveys effluent through a force main to the
point of treatment. Advantages of STEP systems are that they do not require modification to household plumbing,
require little space, eliminate drainfields, use small diameter piping, reduce organic loading to the treatment plant,
and are less expensive to install than gravity sewers. A disadvantage of STEP systems is that they are somewhat
maintenance-intensive. They also create septic conditions in collection systems with associated gas, odor, and
corrosion problems.
B.3.4 Grinder Pump Systems
Grinder pump systems are similar to STEP systems however, the grinder pump station replaces the septic tank and
acts as a small lift station. Sewage is pumped from the holding basin directly into collector force mains. Grinder
pump systems usually have higher operating pressures than STEP systems, thus the two cannot be used
simultaneously.
Grinder pump systems have further advantages over STEP systems:
•	No septic tank and no septage disposal or handling is necessary.
•	Force main pressures are higher and there is less likelihood of vapor lock occurring in the mains.
•	There is less clogging of pumps by rags and solids.
•	Grinder pumps are more heavy-duty and require less maintenance than septic tank effluent system pumps.
•	Grinder pumps can be installed inside existing septic tanks.
•	Septic conditions in collection systems are reduced.
The disadvantages of grinder pump systems include:
•	Higher initial costs for pumps and force mains
•	Higher BODj loading to treatment plants
•	The requirement for 240 volt service (single phase).
B.3.5 Vacuum Systems
Vacuum systems have been described as curious mixtures of small diameter gravity lines and multiple air lift
stations. Vacuum systems depend on a central vacuum source and small diameter collection mains sloped
downstream. Numerous short lifts (steps or transport pockets) divide the main into separate gravity sections. A
vacuum pressure of IS to 20 in Hg periodically propels the liquid pockets, called slugs, through the transport lift
at a high velocity. The differential pressures and the nature of slugs and gravity flow combine to produce an
operating system. The system can be constructed in shallow conditions and around subsurface obstructions.
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The advantages of vacuum systems over STEP and grinder pump systezrs include:
•	No pumps are installed on private property.
•	STEP and grinder pump systems are replaced with less expensive individual collection valve pits.
•	Dissolved oxygen (DO) in the wastewater is higher.
•	There is centralized power utilization at vacuum stations.
•	Vacuum systems have fewer mechanical components to maintain.
The disadvantages of vacuum systems over STEP and grinder pump systems include:
•	Vacuum systems are not very cost effective for smaller, isolated developments.
•	Power usage must be borne by a public entity.
•	Vacuum systems need more exact grade alignments during installation.
•	Vacuum systems require larger line sizes and have higher installation costs.
•	There are limitations on allowable lift sizes because of the vacuum pressures available.
•	The potential for infiltration is greater.
•	Vacuum systems have less tolerance to flows that exceed design capacity.
B.3.6 On-site Sewage Disposal Systems
OSDSs typically serve single residential units. The collection system is typically a gravity sewer discharging into
the septic tank. Septic tanks should be inspected every two to three years and pumped out every three to five years.
The septage is usually trucked to a wastewater facility for treatment and disposal (or composting).
B.4 EFFLUENT DISPOSAL OPTIONS
Effluent is the treated wastewater that flows out of a treatment plant. Proper effluent disposal is essential to protect
surface waters and groundwaters from environmental degradation. Effluent disposal options include:
•	Ocean outfalls
•	Class V injection wells (boreholes)
•	Aquifer storage and recovery (ASR)
•	Deep injection wells
•	Reuse for irrigation
•	Reuse for potable water
On November 12, 1975, Monroe County adopted the following resolutions concerning wastewater treatment in the
unincorporated parts of the county:
"Monroe County or the developer will provide for adequate wastewater treatment in existing and new
development."
"Centralized public treatment facilities will be developed in urbanized areas as economic feasibility is
evidenced. The Plan (Land Use Plan Update) will require phasing out of septic tanks and package treatment
plants, with hook-ups to these new treatment plants as they become available."
"In new residential subdivisions where planned densities are sufficient to eventually support a central treatment
facility, the use of septic tanks will be permitted only on an interim basis until sufficient development has
occurred to permit the installation of the central treatment system by the developer. New developments will
be required to strictly conform to county and state design and operating standards for septic tanks and package
treatment plants. Development in which private central treatment facilities will be required, will be responsible
3B-15

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for prov ding collection, treatment, and disposal methods that meet design and performance standards
established by the county. New development in areas where public central treatment is available will be
required to provide collection lines at the developer's expense."
B.4.1 Ocean Outfalls
Because of the Outstanding Florida Waters (OFW) designation in Monroe County, it is very difficult to obtain a
new permit from the FDER and Environmental Protection Agency (EPA) to construct an outfall to surface waters
to use as a method of effluent disposal. There are currently six wastewater treatment facilities discharging effluent
via outfall to surface waters in unincorporated Monroe County.
B.4.2 Class V Injection Wells (Boreholes)
Boreholes range in depth from 60 to 90 ft. These shallow Class V injection wells are used in the county as the
prevailing sewage disposal method for centralized systems such as package plants. As reported by the FDER in
January 1988, the secondarily treated effluent being disposed of via these injection wells in the Florida Keys is of
relatively good quality for disposal into Class G-III groundwater. Though additional monitoring of injection wells
by the FDER is scheduled, no violations of the "minimum criteria" for groundwater were found in 20 effluent
samples collected by the FDER in 1988. Further, data collected locally by the FDER Marathon district office has
shown that effluent disposed of in encased wells will have less effect on surface waters than effluent disposed of
in drainfields.
B.4.3 Aquifer Storage and Recovery
ASR is a relatively new technique that involves pumping treated effluent to a confined shallow aquifer (— 500 ft
deep) for future use. The treated effluent forms a "bubble," displacing the native groundwater. The native
groundwater is usually saline, so mixing is minimal. Recovery can take place in the future for irrigation use or
potable retreat merit. The advantage of ASR is that no storage facility needs to be constructed for future use.
B.4.4 Deep Injection Wells
Deep injection wells are large diameter wells (generally 24-36 in) that extend into the boulder zone 2500 to 3000
ft below the land surface. Because of the cavernous nature of the boulder zone, deep injection wells usually have
high disposal capacity. Deep injection wells are much more expensive than Class V injection wells (boreholes),
and if used as a primary method of effluent disposal, two are required by FDER. Use of deep injection wells for
disposal of secondary effluent in the Keys would have to be preceded by geotechnical investigations to assure that
effluent discharged to the boulder zone will not impact nearshore waters.
B.4.5 Reuse for Irrigation
Reuse of water through irrigation is preferred over other methods of effluent disposal that do not reuse or conserve
the water resource or provide additional treatment (see preceding discussion under Section B.2: Wastewater
Treatment Methods). The advantages of water reuse for irrigation are:
•	Application to land removes nutrients from treated wastewater.
•	Pollutant loadings in surface water and groundwater are reduced.
3B-16

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•	Groundwater recharge is provided.
•	Potable water that might otherwise be used as irrigation water is conserved.
Irrigation reuse potential in the Keys is limited by the number of suitable large-scale application sites available.
B.4.6 Reuse for Potable Water
The reuse of wastewater effluent as a source of drinking water is a viable method of effluent disposal. At present,
there are several communities that have potable reuse facilities, but none of any size is located in Florida. The City
of El Paso, Texas has been using a 12 MGD potable reuse facility since 1985. Potable reuse requires an intensive,
multi-step treatment process, with close monitoring of water quality between treatment units. Advantages of potable
reuse include water conservation and the generation of revenues from sale of potable water.
3B-17

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APPENDIX C
Engineering Options for Domestic Wastewater
Collection, Treatment, and Disposal

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ENGINEERING OPTIONS FOR DOMESTIC WASTEWATER
COLLECTION, TREATMENT, AND DISPOSAL
C.l ENGINEERING DEMONSTRATION OPTIONS
Two engineering demonstration options are proposed, one to evaluate alternative (nutrient removal) on-site disposal
systems (OSDSs) and the other to evaluate the replacement of OSDSs with advanced water treatment (AWT)
wastewater treatment plants (WWTPs). The purpose of these demonstration projects is to evaluate the effectiveness
of these technologies on a small scale prior to implementing them on a large scale.
C.l.l Option Wl — Alternate On-site Sewage Disposal System Demonstration Project
C.l.1.1 DESCRIPTION
Three to six of the most promising systems should be selected and then installed according to manufacturer's
specifications. The systems should be maintained for a period of at least one year by contractors currently
performing these services. The level of maintenance should be no greater than that normally given these systems
and the manufacturer's involvement should be limited to input requested for specific problems that are identified.
Monitoring should be conducted or supervised by Florida Department of Health and Rehabilitative Services
(FDHRS) personnel and should include characterization of the influent and effluent waste streams and monitoring
of background (if feasible) and downgradient groundwater quality. Influent and effluent characterization should use
multiple composite sampling of single-day use periods (16 to 18 h) and may require special collecting chambers and
pumps. Parameters analyzed should include all forms of nitrogen and phosphorus, BODj, total suspended solids
(TSS), pH, and fecal coliform. The market potential for an effective system may encourage manufacturers to
participate in sharing the costs of installing the demonstration systems.
C.l.1.2 RATIONALE
At present there are no alternate OSDSs that have been proven to attain consistently high nutrient reduction levels
over the long term in soils of the Florida Keys. To evaluate what role alternative OSDSs should play in overall
wastewater treatment strategies for the Keys, a long-term evaluation of their nutrient removal capabilities in typical
Keys installations should be performed.
C.1.1J COST
The cost of a one-year OSDS demonstration project is estimated to be $35,000 per system. This cost includes
installation of the system and peripheral sampling devices, monitoring wells, sampling and analyses, and data
interpretation and synthesis. The total cost for evaluating three to six alternate OSDSs is estimated to be $105,000
to $210,000.
C.1.2 Option W2 — Advanced Wastewater Treatment Demonstration Project
C.l.2.1 DESCRIPTION
A relatively compact subdivision or portion of a subdivision currently using an OSDS for wastewater disposal would
be selected. Areas where degraded water quality in nearshore or confined waters has been identified and where
OSDS use is suspected to be a primary cause of degraded water quality should be given priority consideration.
Wastewater from individual residences would be collected with septic tank effluent pump systems (STEP) stations
3C-1

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and pumped to one or more intermediate lift stations. If an appropriate site is available, the reuse of wastewater
for irrigation should be considered for effluent disposal. Boreholes would be used for effluent disposal if an
appropriate reuse site cannot be found. Monitoring should include 24-h composite characterization of WWTP
influent and effluent on a regular basis, background and downgradient groundwater monitoring, and monitoring of
confined surface waters adjacent to areas of formerly heavy septic tank use (e.g., dead-end canals). Parameters
analyzed should include all forms of nitrogen and phosphorus, BODj, TSS, pH, and fecal coliform. Most facilities
constructed in this demonstration project could be incorporated into a larger system in the future.
C. 1.2.2 RATIONALE
Data linking OSDS use to degradation of nearshore water quality are very limited. A demonstration project
involving replacement of OSDSs with a package AWT plant and monitoring of its performance will provide valuable
information regarding the practicality and benefits of utilizing AWT package plants.
C.1.2.3 COST
The cost of an AWT demonstration project will be highly dependent on the site selected and size of the system
installed. The total cost of a 5,000 to 10,000 gallons per day (GPD) system is estimated to be $350,000 to
$700,000.
C.2 OPTIONS FOR AREAS OUTSIDE THE CITY OF KEY WEST
Engineering options described in this Appendix use methods or groups of methods discussed in Appendix B to
address sources of wastewater pollution throughout the FKNMS. A wide range of options is considered for each
category of pollution sources. Options generally are listed in order of increasing level of effort and cost of
implementation.
Discussions of options in this Appendix address the City of Key West separately from the rest of Monroe County.
The City of Key West Comprehensive Plan indicates that the City's WWTP is currently providing a high level of
secondary treatment and has adequate capacity to serve that area well beyond 2010. The city is extending service
to all incorporated areas, eliminating OSDS and package plant use. Because of the program being implemented to
reduce the unusually high infiltration and inflow, the existing WWTP will have excess capacity through the Year
2010. Because of these circumstances, the only engineering options considered for wastewater within the City of
Key West are upgrades in effluent disposal. Consideration is given to using excess capacity at the City of Key West
WWTP to treat wastewater from Planning Area Analysis/Enumeration Districts (PAEDs) 1 and 2 (Stock Island to
Big Coppitt Key).
The remaining seven options address wastewater collection and treatment in all Monroe County areas outside the
City of Key West, including the Cities of Layton and Key Colony Beach. The City of Key Colony Beach owns and
operates a wastewater collection and treatment system. Some, or most, of the Key Colony Beach facilities may be
incorporated into community or subregional facilities associated with proposed engineering options. However,
because of the relatively small size of the Key Colony Beach system (0.175 million gallons per day [MGD]), it
should not be a significant factor in the cost of developing a community or subregional wastewater collection and
treatment system. Options considered for unincorporated Monroe County areas include upgrading existing OSDSs
and package plants to current FDHRS and Florida Department of Environmental Regulation (FDER) standards or
to nutrient removal/AWT levels, constructing community systems in Marathon and Key Largo and using the excess
capacity of City of Key West wastewater treatment plant to serve PAEDs 1 and 2. constructing seven community
systems to serve 73% of total wastewater flows, constructing 12 community systems to serve the entire area, or
constructing three subregional systems to serve the entire area.
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New WWTP: using effluent disposal options that the have potential for discharge to nearshore waters (boreholes),
or effluent disposal options requiring high-quality water for potable reuse are assumed to incorporate AWT for
nitrogen and phosphorus removal in the treatment process. Where effluent disposal methods have little or no
potential for discharge to nearshore waters (e.g., deep injection wells or irrigation use out of the Florida Keys),
secondary treatment is assumed to be used. For the purpose of determining reductions in nutrient loading by
increasing treatment levels to AWT, it was nwunwH that all AWT plants produced effluent with a maximum of 6
mg/L total nitrogen and 4 mg/L total phosphorus.
PAEDs, as delineated in the Monroe County Year 2010 Comprehensive Plan, are used to estimate potential service
areas for wastewater collection and treatment systems. Where PAEDs are in close proximity and not separated by
long bridge crossings (e.g., Key Largo area and Upper/Lower Matecumbe), they are aggregated into single
"communities." Table C-l shows wastewater flows for these population centers and the rankings of these centers
by population and by wastewater flow.
C.2.1 Option W3a — Upgrade Existing Systems to Current Standards
C.2.1.1 DESCRIPTION
This option consists of identifying all non-complying OSDSs and package WWTPs and retrofitting or upgrading
these facilities to meet current standards. Specific components of this option are:
•	Continue present level of OSDS use, but bring all systems into compliance with FDHRS current
standards. This would require an extensive OSDS inspection and evaluation program.
•	Continue package plant use for individual developments that require them under current regulations and
bring all existing plants into compliance with FDER regulations for secondary treatment under 1992
standards.
•	Initiate an aggressive program for the identification and elimination of all cesspits.
C.2.1.2 RATIONALE
The rationale for selecting Option W3a would be that if existing substandard wastewater systems are upgraded to
current FDHRS or FDER standards, a significant, cost-effective improvement in water quality over the "No Action"
option would occur. Additionally, a judgment would have to be made that this level of improvement in water
quality would contribute to acceptable long-term water quality conditions within the FKNMS. Additional monitoring
and studies will be required to select this option.
C.2.1.3 POLLUTION REDUCTION
Nutrient reductions associated with this option are summarized in Table C-2 . The overall effectiveness of the
option would be limited because of continued widespread OSDS and cesspit use. The greatest amount of pollutant
loading reduction would result from elimination of cesspits and retrofitting these facilities with FDHRS-pennitted
OSDSs. Lowering total nitrogen and phosphorus from raw sewage levels currently entering cesspits to levels
attained by proper OSDS treatment would reduce total man-induced (wastewater and stormwater) nitrogen and
phosphorus loadings to the FKNMS by an estimated 5% and 10%, respectively.
Nutrient loading reductions from upgrading non-complying OSDSs and package WWTPs cannot be estimated with
any certainty. Because there are only a small number of non-complying FDER-pennitted package WWTPs,
upgrading these few facilities would provide local benefits but would not have a significant impact on overall
nutrient loadings to the FKNMS. The number of non-complying OSDSs is not known and cannot be determined
without an extensive inspection and evaluation program. If it is assumed that 25 % of existing OSDSs are deficient
3C-3

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Table C-l. Average daily flow for Florida Keys wastewater facilities (1991-1992).
PAED"
Key Areas
WWTP
Surface
Water
Discharge
(MGD)
WWTP OSDS
Ground
Water
Discharge
(MOD) (MGD)
Cesspits TOTAL
(MGD) (MGD)
Rank
Population P>

LOWER KEYS







1A
City of Key West
6.5S8
0.294
0.013
0.005
6.870
1
1
I
Stock Island, Cow & Key Haven
0.017
0.138
0.522
0.109
0.786
5
4
2
Boca Chica, Rockland, Big Coppit & Geigcr
0.131
0.145
0.357
0.074
0.707
8
6
3
Siddlebuneh, Upper it Lower Sugarloaf
0.033
0.023
0.205
0.043
0.304
12
12
4
Cudjoe, Summeriand, Ramrod, Torch Keys Si
No Name Key*

0.041
0.459
0.095
0.595
4
8
5
Big Pine Key

0.020
0.484
0.101
0.605
7
7
6
Spanish Harboir, Bahia Honda, Ohio,
Miuouri, Little Duck Sl Pigeon

0.049
0.051
0.011
0.111
16
17

SUBTOTAL
6.739
0.710
2.091
0.438
9.978



MIDDLE KEYS







7
Knight, Vaca (Maiathon), Siirrup & Boot
0.002
0.251
1.019
0.212
1.484
3
3
8
Fit Deer (including Coco Plum), Crawl Si
Little Crawl
0.175
0.020
0.081
0.017
0.293
14
13
9
Grassy

0.012
0.125
0.026
0.163
13
15
10
Duck &20
Key Laigo (Dove, Rock Harbor, Taipon
Basin, Largo Sound Si Blackwater Sound)

0.582
1.306
0.272
2.160
2
2
21
N. Key Largo (Port BouganviUe to
Angelfuh), Cape Sable

0.178
0.205
0.043
0.426
11
11
22
Cross Key to Dade County Line

0.001
0.007
0.002
0.010
18
18

SUBTOTAL
0.002
1.104
2.305
0.480
3.811



TOTAL
6.998
2.341
6.000
1.252
16.511



TOTAL FLOW: ซ Community WWTPปb
0.152
1J35
4.195
0.873
6.475



TOTAL FLOW: 12 Community WWTPsc
0.364
1.875
5.691
1.184
9.03


NA: Not applicable
'Planning Area Anlaysis/Enumeration district as delineated in Monroe County Year 2010 Comprehensive Plan
b Calculated using flows from Key areas ranked 2 through 7
cCalculated using flows from Key areas ranked 2 through 13
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Table C-2. Estimated costs and nutrient lading reductions for wastewater Options W3a, W3b and W3c:
Upgrade existing systens to current or higher treatment standards.
Efflueot Disposal Options
N Reduction*
(*)
P
Reduction*
<*)
fMiaiatol C0St
Cost Effectiveness1
(J millions)
20 Year
O&Mฎ
(S millions)
Total 20
Year*1
(S millioni)
20 Year per
ซe
($)
TN
TP
OPTION W3ซ: Upgrade
existing systems to cumnt
standards
10
17
42
42
1,000-
5,000
4.2
2.5
OPTION W3b: Upgrade
OSDS (o Current Standards
and Upgrade Package PUou
to AWT
27
24
36
64
1,000-
5.000
2.7
1.1
OPTION W3c: Upgrade
Package Plant* to AWT and
Upgrade OSDS to Alternate.
Nutrient-Removing Systems
57
43
306
240
546
2.200-
18.000
10
13
OAM: Operation and maintenance
*Reduction shown is for man-induced loading, including domestic wastewater, live-aboards, and stormwater from develo sd areas. Stormwaier load*
from undeveloped areas, atmospheric deposition, or other nonpoiu sources are not included.
''Initial costs include land acquisition, initial WWTP constiuction, WWTP capacity increases to serve 20-year demands,, d construction of all
collection lystems.
cCosts include labor, administration, repair/replacement, power and chemicals.
^Present worth only; no financing costs included
eCost shown is for present worth of single 250 CPD service connection share of the total cost.
*Cost Effectiveness = Total Cost/Percent of Nutrient Removal
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and that retrofitting will result in a 50% decrease in nutrient loadings for those systems, an overall reduction of 4%
in nutrient loadings to the FKNMS would be realized. Adding this estimated reduction to that	for the
replacement of cesspits with OSDSs would yield an overall reduction in total nitrogen and phosphorus loadings of
10% and 17%, respectively. Although this is a rough estimate, it is probably reasonable for Option W3a.
CJ.1.4 COST
The cost of this option is difficult to estimate. The number of substandard systems or actual number of cesspits
cannot be known until an extensive inspection program is completed. To provide a reasonable order-of-magnitude
estimate for this option, the following assumptions were made:
•	5,000 cesspits would be replaced with OSDSs at an average cost of $5,0Q0 each
•	25 % of the 24,000 OSDSs would require retrofitting at an average cost of $2,500 each
•	40 package WWTPs would require upgrades at an average cost of $50,000 each
The above assumptions yield an estimated implementation cost of $42 million for this option. This estimate does
not include costs for regulatory agencies to implement additional programs, such as the inspection program that
would presumably be undertaken by FDHRS. It also does not include operation and maintenance costs, which
should not increase significantly over existing costs. Costs and pollution reductions associated with all options under
Option W2 are shown in Table C-2.
C J.1.5 IMPLEMENTATION SCHEDULE
A proposed implementation schedule for Option W3a is shown in Figure C-l. This schedule represents a fast-track,
but reasonable approach toward implementation.
C.2.1.6 AFFECTED ENTITIES
Entities that would be affected by this option include owners of non-complying systems and the agencies responsible
for enforcing compliance. Property owners with non-complying systems would be faced with expenses in the
$2,000 to $3,000 range for upgrading an OSDS or in the $4,000 to $6,000 range for replacing a cesspit with a
permitted OSDS. These costs would be significantly higher for owners of larger commercial systems.
Regulatory agencies affected by this option include the FDER, FDHRS, and possibly Monroe County. The FDER
is responsible for regulatory compliance of package WWTPs and is currently pursuing non-complying facilities.
The FDER is also responsible for permitting boreholes (Class V injection wells) used in conjunction with
commercial aerobic OSDSs. Some increase in FDER staff within the Florida Keys may be necessary to effectively
implement this option.
The FDHRS is responsible for OSDS permitting. Under this option, FDHRS would presumably be responsible for
the identification and inspection of suspected non-complying systems. In addition to establishing the authority to
make these inspections, FDHRS staff in the Florida Keys would have to be increased significantly to implement the
inspection program. Monroe County may become involved in this option if county regulations or programs are
established for identifying and requiring the retrofitting of non-complying systems.
C.2.1.7 ENVIRONMENTAL EFFECTS
The environmental effects associated with implementing this option would be limited to temporary disturbance of
small areas associated with package WWTP or OSDS upgrading or replacement. Adverse water quality effects
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DESCRIPTION
| YEAR
1 I 2 I 3 I 4 | 6
6 | 7 I e I 9 I 10
11 | 12 13 | 14 | 16
16 | 17 | IB | 19 | 20
Establish Regulatory Authority
Identify WWTP, OSDS & Cesspit Improvements
Conceptual Plan & Cost Approval
2S3388
Hi
8SE9



Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Program Management

SB


Design Package Plant Improvements
Permit Package Plant Improvements
Construct Package Plant Improvements
mm
m
warn



Design OSDS Improvements
Permit OSDS Improvements
Construct OSDS Improvements


m


Design Cesspit Replacement
Permit Cesspit Replacement
Construct Cesspit Replacement
I
EES8HEHBI
a


Post-Construction Water Quality Monitoring

h—H


Figure C-l. Implementation schedule for Wastewater Option W3a: Upgrade existing facilities.

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could be minimizec by following proper construction practices and by stabilizing disturbed areas immediately after
completing an installation. No significant adverse environmental effects are anticipated with this option.
C.2.1.8 ADDITIONAL MONITORING
If this option is selected, monitoring programs should be designed to provide a greater understanding of:
•	The effects of widespread use of boreholes for effluent disposal on nearshore water quality, shallow
nearshore bottom habitat, and coral reef systems
•	The effects of the City of Key West WWTP ocean outfall on nearshore water quality, offshore water
quality, shallow nearshore bottom habitat, and coral reef systems
•	The relative contribution of stormwater, wet and diy atmospheric deposition, and other nonpoint sources
toward nutrient loading to waters of the FKNMS
C.2.2 Option W3b — Upgrade On-site Sewage Disposal Systems to Current Standards
and Upgrade Package Plants to Advanced Wastewater Treatment
C.2.2.1 DESCRIPTION
Option W3b consists of identifying all non-complying OSDSs and package WWTPs and upgrading substandard
OSDSs to current standards and package WWTPs to AWT. Specific components of this option are:
•	Continue the present level of OSDS use, but bring all systems into compliance with current standards of
the FDHRS. This would require an extensive OSDS inspection and evaluation program.
3 Continue package plant use for individual developments which require them under current regulations and
bring all existing and future plants into compliance with FDER AWT standards.
*	Initiate an aggressive program for the identification and elimination of all cesspits.
C.2.2.2 RATIONALE
The rationale for selecting Option W3b would be that if existing substandard OSDS systems are upgraded to current
HRS standards and all package plants are upgraded to FDER AWT standards, a significant and cost-effective
improvement in water quality over that attained by Option W3a would occur. Additionally, a judgement would be
made that this improvement in water quality would contribute to acceptable long-term water quality conditions within
the FKNMS. Additional monitoring and studies will be required to select this option.
C.2.2 J POLLUTION REDUCTION
Upgrading package WWTPs to AWT under this option would provide significant additional nutrient reduction.
Package WWTPs represent about 2796 of present total wastewater flows in the Florida Keys (excluding Key West).
AWT would reduce total nitrogen from the 40 mg/L range to less than 6 mg/L and would reduce total phosphorus
from about 8 mg/L to less than 4 mg/L. applying these reductions to 27 % of total wastewater flows for Monroe
County, total nitrogen and phosphorus loadings to the FKNMS would be reduced by 17% and 7%, respectively,
over reductions attained by Option W3a. This would result in estimated Sanctuary-wide total nitrogen and
phosphorus reductions of 27 and 24 percent, respectively, as shown in Table C-2.
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C.2.2.4 COST
The cost of retrofitting a package plant for AWT is relatively high; often as high as the original cost of the entire
plant. A unit cost of $6.00 per gallon of wastewater treated was assumed for retrofitting to package plants to AWT.
Cost ftsri mates for Option W3b are shown in Table C-2.
C.2.2.5 IMPLEMENTATION SCHEDULE
A proposed implementation schedule for Option W3b is shown in Figure C-2. This schedule represents a fast-tract,
but reasonable approach toward implementation.
C.2.2.6 AFFECTED ENTITIES
Entities affected by this alternative would be the same as those affected by Option W3a. Residents or commercial
facilities served by package WWTPs would be impacted more than under Option W3a if users of the system share
in the cost of AWT upgrades.
C .2.2.7 ENVIRONMENTAL EFFECTS
The environmental effects of Option W3b would be nearly the same as those listed for Option W3a. These effects
would be limited to temporary disturbances of small areas associated with package WWTP or OSDS upgrading or
replacement. Slightly larger areas would be impacted as a result of additional treatment units required for AWT
upgrades to package WWTPs.
C.2.2.8 ADDITIONAL MONITORING
Before Option W3b is considered, the proposed AWT Demonstration Project (Option W2) should be implemented.
Data acquired during the AWT demonstration project would be useful in determining whether upgrading package
WWTPs to AWT will provide significant, cost-effective benefits with regard to confined or near-shore water quality.
In addition to implementing Option W2, monitoring programs should be designed to provide a greater understanding
of:
•	The effects of widespread use of boreholes for effluent disposal on nearshore water quality, shallow
nearshore bottom habitat, and coral reef systems
•	The effects of the Key West WWTP ocean outfall on nearshore water quality, offshore water quality,
shallow nearshore bottom habitat, and coral reef systems
•	The relative contribution of stormwater, wet and dry atmospheric deposition, and other nonpoint sources
toward nutrient loading to waters of the FKNMS
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DESCRIPTION
YEAR
1 | 2 | 3 | 4 1 6 ~6 | 7 | 8 I 9 | 10 I 11 | 12 | 13 | 14 | 16 I 16 | 17 | 16 | 19 | 20
Establish Regulatory Authority
Identify WWTP, OSDS & Cesspit Improvements
Conceptual Plan & Cost Approval
mmv
Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Program Management


Design Package Plant Improvements
Permit Package Plant Improvements
Construct Package Plant Improvements

Design OSDS Improvements
Permit OSDS Improvements
Construct OSDS Improvements
f ฃ 3 tl 'Z fs
smiw
Design Cesspit Replacement
Permit Cesspit Replacement
Construct Cesspit Replacement

imm
Post-Construction Water Quality Monitoring
f
Figure C-2. Implementation schedule for Wastewater Option W3b: Upgrade OSDSs to current standards and package WWTPs to AWT.

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C.2J. Option W3c — Upgrade On-site Sewage Disposal Systems to Alternate, Nutrient-Removing
Systems and Upgrade Package Plants to Advanced Wastewater Treatment
C.2.3.1 DESCRIPTION
Option W3c consists of identifying all non-complying OSDSs and package WWTPs and upgrading substandard
OSDSs to nutrient-removal systems and package WWTPs to AWT standards. Specific components of this option
are described:
•	Continue present level of OSDS use, but retrofit all systems to alternate, nutrient-removal systems. This
would require an extensive OSDS inspection and evaluation program.
•	Continue package plant use for individual developments that require them under current regulations and
bring all existing and future plants into compliance with FDER AWT standards.
•	Initiate an aggressive program for the identification and elimination of all cesspits.
C.2.3.2 RATIONALE
The rationale for selecting Option W3c would be that if existing package WWTPs are upgraded to AWT standards
and all OSDSs are upgraded to nutrient-removal systems, a significant and cost-effective improvement in water
quality over that attained by Option W3b would be achieved. Additionally, a judgement would be made that this
improvement in water quality would contribute to acceptable long-term water quality conditions within the FKNMS.
Additional monitoring and studies will be required to select this option.
C.2JJ POLLUTION REDUCTION
Independent evaluations of aerobic systems such as the RUCK*, Klargester", Multi-Flow*, or Norweco" systems
indicate nutrient reductions in the 30% to 90% range for total nitrogen. Phosphorus removal can be accomplished
with most of these systems and removals as high as 95 % are claimed by manufacturers. These high nutnent
reduction rates have not been documented for systems in use in the Keys. In order to achieve the higher end of
nutrient reduction ranges, most of these systems must be upgraded and costs are increased accordingly. Replacing
all OSDSs in the Florida Keys with alternative nutrient removal OSDSs would reduce total nitrogen and phosphorus
loading to the FKNMS by about 30% and 19%, respectively, over the reductions attained by Option W3b. This
would result in estimated Sanctuary-wide, man-induced total nitrogen and phosphorus reductions of 57 % and 43 %,
respectively, as shown in Table C-2.
C.2.3.4 COST
The cost of retrofitting package plants to AWT is estimated at $6.00 per gallon of wastewater treated. Alternate,
nutrient-removal systems range in cost from $6,000 (if substantial portions of the existing OSDS are used) to
$15,000. The system(s) used would depend on outcome of the OSDS demonstration project. To estimate costs for
this option, a mid-range initial cost of $10,000 per system was used. Current contract operating costs for these
systems are about $400 per year. A summary of estimated costs for Option W3c based on these assumptions is
shown in Table C-.2.
3C-11

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C.2J.5 IMPLEMENTATION SCHEDULE
A proposed implementation schedule for Option W3c is shown in Figure C-3. This schedule represents a fast-track,
but reasonable approach toward implementing this option.
C.2.3.6 AFFECTED ENTITIES
Entities affected by this alternative are similar to those listed for Option W3a, but the effects will be much more
widespread. Virtually all residential and commercial wastewater facilities would be required to undergo expensive
upgrades, with a good portion of the cost presumably borne by the system owners. Regulatory agencies with
responsibility for implementing this option (FDER for package plants and FDHRS for OSDSs) would require
substantial staffing increases. Monroe County would most likely be affected also, depending on the role the County
assumes in implementing this option.
C.2J.7 ENVIRONMENTAL EFFECTS
The environmental effects of Option W3c would consist primarily of temporary disturbances to all areas served by
OSDSs during retrofitting or replacement with nutrient-removal systems. Becr.use of the number of individual sites
affected (nearly 24,000), these numerous disturbances would have potential for elevating sediment levels in
nearshore waters. Construction impacts could be minimized by controlling runoff on construction sites and
stabilizing construction areas upon completion. Package plant AWT upgrades would affect somewhat larger sites,
but because of the smaller number of package plants, the overall impact should be considerably less than OSDS
retrofitting.
C.2J.8 ADDITIONAL MONITORING
Prior to considering Option W3c, the proposed AWT Demonstration Project (Option W2) and the proposed OSDS
Demonstration Project (Option Wl) should be implemented. Data acquired during the AWT Demonstration Project
would be useful in determining whether upgrading package WWTPs to AWT will provide significant, cost-effective
benefits with regard to confined or near-shore water quality. The OSDS Demonstration Project is necessary to
determine whether alternate, nutrient-removal OSDS(s) are available that will achieve long-term, consistent nutrient
reduction in soils of the Keys. This project will provide nutrient removal data that can be used to compare OSDS
nutrient removal and costs with package AWT WWTP or community AWT WWTP nutrient removals and costs.
In additional to implementing Options W1 and W2 demonstration projects, monitoring programs should be designed
to provide a greater understanding of:
•	The effects of widespread use of boreholes for effluent disposal on nearshore water quality, shallow
nearshore bottom habitat, and coral reef systems
•	The effects of the City of Key West WWTP ocean outfall on nearshore water quality, offshore water
quality, shallow nearshore bottom habitat, and coral reef systems
•	The relative contribution of stormwater, wet and dry atmospheric deposition, and other nonpoint sources
toward nutrient loading to waters of the FKNMS
3C-12

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DESCRIPTION
Establish Regulatory Authority
identify WWTP, OSOS & Cesspit Improvements
Conceptual Plan & Cost Approval
il2la|4|Ble|7|e|9|
YEAR
10
11 | 12 | 13 | 14 | 15
16 | 17 | 18 | 19 | 20
Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Program Management
Design Package Plant Improvements
Permit Package Plant Improvements
Construct Package Plant Improvements
Design OSDS Improvements
Permit OSDS Improvements
Construct OSDS Improvements
Design Cesspit Replacement
Permit Cesspit Replacement
Construct Cesspit Replacement



Post-Construction Water Quality Monitoring
Figure C-3. Implementation schedule for Wastewater Option W3c: Upgrade OSDSs to alternate, nutrient-removing systems
and package WWTPs to AWT.

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C.2.4 Option W3d — Construct Two Community Wastewater Systems for Marathon and Key Largo
and Use Excess Capacity of Key West Wastewater Treatment Plant in Lower Keys
C.2.4.1 DESCRIPTION
Option W3d involves the construction of two community wastewater collection and treatment systems to serve the
Marathon and Key Largo areas. A wastewater collection system would be constructed in the lower Keys to serve
areas from Key West to Big Coppitt Key and convey these flows to the City of Key West WWTP. This option
would provide AWT for 52% of wastewater flows outside the City of Key West. Essential features of this option
are:
•	Construct two community wastewater collection systems and AWT WWTPs to serve the Marathon and
Key Largo areas (PAED 7 and 16-20, respectively). Use STEP Systems to replace drainfields for
residences currently served by septic tanks.
•	Continue an infiltration/inflow reduction program for City of Key West WWTP on an accelerated
schedule.
•	Construct a community wastewater collection system serving all areas between Key West WWTP service
area and east end of Big Coppitt Key (PAEO 1 & 2). Utilize STEP system in areas presently served by
septic tanks. This wastewater flow would be conveyed to the City of Key West WWTP for treatment.
•	Use aquifer storage for effluent disposal at Key West; use boreholes for effluent disposal at Marathon and
Key Largo.
•	Continue OSDS/package plant use in all areas outside subregional plant service areas. Upgrade all
existing OSDSs and package plants to meet current regulations.
•	Initiate an active program for the identification and elimination of all cesspits. Development using
cesspits would either be served by OSDSs/package plants or community WWTPs, depending on location.
•	Collection system suboptions:
(a)	Grinder pump system transmission from source
(b)	Vacuum system collection from source
•	Effluent disposal suboptions:
(a)	Aquifer storage (all three systems)
(b)	Deep well injection (reduce treatment level to secondary)
(c)	Reuse for potable water with aquifer storage and recovery
(d)	Reuse for irrigation (reduce treatment level to secondary/irrigation quality)
Service areas for the three community wastewater systems are shown in Figures C-4 through C-6. Cost estimates
for Option W3d aซgmrw 100% connection of wastewater flows within the PAEDs served. There may be a small
number of residences in outlying areas within the PAEDs served that may not be practical to connect to the
community wastewater system. Continued service by existing or upgraded OSDSs to the small number of outlying
residences will not significantly impact nutrient removal or cost estimates.
C.2.4.2 RATIONALE
According to the City of Key West Comprehensive Plan (Tables IV-7 and IV-8), the Key West WWTP will have
0.4 MGD excess capacity in 1995 and 1.9 MGD excess capacity in 2010. The projected increases in excess
capacity allow for increases in sanitary flows and are created by reducing infiltration and inflow to the WWTP.
3C-14

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ฆ 1 Key West. WWTP Service Area
"ฆ "ฆ Extension of Key West WWTP Service Area
(j) PAED Designation
Lower Keys
Figure C-4. Wastewater Option W3d: Construct two	WWTh • Lower Keys (Scale: 1" ซ 6000').

-------

4
y
. y>ป
... • 0^ ฐ
*
( .
'o
ob .
0
1
ฃ
oO# 0


-------
WWTP Service Area
7) PAED Designation
Approximate WWTP Location
Upper Keys
Figure W. Wastewater Option W3d: Construct two community WWTh - Upper Keys (Scale: 1" ฆ 6000').

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The Key West WWTP is experiencing very high infiltration and inflow,.which is currently estimated to be 36% of
total flow. Excess capacity at the Key West WWTP may be sufficient Unserve much of the lower Keys. Extending
the service area for the Key West WWTP as far east as practical, coupled with construction of community AWT
wastewater systems for the two most populated communities in the middle and upper Florida Keys (Marathon and
Key Largo) would provide central sewer service for about 73 % of all wastewater flows in the Florida Keys and 52%
of wastewater flows outside the present City of Key West service area. The rationale for selecting this option would
be that by providing AWT for 32% of wastewater flows outside the City of Key West, a significant long-term
improvement in water quality would be realized over that attained by implementing Option W3c. It would also have
to be demonstrated that Option W3d is more cost-effective than Options W3a, W3b and W3c. Additional
monitoring and studies would have to be completed to select this optiod
C.2.4.3 POLLUTION REDUCTION
For the 3.6 MGD combined flow of the Marathon and Key Largo communities, treatment level would be upgraded
from virtually no treatment (cesspits), OSDS treatment or secondary treatment to AWT. Total nitrogen in these
waste streams would be reduced from the 30-70 mg/L range to less than 6 mg/L. Total phosphorus would be
reduced from the 8-24 mg/L range to less than 4 mg/L. Nutrient reductions for the base option are estimated to
be 43 % for total nitrogen and 28 % for total phosphorus.
If aquifer storage, deep well injection or reuse for potable water is selected for these two systems, nutrient loadings
from effluent disposal would be effectively reduced to zero. Nutrient loadings from reuse for irrigation can be
minimiT<ปH by optimization of application rates. For the 1.8 MGD combined flow that would be connected in the
Key West to Big Coppitt Key area, aquifer storage of treated effluent would effectively isolate nutrients from waters
of the FKNMS and that nutrient loading to the FKNMS would cease.
A summary of pollution reduction estimates for all suboptions included under Option W3d is given in Table C-3.
C.2.4.4 COST
The total estimated 20-year cost of the base option would be about $289 million. This cost includes $184 million
in initial costs for land acquisition, WWTP construction, WWTP capacity increases to serve 20-year demands, STEP
systems, force mains, and lift stations. It also includes the estimated present worth for 20-year operation and
maintenance cost, S10S million. Estimates for operation and maintenance are based on a 6% annual inflation rate
and include labor, administration, repair/replacement, power and chemicals. Estimated costs for all suboptions
associated with this option, including equivalent a 20-year share for a single 250 GPD connection, are summarized
. in Table C-3.
C.2.4.5 IMPLEMENTATION SCHEDULE
A proposed implementation schedule for base Option W3d is shown in Figure C-7. This is a fast-track schedule,
but it could be compressed or extended as priorities and funding may dictate. Aquifer storage or deep well injection
disposal suboptions would not impact the schedule significantly, but reuse for potable water would extend the
schedule an estimated two years.
C.2.4.6 AFFECTED ENTITIES
Entities affected by this option include users of the wastewater systems (wastewater generators) and regulatory
agencies involved in permitting and monitoring compliance of the systems. The main effect this option would have
on users of the system would be sharing the costs of construction and operation. The degree to which residential
3C-18

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Table C-3.	costs and nutrient loading reductions for wastewater Option W3d: construct two
community wastewater systems for marathon and Key Largo and utilize excess capacity of
Key West YVWTP in Lower Keys.
Effluent Disposal Option*
. N Reduction1
(*)
P Reduction1
(*)

Fil*—Cost

Coat
Effectiva
	f
Ioitulb
($ millions)
20 Year
O&M0
($ millions)
Total 20
Year*
(J millions)
20 Year per
Connection^
($)
TN
TP
BASE OPTION*
43
28
1S4
103
289
12.900
6.7
10
COLLECTION SYSTEM OPTIONS








Grinder Pump Stations
0
0
+ 11
-4
+7
310
N/A
N/A
Vacuum Systems
0
0
+9
-6
+3
+ 130
N/A
N/A
EFFLUENT DISPOSAL OPTIONS








All Deep Well Injection'1
+5
+ 12
-4
-2
-6
-30
-1.2
-0.5
All Potable Reuse'J
+5
+ 12
+42
+32
+74
+3,600
1.5
6.2
All Irrigation Reuael
+4
+9
+ 16
+ 12
+28
+ 1,250
7
3.1
O&M: Operation and maintenance
"Reduction shown is for man-induced loading, including domestic wastewater, live-aboards. and stormwater from developed areas. Stormwater loads
from undeveloped areas, atmospheric deposition, or other nonpoint sources are not included.
'^Initial costs include land acquisition, initial WWTP construetion, WWTP cspacity increases to serve 20-)'ir demands and construction of all
collection systems.
"Com include labor, administration, repair/replacement, power and chemicals.
^Present worth only, no financing coos included
ฆCost shown is for present worth of single 230 GPD service connection share of the total cost.
Eost Effectiveness " Total Cost / Percent of Nutrient Removal
*Base Option W3d includes STEP collection, borehole effluent disposal for Marathon St Key Largo and ^ lifer storage effluent disposal for the
Cay of Key West.
|*Costs for deep well injection option include reduction in treatment costs from reducing treatment level ft ;m AWT to Secondary.
jCosts for potable reuse do not include revenues from the sale of potable water.
JCosts for reuse options assume aquifer storage and recovery will be used.
3C-19

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DESCRIPTION
1 year |
1 1 2 | 3 1 4 1 6
6 | 7 | 8 | 9 | 10
11 | 12 | 13 | 14 | 16
16 | 17 | 18 | 19 20
Establish Regulatory Authority
Identify WWTP, OSOS & Cesspit Improvements
Conceptual Plan & Cost Approval
mmm
11



Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Land Acqusition
B8
—


Design Wastewater Treatment Facilities
Permit Wastewater Treatment Facilities
Construct Wastewater Treatment Facilities
EHB
mi
m
WEA
Wmm


Design Wastewater Collection Systems
Permit Wastewater Collection Systems
Construct Wastewater Collection Systems
181
m
WL
mmma


Design OSDS System Improvements
Permit OSDS System Improvements
Construct OSDS System Improvements
nm
BBS
BBS
msmrnm







Post-Construction Water Quality Monitoring

Figure C-7. Implementation schedule for Wastewater Option W3d: Construct two community WWTPs.

-------
and non-residential users would participate in this cost sharing depends on funding mechanisms established to
implement this option.
Primary areas of regulatory responsibility and authority would be:
•	Florida Department of Community Affairs (FDCA) — reviewing wastewater master plans for consistency
with comprehensive plan goals, policies, and objectives
•	Monroe County — deciding whether county, Florida Keys Aqueduct Authority (FKAA), or another entity,
will assume responsibility for a regional utility and the issuance of building and utility right-of-way
permits required for construction
•	FDER — permitting of wastewater collection and treatment systems and compliance/enforcement once
system is in operation.
•	Environmental Protection Agency (EPA) — only involved if NPDES permits are issued for emergency
discharges or reuse for potable water option is selected
•	Florida Department of Transportation (FDOT) — permitting of bridge crossings and facilities on FDOT
right-of-way
•	Cities — issuance of building and utility right-of-way permits required for construction
•	Florida Keys Aqueduct Authority (FKAA) — major role if delegated responsibility of wastew ar utility
by Monroe County or if reuse for potable water option is selected; minor role in resolving utilis conflicts
with potable water systems if not delegated responsibility of wastewater utility
•	FDHRS — identifying and retrofitting substandard OSDSs and cesspits outside the servic. areas of
subregional WWTPs; would require an increase in personnel.
C.2.4.7 ENVIRONMENTAL EFFECTS
The environmental effects of implementing this option would be limited to relatively short-term impacts jsociated
with construction activities. Overall land requirements would be low (probably in the 8-12 acre range- And, with
proper sizing, should constitute a very minor effect. Construction of WWTPs and the extensive collectun systems
would create the potential for increased sediment loads in runoff. These would be short-term effects that could be
minimized with prudent construction practices (e.g., use of sediment control devices, where appropriate, and re-
establishment of cover on disturbed areas). The deep well injection suboption would preclude any reuse of effluent
(permanent loss of resource), while aquifer storage or reuse suboptions maximize use of water resources.
C.2.4.8 ADDITIONAL MONITORING
There is abundant circumstantial evidence and some scientific evidence indicating that nutrients discharged from
wastewater treatment and disposal systems within the Florida Keys are adversely affecting water quality within the
FKNMS. Under ideal circumstances, it would be desirable to determine whether reducing nutrient loading to levels
attained by this option would have a significant positive effect on nearshore water quality, shallow nearshore bottom
habitat, and coral reef systems. Unfortunately, obtaining a clear understanding of exactly what extent of water
quality degradation within the FKNMS can be attributed to wastewater would be very expensive and may take years
of study or may not be possible at all.
3C-21

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Considering the difficulty, cost, and time constraints of pinpointing cause-and-effect relationships between
wastewater systems and FKNMS water quality, a more practical approach should be considered. A decision as to
what methods of wastewater treatment and disposal are acceptable for the Florida Keys may have to be based on
existing knowledge and data. Since most "action" options have significant planning and design periods preceding
construction, it would be advisable to pursue OSDS and AWT demonstration projects (Options W1 and W2) on a
fast trick to increase information available for future decision-making.
In addition to these demonstration projects, monitoring in other areas would be beneficial with regard to increasing
the current database and providing additional information for future decision-making. Areas where additional
information would be helpful include:
•	FKNMS background water quality
•	The effects of widespread use of boreholes for effluent disposal on nearshore water quality, shallow
nearshore bottom habitat, and coral reef systems
•	The effects of cesspit and OSDS use on nearshore water quality, shallow nearshore bottom habitat, and
coral reef systems
•	The relative contribution of stonnwater, wet and dry atmospheric deposition, and other natural nonpoint
sources toward nutrient loading to waters of the FKNMS.
If this option is selected, a post-implementation monitoring program should be developed to determine the effects
of reduced nutrient loading on nearshore water quality, shallow nearshore bottom habitat, and coral reef systems.
C.2.5 Option VV3e — Construct Seven Community Wastewater Treatment Plants
for Most Densely Populated Areas
C.2.5.1 DESCRIPTION
The f ^ven service areas for community wastewater systems in unincorporated Monroe County were selected by
startin g with the highest flow ranking (excluding Key West) and adding areas with successively lower rankings until
at lea.t 70% of the flow was accounted for. These areas and the estimated design flows for the community plants
serving them are shown in Table C-4. Service areas and plant locations are shown in Figures C-8 through C-10.
The essential features of this option are:
•	Construct seven community AWT WWTPs for the Key Largo, Marathon, Stock Island to Key Haven,
Plantation, Boca Chica, Big Pine, and Cudjoe/Summerland areas. These seven plants would
accommodate about 73 % of wastewater flows from Keys areas, excluding Key West.
•	Construct wastewater collection systems within the service areas of each community plant. Collection
systems for the areas presently served by OSDSs would utilize STEP systems to replace drainfields and
boreholes. Use of gravity sewers would be limited to service laterals or short collectors to lift stations on
compact commercial or multi-family residential development.
•	Use boreholes for effluent disposal.
•	Continue OSDS/package plant use in all areas outside community plant service areas. Upgrade all
existing OSDSs and package plants to meet current regulations.
•	Initiate an active program for the identification and elimination of all cesspits. Development using
cesspits would either be served by OSDSs/package plants or community plants, depending on location.
3C-22

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Table C-4. Design capacities of seven community WWTPs serving 73% of
unincorporated Monroe County wastewater flow, e u: ng the City of Key West.
Key Areas

PAEDฎ
1992 Average
Daily Flow -
(MGD)
1992
Rank.
2002
2012
Key Largo

16-20
2.16
3.2
3.9
4.5
Knight, Vaca (Marathon), Stirrup & Boot

7
1.48
2.2
2.6
3.1
Stock Island, Cow & Key Haven

1
0.79
1.2
1.4
1.6
Plantation

14
0.73
1.1
1.3
1.5
Boca Chica, Rockland, Big Coppit & Geiger

2
0.70
1.1
1.3
1.4
Big Pine Key

5
0.61
0.9
1.1
1.3
Cudjoe, Summerland, Ramrod, Torch Keys & No Name Keys
4
0.60
0.9
1.1
1.2

TOTAL

7.07
10.6
12.7
14.6
aPlanning Area Analysis/Enumeration District as delineated in Monroe County Year 2010 Comprehensive Plan
3C-23

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ฆฆ ฆ" WWTP Service Area
d
PAED Designation
Approximate WWTP Location
Lower Keys

-------

\
ฆi
f-
y

0ซป .
WWTP Service Areo
7) PAED Designation
Approximate WWTP Location
0^ ฐ

Upper *0
Matecumbo >
Key	#v 'Cj
Middle Keys
Figure C-9. Wastewater Option VV3e: Construct seven community WWTPS - Midi) ys (Scale: 1" ฆ 6000')*

-------

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•	Collection Syixm Suboptions:
(a)	Grinder pump transmission from source
(b)	Vacuum system collection from source
•	Treatment Suboption: Use excess capacity at City of Key West WWTP to serve PAEDs 1 and 2.
•	Effluent Disposal Suboptions:
(a)	Aquifer storage
(b)	Deep well injection (reduce treatment level to secondary)
(c)	Reuse for irrigation within Keys (reduce treatment level to secondary/irrigation quality)
(d)	Reuse for irrigation in areas outside Keys (reduce treatment level to secondary/irrigation quality)
(e)	Reuse for potable water
As with Option W3d, there may be outlying residences within the service areas of community WWTPs that would
be more practically served by existing or upgraded OSDSs than by community systems. This small number of
residences utilizing OSDSs will not affect pollutant reduction or cost estimates for this option.
C.2.5.2 RATIONALE
The rationale for selecting Option W3e would be that the increased level of wastewater collection and treatment
over that afforded by Option W3d would produce a significant, long-term increase in FKNMS water quality.
Additionally, a judgment would have to be made that this level of improvement in water quality would result in
acceptable long-term water quality conditions within the FKNMS. Additional monitoring and studies will have to
be completed to select this option.
C.2.5J POLLUTION REDUCTION
For the 73% of wastewater flows connected to the plants, treatment level would be upgraded from virtually no
treatment (cesspits), OSDS treatment, or secondary treatment to AWT. The effectiveness of this option for nutrient
removal increases significantly if optional disposal methods are used that minimize the potential for entry of effluent
into shallow groundwater or nearshore waters. Deep wells, reuse for irrigation in areas outside Keys, or reuse
for potable water will effectively prohibit treated effluent from entering the waters of FKNMS. Nutrient loading
reductions associated with various suboptions for Option W3e are summarized in Table C-5. The base option will
reduce overall man-induced nitrogen and phosphorus loading to the FKNMS by an estimated 58% and 35%,
respectively.
C.2.5.4 COST
The total estimated 20-year cost of the base option with STEP system collection from septic tanks is $419 million.
This cost includes $265 million initial costs and 5154 million for 20-year operation and maintenance. Suboptions
included with Option W3e for wastewater collection and effluent disposal have a significant effect on the total cost.
A summary of cost and nutrient removal effectiveness for all suboptions included with this option is given in
Table C-S.
3C-27

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Table C-5. Estimated costs and nutrient loading reductions for
wastewater Option W3e: construct, seven community WWTFs.
N Reduction* P Reduction11 Eitimซtw> Cods Coซt
Effluent Disposal Options	(%)	(*)		EffecriTtcg/



Initial1*
($ millions)
20 Year
o&sf
(J millions)
Total
20 Year*
(5 millions)
20 Year per
Coonectiaae

TN
TP
BASE OPTION*
38
35
265
154
419
14,800
7.2
12
COLLECTION SYSTEM OPTIONS








Grinder Pump Stations
0
0
+27
-5
+22
+780
N/A
N/A
Vacuum Systems
0
0
+ 15
-8
+7
+250
N/A
N/A
TREATMENT OPTION
0
0
-18
-13
-31
-1,100
N/A
N/A
Utilize City of Key West








WWTP Excess Capacity








for PAED's 1 & 1








EFFLUENT DISPOSAL OPTIONS








Deep Well Injection''
+8
+ 16
+ 11
+8
+ 19
+671
24
1.2
Irrigation Reuse within Keys'
-1-8
+ 16
+90
+60
+ 150
+5,300
25
13
Irrigation Reuse out of Keys'
-1-6
+ 12
+48
+32
+80
+2,800
10
5
Pouble Reuse1*)
+8
' +16
+63
+46
+ 109
+3,900
14
6.8
O&M: Operauon and miiiuenince
*Reduction ihown is for man-induced loading, including domestic wastewater, tive-aboards, and stormwaier from developed areas Slormwater loada
from undeveloped areas, atmospheric deposition, or other nonpoim sources are not included.
''Initial costs include land acquisition, initial WWTP construction, WWTP capacity increases to serve 20-year demands and construction of all collection systems.
cCosta iir-1'"1" labor, administration, repair/replacement, power and chemicals.
dPresent worth only; no financing costs included
'Cost shown is for pre sent worth of single 250 GPD service connection share of the total cost.
*Cost Eflectiveneaa " Total Cost/Percent of Nutrient Removal
FBase Option W3e includea STEP collection and borehole effluent disposal.
™Costs for deep well injection option include reduction in treatment coas for reducing treatment level from AWT to secondary.
'Costs for reuse options assume aquifer storage and recovery will be used.
JCosts for potable reuse do not include revenues from sale of potable water.
3C-28

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C.2.5.5 IMPLEMENTATION SCHEDULE
A fast-track implementation schedule for Option W3e is shown in Figure C-ll. This schedule could be compressed
or extended as priorities and funding dictate. If intensive effluent disposal suboptions such as the reuse of effluent
for potable or irrigation water are selected, the schedule would be extended an estimated two years.
C.2.5.6 AFFECTED ENTITIES
Entities affected by Option W3e are identical to those affected by Option W3d (see Section C.2.4.6). These entities
are primarily wastewater generators (cost effects) and regulatory agencies (program implementation, permitting, and
compliance).
C.2.5.7 ENVIRONMENTAL EFFECTS
The environmental effects of Option W3e are similar to but greater in extent than those of Option W3d (see Section
C.2.4.7). Overall land requirements for facility construction would be in the 28 to 42 acre range. Short-term
construction effects could be minimis with prudent construction practices.
C.2.5.8 ADDITIONAL MONITORING
The monitoring needs for this Option are the ซwiซ as those listed for Option W3d (see Section C.2.4.8).
C.2.6 Option W3f — Construct 12 Community Wastewater Treatment Plants for All Areas
C.2.6.1 DESCRIPTION
This option is similar to Option W3e, except that 12 community WWTPs with the potential to serve all the Florida
Keys areas outside of Key West would be constructed. The base option provides sewer service with STEP system
collection for 94% of wastewater flow generated in the Florida Keys, excluding the City of Key West. Suboptions
are considered for source collection (grinder pumps or vacuum systems). General service areas and estimated
design flows for the 12 community plants are shown in Table C-6. Service areas and plant locations are shown
in Figures C-12 through C-14. Essential features of this option are:
•	Construct 12 subregional plants to serve the 12 highest flow areas in the Keys (See Appendix B, Table
B-l). These 12 plants would accommodate about 94% of wastewater flows from Keys areas excluding
Key West.
•	Construct wastewater collection systems within service areas of each subregional plant. Use STEP
systems for transmission of wastewater from sources. Suboptions are included to replace the entire OSDS
with grinder pump stations or vacuum collection systems. Limit the use of gravity sewers to service
laterals or short collectors to lift stations on compact commercial or multi-family residential development.
•	Use boreholes for effluent disposal.
•	Continue OSDS/package plant use only in low-density or remote areas. Upgrade all existing OSDSs and
package plants to meet nutrient removal standards or AWT.
•	Initiate an active program for the identification and elimination of all cesspits. Development utilizing
cesspits would either be served by OSDSs/package plants or subregional plants, depending on location.
3C-29

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DESCRIPTION
1 | 2 | 3 | 4~TT
I 7 I 6 I
YEAR
10
11 | 12 | 13 | 14 | 16
16 | 17 | 18 | 19 | 20
Establish Regulatory Authority
Identify WWTP, OSOS & Cesspit Improvements
Conceptual Plan & Cost Approval
Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Land Acqusition
Design Wastewater Treatment Facilities
Permit Wastewater Treatment Facilities
Construct Wastewater Treatment Facilities
Design Wastewater Collection Systems
Permit Wastewater Collection Systems
Construct Wastewater Collection Systems

Design OSDS System Improvements
Permit OSDS System Improvements
Construct OSOS System Improvements

Post*Construction Water Quality Monitoring
Figure C-ll. Implementation scheuu,.; ....	W3e: Construct seven community WWTPS.

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Table C-6. Design capacities of twelve community WWTPs serving 94% of
unincorporated Monroe County wastewater flow, excluding the City of Key West
Key Areas

PAEDa
1992
Average
Daily Flow
(MGD)
1992
Rank
2002
2012
Key Largo

16-20
2.16
3.2
3.9
4.5
Knight, Vaca (Marathon), Stirrup 6c Boot

7
1.48
2.2
2.6
3.1
Stock Island, Cow & Key Haven

1
0.79
1.2
1.4
1.6
Plantation

14
0.73
1.1
1.3
1.5
Boca Chica, Rockland, Big Coppit & Geiger

2
0.70
1.1
1.3
1.4
Big Pine Key

5
0.61
0.9
1.1
1.3
Cudjoe, Summerland, Ramrod, Torch Keys & No Name Keys
4
0.60
0.9
1.1
1.2
Lower Key Largo (Tavemier)

IS
0.48
0.72
0.86
1.0
Lower & Upper Matecumbe

12 & 13
0.46
0.69
0.82
0.95
North Key Largo

21
0.43
0.65
0.77
0.89
Saddlebunch, Upper & Lower Sugarioaf

3
0.30
0.45
0.53
0.62
Fat Deer

8
0.29
0.44
0.52
0.60

TOTAL

9.03
13.55
16.20
18.66
'Planning Area Analysis/Enumeration District as delineated in Monroe County Year 2010 Comprehensive Plan
3C-31

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City ot
Key West
u>
O

ฉ
o"


d
WWTP Service Area
PAED Designation
Approximate WWTP Location
Lower Keys
Figure C-12. Wastewater Option W3f: Construct 12 community WWTPs - Lower Keys (Scale: 1" " €000').

-------
Fioiiit C-14. Wastewater Option W3f: Const)
community WWTPs - Upper Keys (Scale: 1"
6000').

-------
WWTP Service Area
PAED Designation
Approximate WWTP Location
Figure C-13. Wastewater Option W3f: Construct 12 or
^ \
ฉ i
y
*
< •

cO'
• J>
o
OnO
ocป .
Middle Keys
1 WWTP* - Middle Keys (Scale: 1" - 6000').

-------
•	Collection System Suboptions:
(a)	Grinder pump transmission from source
(b)	Vacuum system collection from source
•	Treatment Suboption: Use excess capacity at City of Key West WWTP to serve PAEDs 1 and 2
•	Effluent Disposal Suboptions:
(a)	Aquifer storage
(b)	Deep well injection (reduce treatment level to secondary)
(c)	Reuse for irrigation within Keys (reduce treatment level to secondary/irrigation quality)
(d)	Reuse for irrigation in areas outside Keys (reduce treatment level to secondary/irrigation quality)
(e)	Reuse for potable water
C.2.6.2 RATIONALE
The rationale for selecting Option W3f would be that nearly all wastewater flows within the Keys should be
connected to community systems and given a higher level of treatment than that provided by Option W3e to achieve
the desired level of water quality in the FKNMS. Additionally, a judgment would have to be made that this level
of improvement in water quality would contribute significantly to acceptable long-term water quality conditions in
the FKNMS. Additional monitoring and studies will be required to select this option.
C.2.6J POLLUTION REDUCTION
For the base option, treatment level for 94% of wastewater flows from unincorporated Monroe County would be
upgraded from virtually no treatment (cesspits), OSDS treatment, or secondary treatment to AWT. Overall nutrient
loading reductions for each option associated with Option W3f are summarized in Table C-7. The base option
would reduce overall man-induced nitrogen and phosphorus loading in the FKNMS by an estimated 72% and 43 %,
respectively.
C.2.6.4 COST
The total estimated 20-year cost of the base option with STEP system collection from septic tanks would be about
$607 million. This cost includes $368 million initial cost and $239 million for 20-year operation and maintenance
costs. Suboptions included for wastewater collection and effluent disposal have a significant affect on cost and
nutrient loading reduction estimates for Option W3f. A summary of costs and nutrient removal effectiveness
associated with these suboptions is given in Table C-7.
C.2.6.5 IMPLEMENTATION SCHEDULE
A fast-track implementation schedule for Option W3f is shown in Figure C-15. This schedule could be compressed
or extended as priorities and funding dictate. If intensive effluent disposal suboptions such as the reuse of effluent
for potable or irrigation water are selected, the schedule would be extended an estimated two years.
3C-35

-------
Table C-7. Estimated costs and nutrient loading reductions for
wastewater Option W3f: construct twelve community WWTPs.
Effluent Disposal Option*
N Reduction1
(%)
P
Reduction*
(*)

Firiwift1
Led Cott

Coat
Effectives
MBSf
Initial''
(J millions)
20 Year
0&Mฐ
(S millions)
Total 20
Year*1
(5 millions)
20 Year per
Connection^
(S)
TN
TP
BASE OPTION*
72
43
368
239
607
16,900
8.4
14
COLLECTION SYSTEM OPTIONS








Grinder Pump Stations
0
0
30
-7
+23
+640
N/A
N/A
Vacuum Systems
0
0
17
-10
+ 7
+200
N/A
N/A
TREATMENT OPTION








Utilize City of Key West
0
0
-18
-13
-31
-900
N/A
N/A
WWTP Excesa Capacity








for PAEDa 1 St 1








EFFLUENT DISPOSAL OPTIONS








Deep Well Injection''
+ 11
+ 20
+40
+25
+65
+ 1,800
5.9
1.3
Irrigation Reuse within Keys'
+ 7
+ 15
+ 120
+ 80
+ 200
+5.500
29
13
Irrigation Reuse out of Keys'
+ 11
+ 20
+48
+32
+ 80
+2,200
7.3
4
Potable Reuse1
+ 11
+20
+80
+50
+ 130
+3,600
12
7
O&M: Operaiion and maintenance
'Reduction shown 11 for primarily man-induced loading, including domestic wastewater, live-aboards, and ttormwater from developed areas. Stormwatcr loads
from undeveloped areas, atmospheric deposition, or other nonpoim sources are not included.
bInitial cosu include land acquisition, initial WWTP constniction, WWTP capacity increases to serve 20-year demands and construction of all collection systems.
^Costs include labor, administration, repair/replacement,- power and chemicals,
present worth only; no financing cosu included
Host shown is for present worth of single 250 CPD service connection share of the total cost.
Tost Effectiveness - Total Cost/Percent of Nutrient Removal
(Base Option W3f includes STEP collection and borehole effluent disposal.
''Costa for deep well injection option include reduction in treatment cosu for reducing treatment level from AWT to secondary.
'Costs for reuse options assume aquifer storage and recovery will be used.
JCosU for potable reuse do not include revenues from sale of potable water.
3C-36

-------

1 year |
DESCRIPTION
1 1 2 1 3 | 4 | 6
6 | 7 | 8 | 9 | 10
11 | 12 | 13 | 14 | IB
ie| 17 | 18 | 19 | 20
Establish Regulatory Authority
Identify WWTP, OSOS & Cesspit Improvements
Conceptual Plan & Cost Approval
flBBB
gggJMM
M
n



Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Land Acqusition
ST"
ฆ


Design Wastewater Treatment Facilities
Permit Wastewater Treatment Facilities
Construct Wastewater Treatment Facilities
usssi
m
ฆMK
am
MS


Desion Wastewater Collection Systems
Permit Wastewater Collection Systems
Construct Wastewater Collection Systems
HI
m



Design OSDS System Improvements
Permit OSOS System Improvements
Construct OSDS System Improvements
EMU
($31
BBI
m
mmmmm
j






Post-Construction Water Quality Monitoring

flflHBHRHHH

III!
Figure C-15. Implementation schedule for Wastewater Option W3f: Construct 12 community WWTPs.

-------
C.2.6.6 AFFECTED ENTITIES
Entities affected by Option W3f are identical to those affected by Options W3d and W3e (see Section C.2.4.6).
These entities are primarily wastewater generators (cost effects) and regulatory agencies (program implementation,
permitting, and compliance).
C.2.6.7 ENVIRONMENTAL EFFECTS
The environmental effects of Option W3f are similar to, but greater in extent than, those of Options W3d and W3e
(see Section C.2.4.7). Overall land requirements for facility construction would be in the 48 to 72 acre range.
Construction of wastewater collection systems would affect larger areas. Short-term construction effects could be
minimiwith prudent construction practices.
C.2.6.8 ADDITIONAL MONITORING
The monitoring needs for this option are the same as those listed for Options W3d and W3e (see Section C.2.4.8).
C.2.7 Option W3g — Construct Three Subregional Wastewater Treatment Plants
C.2.7.1 DESCRIPTION
Under this option, three subregional WWTPs and collection systems with the potential to serve all the areas of the
Florida Keys outside the City of Key West would be constructed. The base option provides wastewater collection
and treatment for 94% of unincorporated Monroe County wastewater flows. Wastewater flows for the Cities of
Layton and Key Colony Beach are included with unincorporated Monroe County for this option analysis. Areas
served are identical to those served by the base Option W3f. Additional suboptions for wastewater collection and
effluent disposal are included. Service areas and WWTP locations for this option are shown in Figures C-16
through C-18. The main features of Option W3g are:
•	Construct three subregional plants to serve the upper, middle, and lower Keys. These three plants would
accommodate approximately 94% of wastewater flows from the Florida Keys areas excluding Key West.
•	Construct STEP wastewater collection systems within service areas of each subregional plant as described
for Option W3e.
•	Use boreholes for effluent disposal.
•	Continue OSDS/package plant use for isolated areas that are not practical to connect to a subregional
system, but upgrade these systems to nutrient removal or AWT.
•	Initiate an active program for the identification and elimination of all cesspits. Development using
cesspits would either be served by OSDSs/package plants or subregional plants, depending on location.
•	Collection System Suboptions:
(a)	Grinder pump transmission from source.
(b)	Vacuum system collection from source.
•	Treatment Suboption: Use excess capacity at City of Key West WWTP to treat wastewater from PAEDs
1 and 2.
3C-38

-------
City ot
Key West
d
WWTP Service Area
PAED Designation
Approximate WWTP Location
Lower Keys
Figure C-I6. Wastewater Option W3g: Construct three nibrcgfonal WWTh - Lower Keys (Scale: 1" ฆ 6000').

-------
6
WWTP Service Area
PAED Designation
Approximate WWTP Location
Middle Keys
Figure C-17. Wastewater Option W3g: Construct three subregional WWTPs - Middle Keys (Scale: 1" ฆ 6000')*

-------

WWTP Service Area
PAED Designation
Approximate WWTP Location
Upper Keys
Figure C-18. Wastewater Option W3g: Construct Hire clonal WWTP* - Upper Keys (Scale: 1" - 6000').

-------
• Effluent Disposal Suboptions:
(a)	Aquifer storage
(b)	Deep well injection (reduce treatment level to secondary)
(c)	Reuse for irrigation within Keys (reduce treatment level to secondary/irrigation quality)
(d)	Reuse for irrigation in areas outside Keys (reduce treatment level to secondary/irrigation quality)
(e)	Reuse for potable water
C.2.7.2 RATIONALE
The rationale for selecting Option W3g would be similar to that for W3f, i.e. treat all Florida Keys wastewater
flows to AWT level in order to achieve desired FKNMS water quality. Additionally, selection of Option W3g over
Option W3f would reflect a preference for large, subregional systems over smaller, community systems. As with
Option W3f, 94% of wastewater flows within unincorporated Monroe County would be collected and given a high
level of treatment. Additional monitoring and studies will be required to select this option.
C.2.7.3 POLLUTION REDUCTION
The nutrient loading reduction of this option would be identical to Option W3f because wastewater service areas
and treatment levels are the same. Estimated reductions in loadings of total nitrogen and total phosphorus for the
base option are 72% and 43%, respectively. Estimated nutrient removal effectiveness of the various options
included with Option W3g are summarized in Table C-8.
C.2.7.4 COST
The total estimated 20-year cost of the base option with STEP system collection from septic tanks is $690 million.
This cost includes $418 million an initial cost and $272 million for 20-year operation and maintenance costs. Cost
of this option is higher than Option W3d because of the larger lift station and force main sizes required to pump
higher flows longer distances. Suboptions included for wastewater collection and effluent disposal affect cost and
nutrient loading reduction for Option W3g. A summary of cost increases and nutrient removal effectiveness for
these suboptions is given in Table C-9.
C.2.7.5 IMPLEMENTATION SCHEDULE
A fast-track implementation schedule for Option W3g is shown in Figure C-19. This schedule could be compressed
or extended as priorities and funding dictate. If intensive effluent disposal suboptions such as the reuse of effluent
for potable or irrigation water are selected, the schedule would be extended an estimated two years.
C.2.7.6 AFFECTED ENTITIES
Entities affected by Option W3g are identical to those affected by Options W3d, W3e, and W3f (see Section
C.2.4.6). These entities are primarily wastewater generators (cost effects) and regulatory agencies (program
implementation, permitting, and compliance).
3C-42

-------
Table C-S. Estimated costs and nutrient loading reductions for
wastewater Option W3g: construct three subregional WVYTPs
Effluent Disposal Options
N Reduction*
(*)
P Reduction1
(*)

Estimated Cost

Cost
EfTectiTei
ซsf
In4fialb
(S millions)
20 Year
0&Mฐ
(J millions)
Total
20 Year*
(J millions)
20 Year per
Connection
e(J)
TN
TP
BASE'OFTION*
72
43
418
272
690
19,100
9.6
16
COLLECTION SYSTEM OPTIONS








Grinder Pump Stations
0
0
+30
-7
+23
+640
N/A
N/A
Vacuum Systems
0
0
+ 17
•10
+7
+200
N/A
N/A
TREATMENT OPTION








Utilize City of Key West
0
0
-IS
•13
-31
-900
N/A
N/A
WWTP Excess Cspacity








for PAEDs 1 & 1








EFFLUENT DISPOSAL OPTIONS








Deep Well Injection'1
+ 11
+20
-23
-17
-40
-1,100
-3.6
-2.0
Irrigation Reuse within Keys'
+ 7
+ 15
+ 120
+ 80
+ 200
+5,500
29
13
Irrigation Reuse out of Keys'
+ 11
+20
+48
+32
+80
+2,200
23
4
Potable Reuse1''
+ 11
+20
+ 80
+ 50
+ 130
+3.600
12
7
O&M: Operation and mainfrnanrc
^Reduction shown ii for primarily man-induced loading, including domestic wastewater, live-iboardi, and stormwater from developed areai. Slortnwiier load* '
kxn undeveloped areas, atmospheric dcpoiition, or other nonpoioi sourcea are oca included.
|hitial coat* include land acquisition, initial WWTP construction, WWTP capacity increases to serve 20-year demands and construction of all collection syster
Tom include labor, administration, repair/replacement, power and chemicals.
Present worth only; no financing costs included.
eCiM shown is for present worth of single 250 GPD service connection share of the total cost.
'Coa Effectiveness ซ Total Cost/Percent of Nutrient Removal
'Base Option W3g includes STEP collection and aquifer storage effluent disposal.
^Costs for deep well injection option include reduction in treatment cosu for reducing treatment level from AWT to secondary.
'Coiu for reuse options assume aquifer storage and recovery will be used.
-ICons for potable reuse do not include revenues from sale of potable water.
3C-43

-------
Table C-9. Estimated costs and nutrient loading reductions for wastewater Option W4:
upgrade effluent disposal for City of Key West.
Effluent Disposal Options
N Reduction1
(*)
P Reduction*
(*)

Estimated Cost

Cast EftectiTj(
($ millions)
20 Year 0*Mฐ
(J millions)
Total
20 Ycu4
($ millions)
20 Year per
Coonectioac

5,100*
30 15
O&M: Operation and maintenance
^Reduction shown is for primarily man-induced loading, including domestic wastewater, live-aboardป. and stormwaler from developed areas. Stormwaler
load* from undeveloped areas, stmo spheric deposition, or other nonpoint sources are not included.
''initial com include land acquisition, initial WWTP construction, WWTP capacity increases to serve 20-year demands and construction of all collection
systems.
cCosu include labor, administration, repair/replacement, power and chemicals.
''Present worth only; no financing costs included
'Cost shown is for present worth of single 250 GPD service connection share of the total cost.
^Cost Effectiveness ™ Toul Cost/Percent of Nutrient Removal
(Cost for potable reuse does not include revenue from the sale of potable water.
''Costs for reuse options assume aquifer storage and recovery is used.
'Costs for potable reuse do not include revenues from sale of pouble water.
3C-44

-------
DESCRIPTION
moral
YEAR
8 | 7 | 8 | 9 | 10
11 | 12 | 13 | 14 | 16
16 | 17 | 18 | 19 | 20
Establish Regulatory Authority
Identify WWTP, OSOS & Cesspit Improvements
Conceptual Plan & Cost Approval
Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Land Acqusition
ฆฆ < •
Design Wastewater Treatment Facilities
Permit Wastewater Treatment Facilities
Construct Wastewater Treatment Facilities
Design Wastewater Collection Systems
Permit Wastewater Collection Systems
Construct Wastewater Collection Systems

Design OSDS System Improvements
Permit OSDS System Improvements
Construct OSDS System Improvements
Post-Construction Water Quality Monitoring
Figure C-19. Implementation schedule for Wastewater Option W3g: Construct three subregional WWTPs.

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C.2.7.7 ENVIRONMENTAL EFFECTS
The environmental effects of Option W3g are similar to those of Options W3d, W3e, and W3f (see Section
C.2.4.7). Overall land requirements for facility construction would be reduced to the 20 to 30 acre range. Short-
term construction effects could be minimiwith prudent construction practices.
C.2.7.8 ADDITIONAL MONITORING
Monitoring needs for this option are the same as those discussed for Options W3d, W3e, and W3f (see Section
C.2.4.8).
C J OPTIONS FOR THE CITY OF KEY WEST
C J.l Option W4 — Upgrade Effluent Disposal for the City of Key West Wastewater Treatment Plant
C.3.1.1 DESCRIPTION
This option pertains only to the City of Key West. The City of Key West WWTP would continue providing
secondary treatment of wastewater, but the ocean outfall would be replaced as the primary means of effluent
disposal. The primary features of this option are:
•	Continue use of the City of Key West WWTP for secondary treatment of wastewater from the service
area.
•	Continue programs for the extension of sewer service to areas not presently served.
•	Continue infiltration/inflow reduction programs.
•	Discontinue use of ocean outfall for primary effluent disposal and implement one of the following methods
of effluent disposal:
(a)	Deep well injection
(b)	Reuse for irrigation within areas outside the Florida Keys (with aquifer storage and recovery).
(c)	Reuse for potable water (with aquifer storage and recovery)
Partial reuse of effluent for irrigation within Key West would be used to the extent practical under all effluent
. disposal options. Because of the shortage of suitable application sites, reuse of effluent for local irrigation needs will
account for only a fraction of total effluent disposal needs.
Continuation of ocean outfall use with an upgrade in treatment was determined not to be a viable option. The
present ocean outfall has deteriorated and does not meet current FDER requirements for ocean outfalls. A new
ocean outfall would have to be constructed to meet current FDER Standards. The cost of this construction would
be greater than that for deep well disposal. Also, obtaining a permit for a new ocean outfall may be very difficult,
thus this option was dismissed.
The existing ocean outfall would be used as an emergency short-term disposal method for all four effluent disposal
options. Reuse of effluent for inigation in areas outside the Florida Keys would be considered only if it is proposed
for unincorporated Monroe County.
3C-46

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CJ.L2 RATIONALE
The rationale for selecting Option W4 would be that the existing City of Key West WWTP ocean outfall is
degrading the waters of the FKNMS and upgraded effluent disposal will result in a long-term improvement in water
quality. Additional monitoring and studies may be necessary to determine long-term effects.
CJ.1J POLLUTION REDUCTION
This option would reduce direct nutrient loading to waters of the FKNMS by the amounts present in the WWTP
discharge. The City of Key West Comprehensive Plan indicate that 1990 average effluent concentrations for NH3
+ NO3 nitrogen and orthophosphate are about 4.0 and 2.5 mg/L, respectively. Assuming these are the predominant
forms of nitrogen and phosphorus in the effluent, the total nitrogen loading would be 61 lbs/day and total
phosphorus would be 38 lbs/day. These	loads assume that all wastewater flows within the service area
will be connected to the WWTP. Compared with total nutrient loadings to the FKNMS from all man-induced
sources, this would amount to 5% and 9% estimated reductions in overall nutrient loadings for total nitrogen and
total phosphonis, respectively.
CJ.1.4 COST
Fstimated costs for suboptions under this option are summarized in Table C-9. Initial costs include design,
permitting, and construction. The estimated present worth 20-year operation and maintenance; costs are also
included. Estimates for operation and maintenance are based upon a 6 % annual inflation rate and L :iude labor and
administration, repair and replacement, and power.
CJ.1.5 IMPLEMENTATION SCHEDULE
A fast-track implementation schedule for Option W4 is shown in Figure C-20. This schedule couk .* compressed
or extended as priorities and funding may dictate. If intensive effluent disposal suboptions suet is the reuse of
effluent for potable or irrigation water are selected, the schedule would be extended an estimated -vo years.
CJ.1.6 AFFECTED ENTITIES
Entities affected by this option include users of the wastewater systems (wastewater generators) and regulatory
agencies involved in permitting and monitoring compliance of the systems. The main effect this option would have
on users of the system would be sharing the costs of construction and operation. The degree to which residential
and non-residential users would participate in cost sharing depends on funding mechanisms established to implement
this option.
Primary areas of regulatory responsibility and authority would be:
•	FDCA — reviewing wastewater master plans for consistency with comprehensive plan goals, policies,
and objectives
•	City of Key West — deciding whether city, FKAA, or another entity will assume the responsibility for
a regional utility and the issuance of building and utility right-of-way permits required for construction
•	FDER — permitting of effluent disposal systems and compliance/enforcement once system is in operation
•	EPA — design review for reuse of effluent for potable water.
3C-47

-------
DESCRIPTION
YEAR
1 1 2 | 3 | 4 1 6
e | 7 | e | s 110
11 | 12 | 13 | 14 | 16
16 | 17 | 18 | 19 | 20
Evaluate Existing Disposal Systems
Conceptual Plan & Cost Approval
Establish Funding Mechanism
mam
m	
0SH9BHRKBH
tSsBEBE&Hfl



Preconstruction Water Quality Monitoring
Regulatory Agency Preliminary Review
Land Acqusition
im
nn



Design- Wastewater Effluent Facilities
Permit Wastewater Effluent Facilities
Construct Wastewater Effluent Facilities
nm
ฆ331
Hi
vm
mmm


Post-Construction Water Quality Monitoring




Figure C-20. Implementation schedule for Wastewater Option W4: Upgrade eflluent disposal for the City of Key West WWTP.

-------
•	FDHRS — limits design review for reuse of effluent for potable v. 
-------
APPENDIX D
Engineering Methods for Stormwater
Collection, Treatment, and Disposal

-------
ENGINEERING METHODS FOR STORMWATER
COLLECTION, TREATMENT, AND DISPOSAL
As development occurs, changes in land use in the Florida Keys cause great changes in the way stormwater either
runs off or is absorbed by the land. The characteristics and quality of runoff are also altered by the impervious
nature of development. The natural topography's capacity to capture and buffer the effects of runoff is often
exceeded. A wide range of controls is available to modify the quantity and quality of stormwater runoff.
Stormwater control methods include physical measures to redirect or store stormwater and non-structural measures
to affect the character of stormwater runoff. The treatment efficiencies and areas efficiently served by engineering
methods for stormwater are estimated and presented in Table D-l.
D.l GRASSED SWALES
Grassed swales are used as alternatives to curb and gutter stormwater conveyance systems. Grassed swales consist
of slightly sloped gTassed "valleys," often with dam-like structures made of stone and railroad ties that increase
infiltration and flow attenuation.
Swales, or grassed waterways, are one of the oldest and least expensive stormwater management systems and have
been used along streets and highways for years. A swale is:
•	a shallow trench that has side slopes flatter than 3 ft horizontal to 1 ft vertical
•	an area that contains standing or flowing water only after a rainfall
•	planted with or has vegetation suitable for soil stabilization, stormwater treatment, and nutrient uptake
•	designed to take into account soil erodibility, soil percolation, slope, slope length, and drainage area to
prevent erosion and reduce the stormwater pollutant load.
Swales are used primarily for stormwater conveyance and are considered an on-line practice. As with other
retention practices, the effectiveness of pollutant removal depends on the volume of stormwater that can be
percolated through the filtering vegetation and into the soil.
Maintenance requirements for swales will not be significantly greater 'Han those for a normal lawn. However,
public education is essential, especially for residents who live in developments served by swales. Residents need
to be informed about the benefits provided by their swale so that they take pride in maintaining it and do not fill
it in. Residents need to know that leaves, limbs and other vegetation, along with debris and oil, should not be
disposed of in the swale. If this occurs, the pollutants in these materials will be delivered to downstream waters
and a benefit of the swale would be lost.
Used alone, swales must percolate 80% of the runoff from a 3-in rainfall within 72 hours to provide proper water
quality benefits. However, this is often impossible because of soil type or slope, and the greatest utility of a swale
is as a pretreatmeot conveyance system that reduces pollutants before the stormwater enters a retention and
detention basin or a wetland. The use of swales should be seen as an important component of a stormwater
treatment train.
D.2 SWALE/BERM SYSTEMS
In the Keys, the use of swale/berm systems may be an effective stormwater engineering method for waterfront
residential properties. These systems consist of a swale near the waterfront edge of the property and a low berm
between the swale and the water. The berm serves to impound stormwater runoff in the swale, allowing the
stormwater to percolate into the soil or limestone before being discharged to the adjacent surface water. Swales
for these systems may be grassed or may be covered with the small limerock ("pea rock") typically used for yards
in the Keys.
3D-1

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Table D-l. Estimated removal efficiencies for stormwater engineering methods*.
Stonnwater Engsc ing
Method
Anas
Efficiently
Served

Removal Efficiencies
(*)

Overall Removal
Capability

(acres)
Suspended
Sediment
TP
TN
Trace
Metals

GRASSED SWALES
0-5





low gradient with checkdam
high gradient

20-40
0-20
20-40
0-20
20-40
0-20
0-20
0-20
Low
Low
FILTER STRIPS
0-5





100 ft foteAcd srip
20 ft turf

80-100
20-40
40-60
0-20
40-60
0-20
80-100
20-40
Moderate
Low
Catch Bum
0-2
0-20
Unknown
Unknown.
Unknown
Low
Poroui Ptvemem
2-10
60-80
20-40
20-40
60-80
Moderate
Pervioua Parking
0-10
40-60
20-40
20-40
40-60
Moderate
Exfiltiatioa Trench
5-20
80-100
60-80
60-80
80-100
High
PoUubon Control Structure
5-20
0-20
Unknown
Unknown
Unknown
Low
DETENTION POND
15 +





firn-fiuih: 6-12 h detention time
1 * - 24 h detention time
with tfaallow marah

60-80
80-100
80-100
20-40
40-60
60-80
20-40
20-40
40-60
40-60
60-80
60-80
Moderate
Moderate
High
RETENTION POND
15 +





wet with 1/2' storage
wet with 1' storage
wet with 4" ttorage
dry with 1/2* infiltration
dry with 1 * infiltration
dry with 4" infiltration

60-80
60-80
80-100
60-80
80-100
80-100
40-60
40-60
60-80
40-60
40-60
60-80
20-40
20-40
40-60
40-60
40-60
60-80
20-40
60-80
60-80
40-60
80-100
80-100
Moderate
Moderate
High
Moderate
High
High
"Source: Water Quality - Urban Runoff Solutions APWA Special Report #61
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D.3 FILTER STRIPS
Filter strips, consisting of grass or other close-growing vegetation, are designed to accept overland flows of runoff.
They are usually composed of dense vegetation (such as high grasses, ground covers, or shrubs) and are often
combined with underlying stone layers to enhance infiltration. Filter strips can be effective in slowing stormwater
runoff rates and velocities, reducing downstream sediment loading by settling and physical entrapment. They can
also increase infiltration of stormwater and can provide some nutrient removal through uptake by plants.
D.4 CURB ELIMINATION
Curb elimination has beep identified as a means to improve stormwater runoff. The absence of curbs allows runoff
to disperse over a greater area rather than being channeled into collection facilities. This dispersal over adjoining
land, which is usually covered by vegetation, also aids in reducing runoff velocity and the sedimentation of solids.
Conversely, in urban environments, curbs function to channel vehicular traffic as effectively as they channel
stormwater. Curb and gutter construction:
•	Reduces pavement failure by supporting the edges of bituminous pavement
•	Prevents water seepage into the road base and subbase
•	Improves safety by defining the edge of streets for drivers, children and pedestrians
•	Keeps litter and dirt on the roadway where it can be collected more efficiently
•	Is necessary in many commercial, industrial and business districts
•	Is not necessary in suburban and rural areas.
The anticipated water quality or cost benefits from eliminating curbs must be measured against the longer term
operational and safety implications of their absence.
D.5 CATCH BASINS
Catch basins are part of an underground stormwater collection, treatment, and disposal system. Stormwater runoff
is routed to catch basins by swales, curb and gutter, inverted crown pavement or other conveyance. The catch basin
is designed to capture grit, gravel, and debris, and to protect the remainder of the storm drainage system.
Combined with a swale system where the inlet of the catch basin is raised 3 inches above the surrounding swale,
the catch basin acts as a pretreatment device, providing for some retention of stormwater in the swale.
Catch basins require periodic cleaning and maintenance because they can fill with debris, capture oil or other
hydrocarbons, and attract mosquitoes and other insects. Catch basins have also been abused by individuals who use
them as dump sites for used oil and/or radiator coolant. Organic material, such as leaves, grass clippings, and pet
droppings can be trapped in the catch basin. Catch basins can contribute significant amounts of pollutants to a storm
sewer system with the first flush of a storm event. For these reasons, catch basins are most effective when they
are located in swales and away from areas covered with asphalt.
D.6 EXFTLTRATION TRENCHES
In many areas such as the Florida Keys, where land costs are so prohibitive that the use of retention or detention
basins is excluded or severely limited, the use of exfiltration trenches is common.
The most commonly used underground trench is an off-line exfiltration trench in which runoff is diverted into an
oversized perforated pipe placed within an aggregate envelope above the groundwater table. The first flush of
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stormwater is stored in the pipe and cfiltrates out of the holes, through the gravel and into the surrounding soil.
Routine maintenance consists of vacuuming debris from the ratrh basin inlets and, if needed, using high pressure
hoses to wash clogging materials out of the pipe. Pre treatment with filter strips or swales is essential for efficient,
long-term operation of exfiltration trenches.
Another trench system uses exfiltration trenches beneath swale areas. These trenches enhance the swale usage and
design and increase groundwater recharge. The trench is a shallow 3 to 8 ft-deep excavated area above the
groundwater table and is lined with filter fabric and filled with stone. The top of the trench is covered with three
to 4 in of soil and then is covered with sod. The soil and grass layer acts as a filter for the trench. In Florida,
water tables are often too high for effective use of swale exfiltration trenches.
D. 7 POLLUTION CONTROL STRUCTURES (OIL/GREASE SEPARATORS)
Pollution Control Structures (PCS) are constructed to remove sediment and hydrocarbon loadings from parking lot
and street runoff. PCSs, as typically designed, have limited storage capacities, but serve to separate some of the
coarse sediment, oil/grease, and debris from urban runoff. Fine-grained particulate pollutants such as silt and clay,
and associated trace metals and nutrients are less likely to be removed.
PCSs are appropriate for areas with excessive oil and grease loadings, such as gas stations, roads, or loading areas.
The PCSs are unobtrusive, compatible with the storm drain network, easy to access, and allow pretreatment of
runoff before it enters infiltration facilities. Disadvantages associated with PCSs include limited pollutant removal
capabilities, the need for annual maintenance, and difficulties in disposal of accumulated sediments, which are
sometimes classified as hazardous materials.
D.8 DETENTION/ DETENTION FACILITIES
Detention and retention basins are used along roach ays, parking lots, and other impervious areas to control the
effects of short, high-intensity storms. The basins cc nter the increased rate and volume of runoff from impervious
surfaces by retarding storm runoff. Stormwater is te nporarily held in detention basins or stored for longer periods
of time in retention basins. Detention and retention j as ins are most effective when they are built at the same time
as the surrounding developments. Although they are :ot substitutes for stormwater management systems, the basins
have their greatest benefits immediately downstream.
Maintenance is a key consideration before building detention or retention facilities. After installation, these facilities
should be maintained consistently to keep them from becoming a liability or hazard. Contmuing maintenance
includes routine inspection, mowing, mosquito control, clearing and repairing of outlet works, removal of sediment
and debris after storm events, erosion control on the embankment, maintenance of grass covers, and keeping
vehicles off embankments.
D.8.1 Retention Basins
In an undeveloped area, infiltration is a natural part of the hydrologic cycle. A certain amount of precipitation
infiltrates into the ground, replenishing the groundwater and providing water for trees and other plants. A retention
area retains stormwater on site, allowing it to infiltrate into the ground or to evaporate. This reduces the volume
of stormwater runoff and is effective in reducing stormwater pollution by retaining the first flush of stormwater off-
line. By reducing the volume of stormwater runoff, infiltration also helps reduce the effects of stormwater on
estuaries that are sensitive to salinity variations.
The amount of infiltration that occurs depends primarily on soil type. Successful use of infiltration requires
appropriate site conditions to assure that the stormwater will infiltrate within 24 to 72 h. Coarse-grained sandy soils
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have excellent infiltration capacity. As soils begin to contain higher a-nounts of fine-grained clays and silts, their
infiltration capacity diminishes. To protect groundwater from contamination, the bottom of retention basins should
be at least 3 ft above the seasonal high water table and bedrock.
D.8.2 Detention Basins
These facilities provide temporary storage of stonnwater runoff. Detention basins control peak discharges and
provide pollutant gravity settlement. If site conditions will not allow total infiltration of the first flush of
stonnwater, then parts of the first flush ran be infiltrate as pre treatment before the stonnwater enters a wet
detention or wetland treatment system for final treatment. On a small scale, lawns, parking lot islands and small
landscaped areas can all be used to store stonnwater and allow it to infiltrate. Such areas are especially appropriate
as elements of a stonnwater treatment train where raised storm sewer inlets are placed in the retention area allowing
some treatment before excess stonnwater is routed to a detention facility or other ultimate destination.
D.9 CLASS V INJECTION WELLS (BOREHOLES)
The Florida Department of Environmental Regulation (FDER) allows the use of shallow (Class V) injection wells
for wastewater and stonnwater disposal. Shallow injection wells (or boreholes) are used widely for disposal of
package wastewater treatment plant effluent. Forty-three boreholes were being used for stonnwater disposal in the
Florida Keys as of July, 1992. The use of boreholes for stonnwater disposal should only be for stonnwater
pretreated by detention or other methods.
A typical borehole in the Florida Keys is an 8-in diameter hole drilled to a depth of 60 to 90 ft and cased to a depth
of 30 to 60 ft. Some large-diameter boreholes (24 to 30 in) are used in the Florida Keys for stonnwater disposal.
Current FDER regulations require boreholes to be drilled to a depth of 90 ft and cased to 60 ft.
D.10 AQUIFER STORAGE AND RECOVERY
Aquifer storage and recovery (ASR) is a relatively new technique involving pumping treated water to a confined
shallow aquifer (- 500 ft deep) for future use. The pumped water forms a "bubble" displacing native saline water.
Differences in densities between the two water masses and restrictions of the aquifer formation minimize mixing
of pumped and native waters. Recovery of the pumped water, for irrigation or other uses, can take place either
immediately or in the future.
D.ll DEEP INJECTION WELLS
Deep well injection historically has been used primarily for the disposal of wastewater and reverse osmosis brine.
Although, there are no known deep wells used strictly for stonnwater disposal in Florida, FDER may allow the use
of deep wells for stonnwater injection. However, because of the high costs for construction, operation, and
maintenance, the decision to utilize deep well injection for stonnwater disposal may be cost prohibitive.
D.I2 CISTERNS
Cisterns historically were used to collect rain water for household purposes. As potable water systems have become
available, their application has all but disappeared. Cisterns can be a stonnwater retention device, storing the water
for irrigation during dry periods. Although cisterns provide no stonnwater treatment, the capture of runoff and its
delayed application to surrounding vegetation provides a beneficial use of stonnwater. The vegetation also provides
some treatment. Cisterns can also be utilized to store water for potable use. Cisterns used to collect and hold
3D-5

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potable water generally are associated with roof collection systems. Ci items are the primary method of supplying
potable water on many of the outer Bahama Islands.
D.13 POROUS PAVEMENT
Porous pavement is an innovative stonnwater practice that is applicable to parking areas not subject to sand and mud
earned on tires. Areas paved with porous concrete allow water to percolate into the underlying soil. A parking
lot, if paved with porous concrete, can remain pervious and allow infiltration, thereby reducing stonnwater volume,
peak discharge rate, and pollutant load. In addition, porous concrete eliminates the accumulation of water pockets,
providing a safer, skid-resistant parking lot surface.
However, porous concrete is only feasible and cost effective on sites with gentle slopes, permeable soils, and
relatively deep water tables. When properly designed and carefully installed, porous concrete has the load-bearing
strength and longevity of conventional concrete. The design and installation of porous concrete should be
undertaken only by a professional team of engineers and contractors who are familiar with its properties. Routine
inspection and maintenance is essential to preserve the high infiltration rate of porous concrete paving. The surface
should be routinely checked after a prolonged storm for evidence of debris accumulation, ponding of water, clogging
of pores, or other damage. Regular vacuum sweeping should be performed to prevent clogging of the porous
parking surface. High pressure steam cleaning or vacuuming may be needed annually. During construction it is
essential that sound erosion and sediment control practices be used to keep sediment off the pervious pavement and
to prevent clogging of pores.
If properly designed, installed and maintained, pervious concrete provides a cost-effective, viable solution to
stonnwater management problems associated with parking lots.
Porous pavement is constructed in layers as:
•	Top porous pavement course, 2.5 to 4.0 in thick
•	Upper filter course of 0.S in diameter gr> /el, 1.0 in thick
•	Stone reservoir of 1.5- to 3.0-in diameter r;one; storage provided by the void space between stones; depth
variable depending on the storage volume needed
•	Lower filter Course of gravel, 2 inches o ซp
•	Filter fabric layer
•	Undisturbed soil
Parking lots are among the largest generators of runoff and polluted stormwater. These vast paved areas generate
stonnwater after every stonn. Many parking areas, such as those at shopping centers, are rarely completely filled
with cars. Parking lots should be covered with grass or gravel as much as practical.
D.15 STORMWATER REUSE FOR IRRIGATION
The reuse of stormwater for irrigation commonly is practiced in areas where the water supply is limited. The
practice involves routing stormwater to a detention basin that is adequately sized to provide irrigation water for the
intended application area. Irrigation water is pumped from the detention basin to the application site, where it is
applied with overhead, underground, or drip systems. Stormwater can be reused to irrigate to areas ranging from
single-lot residential or commercial sites to large gblf courses or agricultural areas. On large projects, detention
pond area and evaporative losses may be minimized if the use of an ASR system is feasible on the site.
3D-6

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APPENDIX E
Engineering Options for Storm water
Collection, Treatment, and Disposal

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ENGINEERING OPTIONS FOR STORMWATER
COLLECTION, TREATMENT, AND DISPOSAL
Options for the improvement of stonnwater runoff cover a variety of engineering methods. These methods are
defined and discussed in Appendix D.
Because options typically involve a combination of several engineering methods, they are described and presented
in order of increasing level of effort. The first option identifies stonnwater improvements for potential hot spots.
Hot spots are defined as land-based activities, such as intensive commercial, industrial, and dry dock facilities, that
contribute significant quantities of pollutants to storm water runoff. The second option involves an extensive
program of retrofitting population centers, hotels, resorts, and major residential areas with stonnwater treatment
methods, along with the hot spots addressed in the first option. The third and ultimate option requires retrofitting
all developed areas within the Florida Keys with best available technology.
Sections for each option* include a description of the option, rationale for selection, estimated pollution reduction,
cost, implementation schedule, affected entities, environmental effects, and additional monitoring. It should be
noted that the relationship of removal efficiency to cost is only roughly understood for stonnwater.
E.1 OPTION Sla - RETROFIT HOT SPOTS
E.1.1 Description
The option for retrofitting hot spot potential sources of contamination is:
•	Identify hot spots or problem areas (e.g., commercial, industrial, dry docks, U.S. 1).
•	Retrofit stonnwater facilities in hot spots using: grass parking, swales, exfiltration trenches, PCS, and
detention/retention facilities.
•	Eliminate stonnwater runoff in areas handling toxic and hazardous materials (e.g., commercial, industrial,
dry docks).
•	Install swales and detention facilities along limited sections of U.S. 1.
E.1.2 Rationale
The rationale for selecting Option Sla would be that the retrofitting of stormwater hot spots with control and
treatment methods will result in a significant reduction in pollutant loadings to waters of the Florida Keys National
Marine Sanctuary (FKNMS) and an improvement in long-term water quality over that provided by the "no action"
option. Additional monitoring and studies may be necessary to select this option.
E.1.3 Pollution Reduction
The effectiveness of stonnwater control/treatment facilities is not well known and is very site specific. Nutrient
removals are highly dependent on site conditions, Engineering methods, and level of facility maintenance.
•	Potential reductions in total nitrogen and total phosphorous loadings are estimated to be about 0.2 to 0.S %
of the total man-induced loadings (stormwater and wastewater) to the FKNMS.
•	Potential reductions in sediment loadings are about 0.5 to 1.0% of the total man-induced loadings
(stonnwater and wastewater) to the FKNMS.
3E-1

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Some of the toxic constituents in stormwater runoff will be removed by this option. The toxic constituents removed
generally will be those associated with sediments or floating materials. Because of the many different toxic
materials, the wide range of concentrations at which specific constituents are toxic, the high variabili" n stormwater
quality from site to site, and the lack of significant stormwater data concerned with the Keys, me degree of
reduction of toxic materials attained by implementing this option cannot be reliably estimated.
E.1.3 Cost
Construction costs are estimated to be $80 million. The present worth, 20-year operation and maintenance costs
are rstimatrd to be $120 million, based on a 6% annual inflation rate. The estimated total 20-year cost of this
option is $200 million.
E.1.5 Implementation Schedule
A proposed fast-track implementation schedule for Option Sla is shown in Figure E-l. This schedule can be
compressed or extended as dictated by priorities and funding.
E.1.6 Affected Entities
Entities affected by this option are:
•	Owners of hot spots
•	Florida Department of Transportation (FDOT) — Responsibility for runoff from FDOT right-of-way
•	Environmental Protection Agency (EPA) — Administers National Pollutant Discharge Elimination System
(NPDES) program
•	Monroe County — Enforces October 1992 Stormwater Management Ordinance
•	South Florida Water Management District (SFWMD) — Regulates larger parcels (10 acres or more total
area or 2 acres or more impervious area)
•	Florida Department of Environmental Regulation (FDER) — Maintains oversight authority over SFWMD
permitting
•	National Oceanic and Atmospheric Administration (NOAA) — Regulates FKNMS
E.1.7 Environmental E fleets
The environmental effects of the implementation of Option Sla would be limited to short-term impacts associated
with stormwater facility construction in hot spot areas.
E.1.8 Additional Monitoring
Existing stormwater data are inadequate to characterize present pollutant loadings to the FKNMS. Quantifying
pollutant loading reductions from implementation of this option would be even more difficult. Because of this lack
of data, it is recommended that a marina stormwater-control demonstration project be conducted in the Florida Keys.
This project should focus on a suspected stormwater hot spot. The recommended location is a large marina with
a large, unpaved, outdoor area where bottom painting and other intensive maintenance activities are performed.
Activities associated with this project should include:
3E-2

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DESCRIPTION
YEAR
1 1 2 1 3 1 4 | 6 a I 7 | 8 I 9 | 10 [ 11 | 12 | 13 | 14 I IB | 18 | 17 j 18 1 19 | 20
Establish Regulatory Authority
Identify Stormwater Pollution Hot Spots
Conceptual Plan & Cost Approval
Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Preliminary Agency Approvals
mmim:

Design Stormwater Treatment Retrofits
Permit Stormwater Treatment Retrofits
Construct Stormwater Treatment Retrofits
Post-Construction Water Quality Monitoring
Figure E-l. Implementation schedule for Stormwater Option Sla: Retrofit hot spots.

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•	Paving and curbing the entire maintenance ana
•	Constructing pollution control device(s) and retention pond(s) as necessary to control discharge of
stormwater runoff. Pollution control devices and filters should be installed ahead of all ponds
•	Geaning visible residue from waters near the existing point(s) of discharge
•	Providing sweeping equipment to regularly clean the paved maintenance area
Monitoring associated with the demonstration project should include:
•	Pre-implementation sediment and water quality monitoring of nearshore surface waters including
background (if appropriate) and existing discharge point(s)
•	Pre-implementation storm event monitoring at existing discharge point(s) (water and bed load sampling,
if appropriate)
•	Post-implementation sediment and water quality monitoring
•	Post-implementation storm event monitoring
•	Characterization of all materials removed from maintenance areas prior to disposal to determine the
potential generation of pollutants by maintenaqro activities
Sediment and water samples should be analyzed for several parameters, including heavy metals, organics, and
pesticides. Other analyses, as determined from site-specific operations and the materials used, should be performed.
In addition to the marina stormwater-control demonstration project and its associated monitoring, pre- and post-
implementation monitoring of selected stormwater hot spots located away from the project should be performed in
order to evaluate the pollutant reduction effectiveness of this option and the long-term effects on water quality.
E.2 OPTION Sib - RETROFIT HOT SPOTS AND POPULATION CENTERS
E.2.1 Description
The option for retrofitting population centers and hot spots is:
•	Retrofit hot spots as specified in Option Sla.
•	Initiate an extensive stormwater retrofitting program for population centers.
•	Install swales and detention basins along a majority (i.e., developed areas) of U.S. 1.
E.2.2 Rationale
The rationale for selecting Option Sib over Option Sla would be that the higher intensity and commitment
associated with Option Sib would result in a significant long-term improvement in water quality. Additional
monitoring and studies may be necessary to select this option.
E.2.3 Pollution Reduction
The effectiveness of extensive stormwater engineering implementation is not well known and is very site specific.
Nutrient removals are highly dependent on site conditions, engineering methods, and level of facility maintenance.
3E-4

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•	Potential reductions in total nitrogen and total phosphorous loadings are estimated to be about 5 to 12%
of the total man-induced loadings (stormwater and wastewater) to the FKNMS.
*	Potential reductions in sediment loadings are estimated to be about 20 to 50% of the total man-induced
loadings (stormwater and waistewater) to the FKNMS.
Some of the toxic constituents in stormwater runoff will be removed by this option. The toxic constituents removed
generally will be those associated with sediments or floating materials. Because of the many different toxic
materials, the wide range of concentrations at which specific constituents are toxic, the high variability in stormwater
quality from site to site, and the lack of significant stormwater data concerned with the Keys, the degree of
reduction of toxic materials attained by implementing this option cannot be reliably estimated.
E.2.4 Cost
Construction costs are estimated to be S370 million. The present worth, 20-year operation and maintenance costs
are estimated to be $440 million, based on a 6 % annual inflation rate. The estimated total 20-year cost for Option
Sib is $810 million.
E.2.5 Implementation Schedule
A proposed fast-track implementation schedule for Option Sib is shown in Figure E-2. This schedule can be
compressed or extended as dictated by priorities and funding.
E.2.6 Affected Entities
Entities affected by the option are identical to those affected by Option Sla (see Section E.1.6).
E.2.7 Environmental Effects
Construction of stormwater control facilities will cause short-term construction impacts. The removal of developed
land for detention/retention facilities will be a long-term effect.
E.2.8 Additional Monitoring
A marina stormwater-control demonstration project is recommended (see Section E.1.8). As with Option Sla, pre-
and post-implementation monitoring is recommended to assess effectiveness of the retrofit program.
3E-5

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DESCRIPTION
YEAR
1 | 2 | 3 | 4 | 6 I 8 | 7 | B | 9 | 10 I 11 | 12 | 13 | 14 |"l6
16 | 17 | 18 | 19 | 20
Establish Regulatory Authority
Identify Stormwater Pollution Hot Spots
Conceptual Plan & Cost Approval
Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Preliminary Agency Approvals
I

Design Stormwater Treatment Retrofits
Permit Stormwater Treatment Retrofits
Construct Stormwater Treatment Retrofits

'ฆ . 'ฆ %<ฆ wyA
Post-Construction Water Quality Monitoring
Figure E-2. Implementation schedule for Stormwater Option Sib: Retrofit hot spots and population centers.

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EJ OPTION Sic - RETROFIT STORMWATER FACILITIES THROUGHOUT SANCTUARY
E.3.1 Description
The option for retrofitting storm water facilities throughout the Florida Keys is:
•	Retrofit hot spots as specified in Option Sla.
*	Initiate an extensive stornrwater retrofitting program for population centers discussed in Option Sib and
other developed areas.
•	Install swales and detention facilities along U.S. 1.
•	Include the ultimate disposal of stormwater via boreholes or deep wells.
EJ.2 Rationale
The rationale for. selecting Option Sic over Option Sib would be that the higher intensity and commitment
associated with Option Sic would result in a significant long-term improvement in water quality over that provided
by Option Sib. Additional monitoring and studies may be necessary to select this option.
E.3.3 Pollution Reduction
The effectiveness of this option is not well known and is very site specific. Nutrient removals are highly dependent
on site conditions, engineering methods, and level of facility maintenance.
*	Potential reductions in total nitrogen and total phosphorous loadings are estimated to be about 20 to 50 %
of the total man-induced loadings (stormwater and wastewater) to the FKNMS.
*	Potential reductions in sediment loadings are estimated to be about 40 to 60% of the total man-induced
loadings (stormwater and wastewater) to the FKNMS.
Some of the toxic constituents in stormwater runoff will be removed by this option. The toxic constituents removed
generally will be those associated with sediments or floating materials. Because of the many different toxic
materials, the wide range of concentrations at which specific constituents are toxic, the high variability in stormwater
quality from site to site, and the lack of significant stormwater data concerned with the Keys, the degree of
reduction of toxic materials attained by implementing this option cannot be reliably estimated.
E.3.4 Cost
Construction costs, when boreholes are used for disposal, are estimated to be $530 million. The present worth, 20-
year operation &. maintenance costs are estimated to be $680 million based on a 696 """'"I inflation rate.
Construction costs, when deep wells are used for disposal, are $680 million. The present worth, 20-year operation
and maintenance costs are estimated to be one billion dollars, based on 6 % annual rates. The estimated total 20-
year costs for Option Sic are $1.2 billion with borehole disposal and $1.7 billion with deep well disposal.
E.3.5 Implementation Schedule
A proposed fast-track implementation schedule for Option Sic is shown in Figure E-3. This schedule can be
compressed or extended as dictated by priorities and funding.
3E-7

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DESCRIPTION
YEAR
1 I 2 | 3 | 4 | ป ~6 | 7 | 8 | 9 | 10 ~1 | 12 | 13 I 14 | 16 18 | 17 1 IB | 19 | 20
Establish Regulatory Authority
Identify Stormwater Pollution Hot Spots
Conceptual Plan & Cost Approval
Establish Funding Mechanism
Preconstruction Water Quality Monitoring
Preliminary Agency Approvals

Design Stormwater Treatment Retrofits
Permit Stormwater Treatment Retrofits
Construct Stormwater Treatment Retrofits
Post-Construction Water Quality Monitoring

Figure E-3. Implementation schedule for Stormwater Option Sic: Retrofit stormwater fadlites throughout the Sanctuary.

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EJ.6 Affected Entities
Entities affected by this option are identical to those affected by Options Sla and Sib (see Section E.1.6).
EJ.7 Environmental Efleets
Construction of stonnwater control facilities will cause short-term construction impacts. The removal of developed
land for detention/retention facilities will be a long-term effect. The creation of some artificial upland wetlands for
stonnwater treatment has a net beneficial result.
EJ.8 Additional Monitoring
A marina stormwater-control demonstration project is recommended (see Section E.1.8). As with Options Sla and
Sib, pre- and post-implementation monitoring is recommended to assess effectiveness of the retrofit program.
3E-9

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TASK 5 - FUNDING SOURCES REPORT
CONTENTS
Acronyms		 v
1.0 INTRODUCTION	 5-1
2.0 OVERVIEW OF THE WATER QUALITY OPTIONS 	 5-1
2.1	WASTEWATER MANAGEMENT	 5-1
2.1.1	On-site Sewage Disposal Systems 		5-1
2.1.2	Package Plants		5-3
2.2	STORMWATER MANAGEMENT		5-3
2.2.1 Funding Requirements		5-4
2.3	MARINAS AND LTVE-ABOARDS 		5-4
2.3.1 Funding Requirements		5-4
2.4	LANDFILLS 		5-5
2.4.1 Funding Requirements	 		5-5
2.5	MOSQUITO CONTROL		5-5
2.5.1 Funding Requirements		5-5
2.6	PUBUC EDUCATION/OUTREACH 		5-5
3.0 FUNDING MECHANISMS	 5-6
3.1	MUNICIPAL BONDS	 5-6
3.1.1	General Obligation Bonds 		5-7
3.1.2	Revenue Bonds 		5-7
3.1.3	Certificates of Participation 		5-7
3.1.4	Pooled Bonds 		5-8
3.1.5	Private Activity Bonds		5-8
3.1.6	Impacts		5-9
3.2	TAX FINANCE 		5-9
3.2.1	Florida State Level Tax Revenue 		5-10
3.2.2	Florida Local Level Tax Revenue		5-10
3.2.3	Taxation Related to Water Quality Improvements		5-11
3.2.4	Impacts		5-16
3.3	GRANTS AND LOANS 		5-17
3.3.1	Federal 		5-17
3.3.2	State		5-21
3.3.3	Impacts		5-21
3.4	RATES		5-21
3.4.1	Utility Rates		5-21
3.4.2	On-site Sewage Disposal Systems	 		5-22
3.4.3	Impacts			5-22
3.5	FEES	-		5-23
3.5.1	User Fees		5-23
3.5.2	ToUs		5-25
3.5.3	Impact Fees 		5-25
3.5.4	Fines and Penalties		5-26
3.5.5	Impacts	 		5-26
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CONTENTS (continued)
3.6	LICENSES AND PERMITS		5-27
3.6.1	Licenses		5-27
3.6.2	Permits		5-27
3.6.3	Impacts		5-28
3.7	SPECIAL ASSESSMENTS 	 		5-28
3.7.1 Impacts		5-29
3.8	DONATIONS/CHARITABLE TRUSTS		5-30
3.8.1 General Description 		5-30
3.9	PRIVATIZATION				5-30
3.9.1	Operations Contracting		5-30
3.9.2	Construction and Operations Contracting		5-30
3.9.3	Impacts		5-31
4.0 IMPLEMENTATION		5-32
4.1	SELECTING FUNDING MECHANISMS - CONSIDERATIONS	 		5-32
4.2	APPROACHES TO FINANCE		5-33
4.2.1	Wastewater Treatment	 		5-33
4.2.2	Stormwater Treatment		5-35
5.0 CONCLUSIONS		5-37
6.0 REFERENCES		5-37
TABLES
5-1 Applicability of potential funding sources to water quality options	 5-2
5-2 Potential combination of funding sources for a comprehensive on-site
sewage disposal system 		5-36
5-3 Potential combination of funding sources for a stormwater utility		5-36 „
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ACRONYMS
ACIR	Florida Advisory Council on Intergovernmental Relations
BEBR	Bureau of Economics, Business, and Research
BLGFA	Bureau of Local Government Wastewater Financial Assistance
BNW	Batte lie-Northwest
CDBG	("/immunity Development Block Grants/Entitlement Grants
COP	Certificates of Participation
CSO	combined sewer overflow
CWA	Clean Water Act
DOC	U.S. Department of Commerce
EPA	Environmental Protection Agency
FKNMS	Florida Keys National Marine Sanctuary
FDER	Florida Department of Environmental Regulation
FDHRS	Florida Department of Health and Rehabilitative Services
FDNR	Florida Department of Natural Resources
FDOA	Florida Department of Agriculture
FHA	USDA Fanner's Home Administration
FHFA	Florida Housing Finance Agency
FKAA	Florida Keys Aqueduct Authority
FS	Florida Statutes
FTCC	Finance, Taxation, and Claims Committee
FWS	U.S. Fish and Wildlife Service
FY	fiscal year
HUD	U.S. Department of Housing and Urban Development
IDRB	Industrial Development Revenue Bonds
NCW	Near Coastal Waters
NEEA	National Environmental Education Act
NOAA	National Oceanic and Atmospheric Administration
NPDES	National Pollutant Discharge Elimination System
OMB	U.S. Office of Management and Budget
OSDS	On-site Sewage Disposal System
PSFC	Puget Sound Finance Committee
PSWQA	Puget Sound Water Quality Authority
RCW	Revised Code of Washington
SCORE	Small Community Outreach and Education
SFWMD South Florida Water Management District
SCS	USDA Soil Conservation Service
USDA	U.S. Department of Agriculture
WWTP	wastewater treatment plant

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1.0 INTRODUCTION
As part of Phase II, Battelle-Northwest (BNW) was tasked with identifying and evaluating potential sources ~
funding for implementing any necessary institutional and structural corrective actions. The information used in this
report has been gathered from review of Florida State regulations related to funding and analysis of funding options
used in similar activities. This report should serve as an inventory of potential options that can be used to address
certain aspects of the water quality issues in the Florida Keys National Marine Sanctuary (FKNMS).
A wide range of options has been identified for addressing water quality issues in the Keys. The agencies and
institutions that will be involved in implementing these options are diverse in terms of capabilities and resources.
Many of the funding mechanisms discussed in this report could be used to address a number of different
management and engineering options, and it will be the task of the agencies and institutions involved to determine
which options are more appropriate for them. At this stage in the development of management plans for the
FKNMS, no single preferred option, or set of options, has been recommended for addressing water quality issues
in the Keys. Because of this, it is difficult to determine the type and level of funding that will be required and the
potential impacts this funding will have on the local economy. For this reason, this report does not recommend a
specific suite of funding options to use nor does it contain an extensive analysis of economic impacts or potential
revenue generation.
This report presents an inventory of potentially available options for financing water quality improvements in the
FKNMS. Section 2 provides a description and discussion of the water quality issue areas for which funding will
be required. Section 3 discusses the categories of funding mechanisms and provides examples of specific
mechanisms that could be used to finance activities in the Florida Keys. In Section 4, an overview of steps for
implementing the funding mechanisms, and strategies for implementing the funding mechanisms in the areas of
wastewater and storm water management, are identified and discussed. Conclusions are in Section 5.
2.0 OVERVIEW OF THE WATER QUALITY OPTIONS
The management and engineering options have been divided into several issue areas based on the priority issues
identified in the Phase I report. These areas are wastewater management (including both on-site sewage disposal
systems [OSDS] and wastewater treatment facilities), stormwater management, marinas and live-aboards, landfills,
and spills and hazardous waste. In addition to these management and engineering options, this section also discusses
potential funding for public education and outreach. Applicability of potential funding sources to water quality
options is illustrated in Table 5-1.
2.1 WASTEWATER MANAGEMENT
2.1.1 On-site Sewage Disposal Systems
One of the major suspected sources of water quality degradation in the Keys is the extensive use of on-site septic
systems, especially in the unincorporated areas of Monroe County. Although OSDSs are required to be permitted
prior to installation, there is presently no requirement to upgrade older systems to bring them into compliance with
current regulations. In addition, owners of these systems are not required to monitor for nutrients in their effluent.
Water quality options discussed in Tasks 3 and 4 that seek to address this problem would require that all current
OSDSs comply with current regulations. This may include upgrading the septic systems to current standards or
retrofitting them with nutrient removal systems. This option would allow the septic systems to remain in operation,
but would increase the management and monitoring of these systems to enhance protection of the manne
environment.
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Table 5-1. Applicability of potential funding sources to water quality options.
Municipal Tax Grants	Fea Licenses Special Privatiia- Donations
^iHuh Finance and	sod Atini ttoo and Trusts
Permits meats
WASTEWATER
Retrofit Packife Plata*
Ccstralizatioo of Treatment
Facilities
STORMWATER
Change Africulnml Practices
EflbADGCd Public Education	•	•	*
T-j'	•	•	•
Pickup
Eotanctd Public	•	•	• •
TruupoftAtioo
Fliminam Size Exemption foe	*
Suxmwater Permits
MARINAS UVE-ABOARDS
Coanrucl Onshore Putnpout
Faciiitiea
Coastnirl Maintenance Anas
Require Containment around
Fuel Docks
Specified Mooring Fields
LANDFILLS
Increased Groundwater
Monitoring
Remedial Action*
MOSQUITO CONTROL
Alter Application Techniques
Evaluation and Study of
Impacts
PUBLIC EDUCATION AND
OUTREACH
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Another approach to addressing the OSDS problem is to gradually replace the septic systems with sewers.
Construction of 2 to 12 community or 3 subregional wastewater treatment plants (WWTPs) would be required over
a period of 12 to 20 years (see Tasks 3 and 4). Large population areas would be the first priority of these
community or subregional systems.
2.1.1.1 ACTIVITIES TO BE FUNDED
Activities requiring funding include the capital expenses of retrofitting existing OSDSs and the construction of
community or subregional plants and collection systems. Should the septic 'systems be left in place and upgraded,
additional funding will be required for providing on-site inspection and monitoring to ensure continued compliance
with the regulations.
2.1.2 Package Plants
A significant portion of domestic wastewater treatment in the Keys is accomplished through the use of small
"package plants" that serve individual uses such as schools, trailer parks, hospitals, restaurants, and hotels/motels.
These package plants generally discharge their effluent into boreholes or injection wells permitted by the Florida
Department of Environmental Regulation (FDER). Package plants are designed to meet secondary treatment
standards, but do not have any requirements regarding nutrient levels. Although a direct connection between
borehole disposal of effluent from package plants and nitrification of surface waters has not been made, it is
suspected that these plants may be contributing to increased nitrogen levels of nearshore waters in the FKNMS.
One water quality option that would address the impacts of package plants is to retrofit the package plants for
nutrient removal. This option would continue to use boreholes for effluent disposal or require the construction of
deep wells (3,500 feet or deeper) for waste injection. An additional option would be to connect facilities currently
using package plants to centralized wastewater treatment facilities. The latter would require the construction of 2
to 12 community or 3 subregional treatment facilities over a period of 12 to 20 years. New treatment facilities that
have a potential for discharge to nearshore waters are assumed to incorporate advanced waste treatment technology.
Facilities with little or no potential for discharge to nearshore waters are assumed to use secondary treatment.
Treated effluent from these treatment facilities could be used for irrigation.
2.1.2.1 FUNDING REQUIREMENTS
Activities requiring funding include the capital expenses of retrofitting existing package plants and the construction
of community or subregional treatment facilities. Construction of deep wells may also be classified as a capital
expenditure. Noncapital funding requirements include water quality monitoring and facility inspection.
2.2 STORMWATER MANAGEMENT
A potentially major source of nonpoint pollution results from storm water runoff from roads, industrial facilities,
agricultural land, and residential areas. This water can cany several types of pollutants including petroleum
products, fertilizers, and pesticides. The South Florida Water Management District (SFWMD) has been delegated
authority over storm water management by the FDER. SFWMD currently requires stormwater permits for
development of sites over 10 acres in size with 2 or more acres of impervious surface. Industrial facilities and roads
are required to provide some level of stormwater treatment before the water is allowed to be released to the
stormwater canals. Activities that do not meet the size requirements for SFWMD permits may still be required to
receive a permit from the municipality or local government. Water from the canals is not currently treated for
pollutant removal prior to being released to the surface waters, nor is it required to have a discharge permit.
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Because storm water carries pollutants from a number of sources, its impact to water quality is very difficult to
quantify. Two options to decrease the impact of stormwater on the FKNMS include requiring treatment of
stormwater in "hot spots" and developed areas, and discharging treated water into boreholes or deep wells.
Combined sewer overflows (CSOs) associated with wastewater treatment facilities often become overwhelmed during
periods of heavy rain and discharge untreated sewage directly into surface waters. Managing discharges from CSOs
is also an option for improving water quality. Requirements for CSO management are currently being reviewed
by the Environmental Protection Agency (EPA).
Additional options include the use of natural filtration systems to retain stormwater and allow certain pollutants to
settle out or be absorbed. These systems include swales, waterways, filter strips, and wetlands. In addition to
changing engineering practices related to stormwater management, rnhanrrrt public education on the fate of
pollutants released to storm sewers may also have some impact on water quality. Other options include enhancing
the curbside trash collection program to reduce the amount of garbage carried away by stormwater, and enhancing
public transportation systems to lessen the number of automobiles adding pollutants to road surfaces. An additional
option would eliminate the size exemption for stormwater permits and require all activities to contribute to
stormwater management.
2.2.1 Funding Requirements
Construction activities, including retrofitting wastewater treatment facilities to eliminate CSOs, the creation of
boreholes or deep wells, or construction or expansion of public transportation services - will require capital
expenditures. Other activities that will need to be funded include enhanced stormwater monitoring, increased
garbage collection, inspection of cars and trucks, and enforcement.
23 MARINAS AND LIVE-ABOARDS
Boating is a popular activity within the Florida Keys. The Phase I report indicates that there are approximately
1,285 slips in the lower Keys and 2,053 in the middle and upper Keys. A substantial portion of the recreational
boating activity within the Keys is associated with live-aboards (defined as boats serving as a continuous residence
for a period of 2 months or more). Recreational boating activities affect water quality in several ways. Fuel and
oil are released to the environment from marina fuel facilities and boat bilges. Other pollutants result from boat
cleaning and maintenance activities such as bottom scrubbing and painting. In addition, live-aboards contribute to
water quality degradation through the release of human waste.
Of the 186 marinas in the Keys, only 8 are equipped with sewage pump-out facilities. One option for addressing
the water quality impacts associated with marinas and live-aboards would be to require the construction of onshore
pump-out facilities or provide mobile pump-out service. Reduction of pollutants from boat maintenance activities
could be addressed by requiring maintenance areas to be constructed for collection and proper disposal of paint and
other hazardous wastes. Additionally, marinas could be required to provide containment around fuel docks to
prevent the spread of spills. Options for addressing boat impacts outside the marinas include designation of specific
mooring fields for anchorage.
2.3.1 Funding Requirements
Because most of the marinas in the Keys are privately owned, the requirements on agencies and institutionsinvolved
in water quality management in funding marina activities are different from those associated with either wastewater
or stormwater management. The marinas are located on state aquatic lands and are required to obtain permits and
leases. Some public assistance to private marinas in meeting the water quality option requirements may be deemed
in the interest of the state. This may include assistance in constructing pump-out facilities, purchase of mobile
pump-out vessels, and construction of containment areas for boat maintenance. In addition, funding for enforcement
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of live-aboard sewage disposal regulations and marina fuel containment areas will be required. Public education
on the issues associated with recreational boating impacts on water quality may also need to be funded.
2.4 LANDFILLS
There may be some impact on FKNMS water quality from operating or closed landfills. Of the four landfills
previously operating in the FKNMS, only the Key West facility is still in operation. This facility is expected to be
closed by November 1993. Although present and former landfills have operated within state and federal water
quality standards, there is some question as to whether these standards are strict enough to protect the environment
of the FKNMS.
Options to address the water quality issues associated with current and former landfill operations in the FKNMS
include a search for abandoned landfills and increased monitoring of groundwater to determine the level of impact.
Additional requirements, such as removal of the landfill or implementation of remedial actions, may also be
necessary.
2.4.1 Funding Requirements
A search for abandoned landfills and increased monitoring of landfills will require additional funding. Remedial
actions, such as the removal of the landfill or installation of containment devices (slurry wails), may require
increased levels of funding.
2.5 MOSQUITO CONTROL
The Mosquito Control Program conducted by the Florida Department of Agric ilture (FDOA) is a potential source
of nonpoint pollution in the FKNMS. Pesticides are generally applied via truc> spraying; however, during periods
of heavy mosquito infestation, aerial spraying is employed, which increases the likelihood of airborne contaminants
being dispersed into the FKNMS area. Although there have been no in-dep.a studies relating mosquito control
activities to deteriorating ecological and environmental effects in the Keys, it if possible that adverse impacts to the
neaishore environment are occurring.
Water quality options to address the impacts of mosquito control activities irr:iude changing application techniques
from aerial to truck spraying, or finding alternative methods for mosquito control. Evaluation and study of the areas
in which the controls are being applied have also been identified.
2.5.1 Funding Requirements
Research and monitoring of current application techniques and evaluation of alternative techniques will all require
some level of funding.
2.6 PUBLIC EDUCATION/OUTREACH
Task 8, Public Education and Outreach, is identifying interested publics and existing public education and outreach
programs and developing a public education and outreach program. The needs for public education and outreach
identified by participants of workshops and strategy sessions hosted by the National Oceanic and Atmospheric
Administration range from general information on the environment of the Keys to specific, activities aimed at
increasing awareness of the impacts of sewage treatment, household hazardous materials disposal, and
environmentally sensitive harvesting and collecting methods for marine resources.
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Some level of public education and outreach is necessary in addressing all of the water quality issues discussed
above. This effort is being addressed separately to emphasize the need for coordinated activities to educate the
public on the number and type of water quality issues in the Keys. In addition, specific funding revenues will nmi
to be designated toward public education and outreach activities. These funds may come from sources specifically
dedicated toward financing public education (i.e. EPA Education Grants), or may be a percentage of the revenue
generated by fees and charges on specific activities.
3.0 FUNDING MECHANISMS
This section contains an inventory of categories of funding mechanisms that can be used to finance water quality
improvement activities in the FKNMS. Examples of specific funding mechanisms and their applicability to water
quality issues are also provided.
Most activities related to financing pollution prevention or control operate on a "polluter pays" principle that
assesses the majority of the costs for an activity to the population creating the adverse impact. The public tends
to view this as an equitable form of assessing costs when the polluters are corporations or industries causing a direct
and noticeable impact to the environment. The perceived equitability of this type of approach is reduced when the
polluter being assessed is the general public.
Since the passage of the Clean Water Act (CAVA) in 1972, a significant effort has been taken to reduce the level
of industrial waste and pollution being discharged into the nation's waters. These point sources are now being
regulated and permitted to reduce their adverse effects on the environment. However, controlling these point
sources has increased the realization that pollution resulting from automobiles, household fertilizer and pesticide use,
improper disposal of household hazardous waste, and other "nonpoint" sources is also having a significant impact
on the health of the environment. Because these nonpoint sources result from day-to-day activities, rather than the
pollution events of industries, it is often difficult for the public to perceive the effects of their activities on the
environment. In the Florida Keys, as elsewhere around the country, it needs to be recognized that these sources
must also pay their fair share of the costs of a clean environment. A number of the taxes and fees discussed in this
section seek to capture the costs of nonpoint source pollution.
3.1 MUNICIPAL BONDS
Municipalities, including stara, counties, and "special districts," are generally authorized to issue municipal bond
securities that pay interest fhat is exempt from federal taxation. Such "tax free" municipal bonds are most
appropriately used to finance projects that involve acquisition of equipment or construction of capital facilities, such
as water delivery systems, solid waste facilities, or sewage treatment plants.
For large-scale capital expenditures, the cost of development may exceed current tax revenue. Bonds offer the
municipality the ability to spread the cost burden of the facility over a long period of time and distribute payment
for the project to all who benefit from it. In some instances the facility created as a result of the bond issue will
provide enough revenue to pay off the bond, but in other instances general tax revenue will be required for
repayment. In either case the people of the municipality pay for the bond through higher taxes, user fees, or utility
rate charges.
Because bonds are most appropriate for large-scale expenditures, it is often in the interest of municipalities and local
governments to groi their capital expenditures into large projects for which bonds could be used. Relatively small
expenditures for equ.;.. nent purchase, for which a bond issuance would normally be inappropriate, can be combined
with activities such as the construction of wastewater treatment facilities or modification of stormwater canals and
be covered by the bonds issued for those activities.
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3.1.1 General Obligation Bonds
As the name implies, a General Obligation Bond is a general obligation of the municipality. This means that the
bond is backed by the full faith and credit, and taxing power, of the municipality, and any form of municipal
revenue may be used to repay the bond debt. General Obligation Bonds may be used for construction of facilities,
infrastructure development, or municipal improvements. Some of these projects may generate revenues while
others, such as roads, may not.
General Obligation Bonds could be used to finance expansion or construction of wastewater treatment facilities, and
may be able to be used for financing retrofit or replacement of OSDSs if those systems are managed by an agency
or authority with the ability to issue bonds. The state or local government may also issue General Obligation Bonds
for construction of public infrastructure such as boat pump-out facilities, boat launches, and maintenance areas for
boat repair. General Obligation Bonds may also be used for providing other types of infrastructure such as public
transportation and roads.
3.1.2 Revenue Bonds
Revenue bonds are issued to finance projects that will provide revenue that can be used to repay bond debt. Sewage
treatment plants, water delivery systems, and solid waste facilities are all examples of capital facilities that can be
financed through issuance of Revenue Bonds. A specific type of Revenue Bond that deserves mention is a Special
Assessment Bond. Special Assessment Bonds are secured by revenues generated through assessments on the
properties benefiting directly from improvements. The use of special assessments as a funding mechanism is
discussed in Section 3.7.
Because Revenue Bonds are used for projects that generate revenue, they are a potential option for financing the
construction of wastewater and storm water treatment facilities where those facilities charge rates or fees for their
services. In addition. Revenue Bonds may also be an appropriate funding mechanism for construction of storage
and reuse facilities that would sell treated effluent for agricultural/horticultural applications.
The city of Key Colony Beach used Revenue Bonds to finance construction of its sewage treatment plant, and Key
West has also used Revenue Bonds for wastewater treatment facility expansion (J. Sheldon, Key Colony Beach,
personal communication, 1992) (P. Cates, Key West City Government, personal communication, 1992).
3.1.3 Certificates of Participation
Certificates of Participation (COPs) are a type of municipal security similar in design to traditional municipal leases.
In a traditional lease the municipality provides funding for a project and then earns income through lease of the
facility. With a COP, investors purchase the COP, thereby providing funding for the project. The municipality uses
those fluids to finance the project, which is then leased, and the income from the lease is used to make biannual
interest payments to investors and to repay the COPs at maturity. COPs have been used for financing such things
as fire trucks, sewer-related equipment, and telecommunications systems (Barzel 1988). They are traditionally a
small issue security but can be pooled into larger issues (Barzel 1988)
COPs are not considered a direct debt of the municipality issuing them but are considered to be a current operating
expense to be paid through annual budgetary appropriation. COPs are usually short-term instruments and do not
require voter approval. They provide an easy way for municipal governments to finance projects with fewer of the
administrative and bureaucratic difficulties associated with standard bond issues. For this reason, COPs may be
criticized as a method for governments to finance projects that provide unpopular facilities without public consent.
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3.1.4 Pooled Bonds
Issuance of Municipal Bonds can be quite costly for some smaller municipalities. While large municipalities enjoy
a relatively >ad tax capacity and a resulting ability to issue municipal bonds easily, smaller municipalities may
have difficulty obtaining a good credit rating or simply affording the cost of the bond issuance. In some instances,
small municipalities, or relatively small projects, could be abandoned due to the expense of small bond issues.
Several states and regions have sought to ease these difficulties by creating Municipal Bond Banks that either pool
the individual bond issues into one large issue or use a large state General Obligation Bond issue to generate funds
to purchase the smaller bond issues directly from small municipalities. In either case, the bonds are issued as
General Obligation Bonds carrying the full faith and credit guarantee of the state. This method reduces the cost of
issuance to the small municipality by spreading the costs over all participants of the pool. In addition, use of the
state's higher credit rating reduces interest costs.
The funds required for some water quality improvement options at the local level may be too small for a standard
bond issue. A state-operated bond bank or bond pool could provide a mechanism for issuance of bonds to finance
these projects.
A similar approach to this type of financing has been used to enhance the available revenue in the State Revolving
Loan Funds (see section 3.3.1.1). States issue bonds and deposit the revenue into the State Revolving Loan Fund.
These monies are then loaned to local governments in the same manner as other revenues from the Fund. Federal
and state contributions to the State Revolving Loan Funds are used to lower the interest rate on the loans made to
the local governments, and increase the credit rating of bonds (EPA 1990b). The State of Flonda uses a similar
approach in its Bond/Loan Program (see section 3.3.2).
3.1.5 Private Activity Bonds
The 1986 Federal Tax Reform Act greatly altered the rules for issuance of certain classes of municipal bonds. Prior
to the act, municipalities and special districts were allowed to issue tax-free Industrial Development Revenue Bonds
(IDRB) to finance development (ACIR 199Id). In many cases such development was undertaken specifically to
make a locality more attractive to industry. Facilities such as business incubators and manufacturing plants were
constructed using IDRBs and then contracted to private companies. The proceeds of the contracting arrangement
were then used to repay the bond debt.
Use of IDRBs to finance projects was severely curtailed by the 1986 Federal Tax Reform Act. The 1986 Tax Act
defines such bonds as private activity bonds if more than 10% of the bond repayment revenue comes from private
activities such as private operation of a WWTP. The 1986 Tax Act established a statewide private activity "unified
bond cap" based on a dollar amount per capita. Subsequent to the passage of the 1986 Tax Reform Act, the Internal
Revenue Service in Section 146 of the Internal Revenue Code of 1986 defined the unified bond cap as the greater
of $150 million or $50 multiplied by the population (ACIR 199Id).
In 1991, Florida was allowed $633.5 million in issuance of private activity bonds statewide. The state of Florida
facilitates the equitable distribution of the private activity unified bond cap through three pools; the State Pool, the
Florida Housing Finance Agency (FHFA) Pool, and the Regional Pools. The State Pool receives 15% of the cap
amount, which is set aside for "Priority Projects." Such projects include solid waste disposal and sewage facilities.
Additionally, the State Pool may fund other eligible private activity bonds issued by the Florida government or
FHFA. The FHFA pool receives 25 % of the cap amount and utilizes that portion for housing-related projects. The
Regional Pools receive 60% of the volume cap, which is then further allocated to each of the regions for general
private activity bonds. The Executive Office of the'Govemor is responsible for prioritizing projects applying to the
State Pool. The Regional Pools are allocated via lottery (ACIR 199Id).
Under the allocation schemes for each pool, there is no assurance that a request for a private activity bond allocation
under the unified cap will be granted. Also, it is possible that only a portion of the amount needed to fund a
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project will be allocated to the project by the pools. In such cases, the authority to issue the private activity bonds
may be carried forward for three years, during which additional applications for inclusion in future pools may be
submitted (ACLR 1991d). In this way, authorization for financing a project with private activity bonds may be
obtained over a three-year period.
3.1.6 Impacts
Bonds are a valuable source of revenue that allow the costs of the project to be spread over a long period of time.
For this reason, they are extensively used to fund construction of public works including water and sewage works,
and landfills. Depending on the type of bond issued, bonds may be paid with either rate or tax revenue. Use of
rate revenue will impact the users of the project, while tax revenue spreads the costs of the project across the entire
taxable public. Depending on the amount of the bond and the repayment schedule, the impacts on rates and taxes
will vary.
Because they are used for long-term financing, use of bonds requires long-term debt management. In addition,
bonds tend to result in either new or increased taxes or rates that can be viewed unfavorably by the public. In many
cases, voter approval is required prior to issuing bonds, making the level of rate or tax increase a significant
consideration. Finally, bonds can be expensive to issue and can increase administrative burdens on the issuing
entity. Pooling of bonds may lower these transaction costs. In general, bonds are viewed as a relatively equitable
source of finance because, whether they are repaid by taxes or rates, they spread the costs of a project providing
public benefit over the population that is benefiting.
3.2 TAX FINANCE
The most prevalent form of municipal revenue generation is direct taxation of the public. Taxes can take on a wide
variety of forms but usually can be grouped into one of three general categories: personal income, property, and
sales and use. In addition to personal taxation, many states charge corporate income taxes or business and
occupation taxes.
Taxation of personal income occurs in all but seven states (FTCC 1991b). This form of taxation is usually used
to provide general revenue to be allocated in the state budget process. Some states levy income taxes on a
progressive scale similar to federal income taxes, while others charge a flat percentage of income. In some cases,
counties are allowed to charge "piggyback" income taxes on the state income tax to provide additional county budget
revenue. Although the Florida Constitution prohibits the levying of a personal income tax, for a majority of states
this type of tax represents a significant source of income.
Taxation of personal property, such as real estate, boats and automobiles, is a common form of taxation. Property
taxes on real estate are usually charged via a millage rate (one mill equals SI per $1,000 of assessed value) on the
assessed value of property. Exemptions for government property and leaseholds are often granted, and some
personal exemptions may be granted as well. In some states, personal property such as boats or automobiles are
also taxed based on market value.
Sales and use taxes are charged by most states and include taxes on many consumer items. Such taxes can be levied
on a per-unit basis or as a percentage of value. In addition to standard sales taxes, specific1 commodities are
sometimes taxed to provide revenues for government programs related to the commodity. Such taxation often
occurs on consumption of a good that has an impact on infrastructure or the environment.
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3.2.1 Florida State Level Tax Revenue
The Florida State Constitution grants to the state all revenue sources not specifically provided for by law except ad
valorer.. property taxes (MacManus 1991). This provision gives the state sole authority to assess and collect taxes
unlets the state legislature authorizes specific taxes at the local or county level. In addition, the constitution
prohibits assessment of a state income tax. The inability of the state to collect ad valorem property taxes or state
income taxes effectively limits its revenue to sales and use taxes. This limitation has resulted in numerous sales
taxes and tax surcharges.
Florida tax revenue must be deposited into one of four types of funds in the custody of the state treasury, unless
specifically exempted. The four fund types are: (1) the General Revenue Fund; (2) Trust Funds; (3) the Working
Capital Fund; and (4) the State Infrastructure Fund (MacManus 1991). The Florida legislature is responsible for
appropriation of state tax revenues in the annual budget process. Therefore, use of state level tax revenue for water
quality improvement depends on legislative appropriation of funds to the agencies requesting funds for such
programs.
There are numerous trust funds that are capitalized with tax receipts legislatively earmarked for a specific purpose.
It is estimated that there are approximately 1,200 trust funds in the state (J. Stargel, Florida Tax and Budget Reform
Commission, personal communication, 1992). The funds are established through general law, the constitution, or
a trust agreement and are used for funding specific activities or programs; distributing revenues to individuals or
local governments; and funding construction, repair, or replacement of facilities, as clearing accounts; and as
revolving loan or capital funds (FTCC 1991a). The various trust funds received 60% of all state revenues in 1991
(R. Saunders, Florida House of Representatives, personal communication, 1992) and the trend shows an increasing
share of revenue going to trust funds with less to the other treasury funds. This trend is creating revenue constraints
for the state because any surpluses in the trust funds are not readily available to meet general budgetary needs. This
situation, combined with recessionary decreases in sales tax revenue, has prompted a proposed constitutional
amendment (vote in fall of 1992) to eliminate all trust funds and require legislative reauthorization within a four-year
period and by a three-fifths majority of any funds deemed truly necessary. This amendment would return
appropriations power to the legislature and would allow greater budget flexibility, but may also impact water quality
funding by eliminating trust funds that receive funds with strict definitions as to disbursement for water quality
improvements (J. Stargel, Florida Tax and Budget Reform Commission, personal communication, 1992). Under
the proposed amendment, such a trust fund could be re-established by a three-fifths vote of the Florida Legislature.
3.2.2 Florida Local Level Tax Revalue
County and local governments in Florida are constitutionally limited to collection of ad valorem property taxes,
"local option" taxes legislatively authorized by the state, and state revenues shared with the local and county
governments.
The constitutional provision that grants ad valorem tax rights ti cities and counties also sets property tax millage
limits of 10 mills for county purposes, 10 mills for municipal purposes and 10 mills for school districts. In
addition, certain Municipal Service Units and Special Utilities may be authorized to levy property taxes. The use
of such taxes is developed further in Section 3.2.3.10.
In addition to state shared tax revenue, county and city governments are allowed to levy certain "Local Option
Taxes." Such taxes include the Tourist Development Tax, the Infrastructure Tax, the Gas Tax, and the Convention
Development Tax. The revenue from each of these taxes can be used for projects within the county or local area.
The primary purposes of these taxes is to benefit tourism, develop infrastructure, enhance transportation, and
provide convention facilities, respectively. Each of these taxes, with the exception of the Convention Development
Tax, are discussed in relation to water quality in the subsections of 3.2.
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The State of Florida shares tax revenue with counties, local governments, and school districts in order to promote
equity. There are several methods used to determine the allocation of such revenues. These include considerations
of where the revenue was collected, population, ability to raise revenue, as well as certain compensatory
considerations. The revenue that is shared is, in some cases, limited to specific uses, and qualification to receive
shared revenue may depend on state-mandated requirements. Monroe County received $1.6 million in county
revenue share monies in fiscal year (FY) 1991-92, and the cities of Key Colony, Key West, and Layton received
$17,000, $625,700, and $3,900, respectively. Any portion of this revenue that is not required for specified
allocations goes to the General Fund and may be used by counties and cities to meet their general needs, including
provision of water quality improvements. Obviously, legislative changes made to the revenue sharing programs that
enhance the share distributed to the counties and cities of Florida will increase their capacity to fund local projects
related to improvement of water quality.
3.2 J Taxation Related to Water Quality Improvements
Any type of tax can be used to finance water quality activities; however, because taxes often must be approved by
voters, there is generally some connection between the type of activity being taxed and the activities for which the
revenue will be spent. The amount of revenue generated will depend on the type of tax being levied, the activity
or property on which the tax is levied, and the goal of the tax.
Sales and use taxes provide a good mechanism for providing revenue for specific programs. These taxes can be
easily earmarked for use in specific activities and, for this reason, often are received more favorably by the general
public. Both personal income and personal property taxes provide money to the general state revenue. The amount
allocated to specific programs for these taxes needs to be appropriated on a yearly basis, with no guarantee that
funds appropriated one year will be available for ongoing project activities in the following years.
Sales and use taxes can also be used to discourage specific behaviors. An example of such a tax is North Carolina's
Recycled Paper Tax Incentive, which charges a tax on virgin newsprint used by newspapers (Apogee Research, Inc.
1991). The goal of this tax is to discourage the use of virgin paper and encourage recycling. For this type of tax
to work on products purchased by the general public, such as fertilizers, it is necessary for the tax to be significant,
for alternatives to the taxed products to be available, and for the public to be aware of the impact that purchase of
the taxed product has on water quality or the environment
The following taxes are those that have commonly been used to finance water quality-related activities. The
majority of them are taxes on items or activities that contribute to water quality degradation, such as motor fuel.
Some of these taxes are currently used in Florida, while others are being used elsewhere. Personal property taxes
are also used to finance water quality-related activities such as the construction of wastewater and stormwater
treatment facilities.
3.2.3.1 CIGARETTE AND OTHER TOBACCO PRODUCTS TAX
Some states have used taxes on cigarettes and other tobacco products as a means of financing water quality
improvements. In Washington, a percentage of the wholesale price of tobacco products and an 8-cent tax on each
pack of cigarettes is dedicated to the state Centennial Clean Water Fund. This fund is used to provide grants to
conservation districts and to support public education and outreach activities (Puget 1989). Both Rhode Island and
Florida also have cigarette and tobacco-product taxes, but the funds are not specifically earmarked for water quality
programs.
Florida charges 33.9 cents per pack of cigarettes and 25% of the wholesale sales price for noncigarette tobacco
products and cigars. Collections in 1992-93 are estimated to be $455 million, with 32.4% allocated to municipal
revenue sharing and 2.9% to county revenue sharing (ACIR 1991a). Increasing the cigarette tax by 1 cent per pack
could generate an additional $12.8 million statewide (FTCC 1991a). Although not currently allocated to water
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quality programs, taxes on cigarettes and other tobacco products, if increased, could be used to finance water quality
activities similar to the Centennial Clean Water Fund in Washington.
3.2.3.2	UTILITIES TAX
Florida currently charges a 2.5% tax on gross receipts from electric, gas, telecommunication services and co-
generated electrical power transmission utilities. The revenue generated is allocated to the Public Education Capital
Outlay and Debt Service Trust Fund. This tax will provide an estimated $4-8 million in FY 1992-93 (ACIR 1991a).
In Washington state, receipts from utility and sales taxes on water, sewer, and garbage collection go to support the
Public Works Trust Fund, which provides low-interest loans for repair and construction of sanitary and storm sewers
(PSWQA 1991). A tax on wastewater and stonnwater utilities in Florida could provide revenue for facility
expansion and improvement, water quality monitoring, and public education and outreach.
3.2.3.3	MOTOR FUELS AND PETROLEUM PRODUCTION TAXES
Several states that charge taxes on motor vehicle fuels have expanded their programs to include marine fuels.
Because recreational boating has an impact on water quality, marine fuel taxes are viewed as an equiuble method
for financing both the capital and operating expenses of water quality improvements. This tax applies to both
resident boaters and people using their boats for transportation into the state, thereby making this tax more equiuble,
and less easy to circumvent, than boat registration fees. Commercial carriers are currently assessed a federal marine
fuels tax that is used to finance the Inland Waterways Trust Fund (Buzzards Bay Project 1991). State taxes on
marine fuels can be assessed on both commercial and recreational users.
Florida charges a 4-cent-per-gallon state tax on motor fuels and special fuels. Local governments are allowed to
charge a tax of 1 to 6 cents on motor fuel and special fuels sold at the retail level (ACIR 1991a). These funds are
collected by the state and returned to the counties via a revenue-sharing program. In addition to this Local Option
Gas Tax, a county may also impose a 1-cent-per-gallon Voted Gas Tax by referendum. Revenues from this county
tax may be shared with municipalities. Monroe County does not currently have a Voted Gas Tax.
Estimated gross collections of the Motor Fuels Tax for the state for FY 1992-93 are $997 million (ACIR 1991a).
Flonda currently exempts fuels used for agriculture, aquaculture, and commercial fishing. The estimated value of
this exemption is S2.6 million. Increasing by 1 cent the tax on motor and special fuel would provide an additional
$71.6 million statewide (FTCC 1991a,b).
As with most states, the majority of the revenue generated by the motor fuels tax is allocated to road construction,
maintenance, and repair (3.8% of the revenue is allocated to Aquatic Weed Control). Several states, such as
Washington, Virginia, and North Carolina, are examining the potential for capturing the portion of taxes provided
by purchase of marine fuels to provide funds for marine-related water quality programs. By eliminating the
exemption on agriculture, aquaculture, and commercial fishing, the state of Florida would gain an additional $2.6
million that could be applied to both marine programs and activities aimed at controlling nonpoint pollution from
agricultural land. Additional funds could also be diverted to water quality-related activities by estimating the amount
of the Motor Fuels Tax that comes from purchase of fuel by recreational boaters and allocating those funds to water
quality programs.
A Voted Gas Tax in Monroe County could also be \ised to provide revenue for water quality-related programs such
as nonpoint pollution control from roads and highways, and providing assistance in developing facilities for
controlling pollution from marinas and boat yards.
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3.2J.4 TOURIST DEVELOPMENT AND IMPACT TAXES
Some of the water quality impacts in the Florida Keys result from activities that support seasonal tourists. Use of
package plants by hotels, motels, and restaurants has been suspected to contribute to increased nutrient loadings.
In addition, tourists cause stress to garbage and maintenance services. Revenue generated by taxes on lodging and
meals can be used to offset some of the costs of tourist-related impacts.
Sales taxes on lodging have been used in Dare County, North Carolina (Buzzards Bay Project 1991), and in Rhode
Island for economic development and general revenue (EPA 1990a). In addition, both North Carolina and Virginia
charge occupancy taxes on hotels, rental houses, and cottages (Apogee Research, Inc. 1991).
Under the Local Option Tourist Development Tax, Florida counties can levy taxes on living accommodations in
hotels, motels, apartment houses, rooming houses, and mobile home parks. Proceeds of the tax must be used to
promote tourism and finance tourist-related facilities or tourist-promotion bureaus. This includes financing "beach
improvement, maintenance, renourishment, restoration, and erosion control, including shoreline protection,
enhancement, (and) cleanup" (ACIR 1991a).
The Florida Keys is a major destination for scuba divers. It is unclear whether the Local Option Tourist
Development Tax could be used to address water quality impacts affecting coral reefs or other coastal areas of
interest to this specific group of tourists. Special authorization from the legislature may be required in order to use
proceeds from the tax to offset the costs of sewer systems to which hotels and other tourists facilities would be
connected. (Special authorization has been given to counties, under specific conditions, to levy Convention
Development Taxes to provide revenue for development of convention centers, stadiums, and exhibition halls.)
Since 1981, Monroe County has charged a 3% tourist tax. Proceeds from this tax were approximately $5.7 million
in FY 1989-1990 (ACIR 1991a). Forty percent of these proceeds were used to promote tourism and tourist
activities, 29% were used to fund tourist bureaus, and the remaining 8% were used for other purposes (i.e., special
events). Other counties have used a larger portion of their proceeds to finance beach and lake projects (Indian River
County, 82%, Sarasota County, 50%, Walton County, 50%).
3.2J.5 FOODFISH AND SHELLFISH TAXES
One method for financing activities aimed at protecting water quality and enhancing food fish and shellfish resources
is the use of a foodfish and shellfish tax. Washington State levies a tax on the person with first possession of
foodfish and shellfish for commercial purposes after it has been caught. The state is currently investigating
removing the exemption for aquaculture. The tax rate is on a variable scale by type of fish or shellfish (PSFC
1989).
In Maryland and Georgia, a shellfish tax is levied on the leasing of commercial shellfish harvesting areas.
(Buzzards Bay Project 1991). In Virginia a saltwater take fee is applied to "taking" or harvesting of oysters by the
commercial shellfish industry. Virginia requires both vendors and fishermen to document the amount of oysters
sold (Apogee Research, Inc. 1991).
Proceeds from these taxes are generally applied to resource management and assistance to commercial fishermen.
Water quality improvement activities could also be funded under the goal of resource management and enhancement.
Although the burden of these taxes in Maryland and Georgia falls directly on commercial fishermen, it is envisioned
that some of the burden of the tax is shifted to consumers in higher shellfish prices. Washington's tax is imposed
directly on consumers.
Florida does not currently have a tax on the commercial take of either fish or shellfish. Shellfish catches in 1987
for the state were 61 million pounds, with 13 million pounds caught in Monroe County (BEBR 1991). Although
monetary information is not available for 1987, data for 1984, in which Monroe County caught 18 million pounds.
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indicates the value of this catch to be $40.8 million (BEBR 1987). Applying a tax to this revenue could provide
a significant source of funding for fisheries management and. water quality improvement programs.
3.2J.6 LITTER CONTROL TAX
Washington State imposes a litter control tax on selected products such as food, cigarettes, soft drinks, beer and
wine, newspapers, household paper and paper products, and cleansing agents (EPA 1990a). Fast food restaurants
are subject to the tax that is paid by manufacturers, wholesalers and retailers. Proceeds, estimated at $2 million
annually, are used to fund litter control programs, public education and awareness, and recycling. Several annual
campaigns are aimed at controlling litter from water-oriented activities. Another potential use of this fund is for
public education on household hazardous materials and support of a households hazardous materials collection
program. Rhode Island has a similar tax called the Litter Control Participation Permit. The fee varies based on
the gross receipts of any business selling food for immediate consumption (EPA 1990a).
Studies indicate that a Florida Litter Tax could raise approximately $17.5 million (ACIR 1991a) during FY 1991-92.
Beginning in October 1992, an advance disposal fee of 1 cent per container will be assessed on retail sales of glass,
plastic, aluminum, plastic-coated paper, and other metal containers that are not currently being recycled at a
sustained rate of 50% (ACIR 1991a). This tax could potentially provide S150 million for the Container Recycling
Trust Fund. As with the Washington tax, a portion of these proceeds could be used to finance activities aimed at
reducing litter from water-related activities, enhancing litter control on beaches and coastal areas, and providing
increased litter collection during the tourist season. Another reasonable application of such a tax would be to offset
the costs associated with landfill closure and transport of wastes to landfills outside the Keys.
3.2.3.7 AQUATIC LANDS LEASEHOLD TAX
In Washington, a leasehold tax on all public lands leased to private parties (including aquatic lands) is levied at both
the state and local levels. Properties are charged at a rate of 12.84% on the contract or true rental value of the
lands that are exempt from property taxes. Cities may levy an 4% tax, and counties a 6% tax (Apogee Research,
Inc. 1991).
Florida does not currently charge a leasehold tax, and lessees of public property are currently not being assessed
property tax (FTCC 1991b). (Pursuant to Florida Statutes, state and local government property is exempt if used
for governmental or public purposes, although "as a matter of practice, government-owned property used by a
nongovernmental lessee for private purposes was not assessed" [FTCC 1991a]). There are approximately 186
mannas in the Florida Keys. Leases for use of submerged lands are issued by the Florida Department of Natural
Resources (FDNR), Bureau of Submerged Lands. Levying a tax on marinas, mooring fields, and other leases of
aquatic lands could generate revenue for improving pollution control around marinas and boat yards, and financing
public education on the impacts of recreational boating activities, such as sewage discharge, on the marine
environment.
3.2.3.8 POLLUTANTS TAX
This category covers a range of taxes charged on specific pollutants.
The state of Florida has three pollutant taxes that are allocated to various water quality-related trust funds. A
Coastal Protection Tax of 2 cents per barrel is oharged for pollutants produced in, or imported into, the state.
Under this tax, pollutants include petroleum products, pesticides, chlorine and ammonia (ACIR 1991a). Proceeds
from this tax are allocated to the Coastal Protection Trust Fund to be used by FDER for cleanup of spills. The tax
will remain in force until the balance of the trust fund reaches or exceeds $50 million. If the U.S. Department of
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the Interior approves offshore oil drilling in tae waters off the Florida Coast, the cap on the Coastal Protection Trust
Fund will be increased to $100 million. Tie estimated total in the fund for FY 1992-93 is $5.1 million.
The Water Quality Tax is assessed at $1.50 per new or re manufactured lead acid battery, 2.36 cents per gallon of
solvent or solvent mixture, 1 cent per gallon of motor oil, and 2 cents per barrel of petroleum products, ammonia
or chlorine (ACIR 1991a). Proceeds from this tax are allocated to the Water Quality Assurance Trust Fund. The
estimated balance in this fund for FY 1992-93 is $24.5 million.
The amount of tax charged under the Inland Protection Tax varies depending on the balance in the Inland Protection
Trust Fund to which the proceeds are allocated. The tax is 10 cents per barrel of pollutant if the balance in the fund
is between $35 million and $50 million, 20 cents per barrel if the balance is above $5 million but below $35 million,
and 30 cents if the balance is below $5 million (ACIR 1991a). The estimated FY 1992-93 balance in this fund is
$38.7 million.
Revenues from all three of these trust funds are used to restore or replace contaminated water supplies. Products
that represent a serious threat to the environment, but are not regulated under these taxes, are wood preservatives,
creosote, and fertilizers. Fertilizers have been found to have caused major damage to Florida's water reserves,
particularly the Everglades and Lake Okeechobee (ACIR 1991a). Commercial application of pesticides, fertilizers,
and chemicals is controlled through permitting and regulation. Although guidelines are provided by manufacturers
of pesticides, fertilizers, and chemicals for residential use, the actual application of these products is not well
controlled. A retail tax on these products, combined with public education on the impacts that these products have
on water quality and the environment, could encourage wiser chemical use and use of alternative products.
Revenues generated by the tax could be used to fund public education programs on a wide variety of water quality
issues, as well as providing revenue for residential hazardous waste collection programs.
Nine other states impose some type of pollutants tax. Washington state has a pesticide tax of 0.7 % of the wholesale
value of the product. Consideration has been given to basing the amount of the tax on toxicity, persistence and
biฉaccumulation of the pesticide (PSFC 1989). Water quality activities toward which the proceeds from this tax
could be directed include pollution control, household hazardous waste programs, wetlands, stormwater,
environmental education, and environmental enforcement.
Rhode Island levies a "Hard to Dispose Of Materials" Tax on motor oils, organic solvents, antifreeze, tires, and
automobiles (Buzzards Bay Project 1991). The proceeds from this tax are given to the state Department of
Environmental Management to fund household hazardous waste reduction programs, used-oil recycling, and solid
waste data monitoring and research.
3.2.3.9 IMPACT TAXES
Several states currently charge taxes on goods or activities that have a perceived impact to communities and public
resources. Impact fees (Section 3.5.4) are charged on specific activities impacting provision of public services such
as police, fire, parks, transportation, and septage. Rather thaw having a number of specific fees, an impact tax
could cover all public costs associated with development. Alternatives for levying impact taxes are: per unit charges
for new construction (i.e., per living unit, square foot, or land unit area), excise tax on construction materials, gross
receipts tax on contractors and developers, and a rezoning tax based on the category to which the land is zoned and
the number of acres involved (ACIR 1991a). The amount of revenue generated by such a tax would depend on the
amount of development. The funds could be used (o finance water quality-related activities such as wastewater and
stormwater treatment, and wetlands preservation or mitigation.
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3.2.3.10 PROPERTY TAXES
Property taxes provide a general revenue source for financing improvements in services and infrastructure. In
Florida, counties, municipalities, and special taxing districts are given the authority to levy taxes on personal real
estate. In 1991, property taxes provided $31.3 million in revenue for Monroe County (ACIR 1991a). Under
Florida law, the SFWMD has the authority to levy property taxes to cover the costs of providing and improving
stonnwater management systems (ACIR 1991c).
The Florida constitution currently prohibits the ad valorem taxation of motor vehicles, boats, airplanes, trailers,
trailer coaches, and mobile homes (FTCC 1991b). However, the constitutional definition of these items is not
clearly defined, and it may be possible to alter the tax status of some of these items through appropriate statutory
definitions. For example, mobile homes that are permanently affixed to the property are required to be assessed
as real property, and therefore subject to ad valorem taxation (FTCC 1991b). The CWA allows states to regulate
sewage disposal from "houseboats" and allows the state to determine the amount of time a boat serves primarily
as residence in order to be considered a houseboat. Similar reasoning could be applied to houseboats to make them
eligible for ad valorem taxation. Proceeds from ad valorem taxes on houseboats could be used to fund education
efforts aimed at explaining the impacts of sewage disposal on the marine environment, as well as increased
enforcement and provision of pump-out facilities.
3.2.3.11 SALES TAX SURTAXES.
General sales taxes provide substantial revenue that is allocated via various appropriation and revenue sharing
programs. These revenues do not always provide for the complete financing needs of a community, and in some
cases governments may authorize additional sales taxes to meet specific needs. Such is the case in Florida, where,
in addition to genera] sales taxes, the state of Florida allows certain "discretionary sales surtaxes" to be levied.
Florida allows several tax surcharges; however, the most applicable to addressing water quality improvement needs
is the Local Option Infrastructure Tax. Any county or local government may assess, for a period of up to 15 years,
a 1/2% or 1 % Local Option Infrastructure Tax. The tax may only be assessed on sales of value up to a $5,000 cap
amount, and must be voter approved by referendum. Once adopted, the tax is added to sales tax rates, and the
revenue is collected by the state and returned to the counties for use to finance, plan, construct, or improve capital
infrastructure. A Monroe County referendum to levy the infrastructure tax was defeated in 1987, but voters passed
a 1 % tax in 1989 with a collection period of 15 years. The estimated income from this tax for 1991-92 is
approximately $7.8 million (ACIR 1991a). Additionally, revenues for Key Colony, Key West, and Layton are
estimated to be approximately $111,000, S2.8 million, and $20,800, respectively (ACIR 1991a). This tax provides
substantial revenue that could be used by Monroe County and its cities to finance infrastructure improvements such
as wastewater treatment, stonnwater treatment, and other activities related to water quality.
3.2.4 Impacts
Taxes, whether assessed on income, personal property, or sales of goods and services, can provide a significant
source of revenue for water quality improvement projects. Because property taxes in Florida are levied at the
county and local level, a larger portion of the revenue from these taxes tends to stay in the local community for use
in local projects. Unfortunately, both personal income and property taxes tend to be allocated to general revenue
funds from which monies must be appropriated for specific programs. There is no guarantee that funds allocated
one year will be available in subsequent years, making it difficult to finance long-term, ongoing projects with these
taxes. Sales and use taxes can be more easily tied to specific programs, as has been done in Florida through the
use of Trust Funds. These taxes can also be used to discourage the use of, or mitigate the impacts from, goods and
services that have an adverse effect on the environment.
The major disadvantage to taxes are their unpopularity and the often unequal impact that they have on various
segments of the population. Generally, taxes require voter approval in order for implementation. Florida has full
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disclosure laws requiring that notice and opportunity for comment be given on any proposed property tax increase.
The need to gain public acceptance can often be a costly process. Property taxes have been criticized as taxing
unrealized capital gains resulting from increases in property values. This has been shown to have a potentially
significant impact on property owners of fixed or limited income. Sales and use taxes have been criticized.as being
regressive because all goods and services are taxed at the same rate regardless of the purchaser's ability to pay.
In addition, while a few sales and use taxes can have a relatively small impact, in combination they can create a
significant burden. Implementation of numerous taxes ran also create additional administrative burdens and costs.-
Whether a tax is equitable depends both on the item on which the tax is assess?*! (i.e., property, goods, and
services) and the way the tax is implemented. Most of the sales and use taxes identified in this section have been
considered equitable taxes for the purposes of water quality enhancement and environmental protection on the basis
that the goods and services on which the taxes are levied contribute to water quality and environmental impacts.
Thus, these taxes are merely an application of the "polluter pays" principle to individual uses.
Property taxes used to provide public services have also been defended on the basis that the services provided, such
as wastewater treatment, directly benefit the population being taxed. In general, however, most observers do not
consider property taxes to be equitable because of differences in the way the tax can be assessed from one area to
another, and the fact that the taxes do not take into account individual taxpayer resources (ACIR 1991c).
3.3 GRANTS AND LOANS
Development of the Water Quality Protection Program for the FKNMS program is a unique cooperative arrangement
between the federal government and the state of Florida. This section identifies existing sources of state and federal
funds available for financing water quality protection and restoration activities. Additional funding may be made
available through cooperative agreements between the state and the federal government to provide additional funds
for improving the water quality in the FKNMS. Additional information on existing funding sources is available in
the Guide to Federal Domestic Assistance published by the U.S. Office of Management and Budget (OMB 1991).
3.3.1 Federal
3.3.1.1 ENVIRONMENTAL PROTECTION AGENCY
EPA plays a lead role in identifying, evaluating, and controlling environmental pollutants. EPA has played a major
role in research and monitoring activities in estuaries around the country. In FY 1989, the Chesapeake Bay program
received $825,000 to fund nonpoint pollution research and monitoring activities. EPA also provided almost $10
million for development of comprehensive management plans for the ten designated national estuaries (DOC 1991).
An estimated $625,000 is being provided for the development of the Water Quality Protection Plan for the FKNMS.
Until recently, the EPA was a major supplier of grants for construction of wastewater treatment works under the
CWA. These grants are no longer available and have been replaced in many states by State Revolving Loan Funds
that are seeded by EPA and managed by the states. Under Title VI of the CWA, EPA is authorized to make
capitalization grants to the states for deposit in State Revolving Loan Funds. From these funds, states can provide
loans and other financial assistance (but not graqts) to communities and intermunicipal and interstate agencies for
the construction of publicly-ovned wastewater treatment works, for implementation of nonpoint source pollution
control management programs, and for development and implementation of an estuary conservation and management
plan (Mr. Steve Felerman, Bureau of Local Government Wastewater Financial Assistance, personal communication).
The state must prepare an annual plan identifying the intended use of the State Revolving Loan Fund and describing
how the funds will be used alone or in combination with other state financial assistance programs. The plan must
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also indicate how the Fund will assist communities in attaining' and maintaining compliance with the CWA and
carrying out other provisions of the state clean water strategy! Both short and long-term goals must be included in
the plan.
In Florida, revenues from the State Revolving Loan Fund can only be used for construction of wastewater treatment
works. The Bureau of Local Government Wastewater Financial Assistance (BLGFA) of the FDER administers the
fund, which is recapitalized by the repayment of the loans and interest. Allocation of loans is on a competitive
basis, with priority given to projects having the greatest impact on human health. Environmental impacts that are
not also presenting an impact to human health are not currently viewed as a priority (G. Swaggert, BLGFA,
personal communication, 1992). The allowable uses of the fund are fairly liberal, and use of the fund for
construction or retrofit of OSDSs by a septic utility (see Wastewater Treatment, Section 4.2.1) or local government
may be possible.
For 1993, nine loans have been approved. Three of these are for $10 million (the maximum amount allowable) with
the remainder falling in the $2 million range. Projects may be funded over several years, and some of the projects
funded in 1993 are continuation segments. No one community can have more than 10% of the total Fund amount
for projects within the community, and IS % of the total amount in the Fund is set aside for small community loans.
Under Section 106 of the CWA, the EPA provides grants to states for water pollution control activities. These
grants may be used to finance monitoring and enforcement activities. The FDER is currently using 106 grant funds
for financing the state's existing ambient water quality monitoring program, deferring the costs of compliance
inspections for wastewater treatment facilities and helping to fund the state's data retrieval network.
Under Section 104 of the CWA, EPA provides project grants to the states for unique, pilot or special studies, and/or
demonstrations to advance knowledge and technologies in addressing point source water pollution problems. These
grants do not require state matching funds.
Grants for financing implementation of nonpoint source pollution programs, including development and
implementation of groundwater protection programs, are provided under Section 319 of the CWA. EPA established
initial planning targets for each state for these grants. The actual allocation of the funds is a Auction of the
planning targets and the state's nonpoint pollution program. Approximately 50% of the target funds are for base
programs and the remaining projects are funded from a regional competitive fund. These grants have specific
matching requirements. Nonpoint pollution Section 319 funds cannot exceed 60% of the project cost. Other
federal funds cannot be used to match Section 319 funds. States are encouraged to use at least 10% of the planning
target for groundwater activities.
Section 104(b) of the CWA authorizes EPA to approve grants or cooperative agreements to state water pollution
control agencies, interstate agencies, other public or non-profit private agencies, and individuals for projects related
to improving the environmental conditions of Near Coastal Waters (NCW). NCWs are defined as inland waters
to the head of the tide, territorial seas, and contiguous zone, and include related wetlands and the Great Lakes.
Projects eligible for funding include, but are not limited to, criteria/standards development, waste load allocations,
effluent guideline development. National Pollutant Discharge Elimination System (NPDES) permit development and
enforcement, CWA Section 404 (dredge and fill) permitting, nonpoint source management plans, and wetlands
protection. EPA Region IV funding for the NCW program was $642,500 in FY 91, and $464,686 in FY 92
(F. McManus, EPA Region IV, personal communication, 1992).
Each EPA region receives yearly funds for providing Small Community Outreach and Education (SCORE) Grants
that can be used to fund public education and outreach activities related to water treatment. These grants are
available to local governments, agencies, and organizations and require a 50% match. In many states these grants
have been used to develop videotapes and handbooks on water conservation and other issues. In FY 1990, the
Maine Department of Environmental Protection was awarded a grant to develop a handbook on planning,
constructing, and financing WWTPs (Buzzards Bay Project 1991).
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Under the National Environmental Education Act (NEEA), EPA also awards grants to organizations, institutions,
schools and agencies for environmental education activities. NEEA grants for 199? ve.: nearly $4 billion
nationwide. Hie grants provided by Region IV were for amounts of $25,000 or less.
3 J. 1.2 U.S. DEPARTMENT OF AGRICULTURE
A small portion of the U.S. Department of Agriculture's (USDA) research is oriented toward examining the effects
of agricultural and natural resource practices on the environment. The USDA supports research, monitoring,
development, and education programs related to pollution causes and effects through direct federal research and
through cooperative efforts and grants. These studies are directed primarily toward agriculture and the management
of rural lands. A major portion of the total research effort is through state matching of federal grants (DOC 1991).
The nonpoint source contaminants program conducts research on contamination of groundwater and aquifers from
septic system drain fields, and soil and crop applications of chemicals, sludges, manure, and other wastes. This
program received $2.7 million nationwide in 1989 (DOC 1991).
The Farmer's Home Administration (FHA) of the USDA provides grants and loans to rural communities (less than
10,000 population) for the development of point and nonpoint pollution reduction activities. Low-interest loans and
grants for the installation, repair, improvement, or expansion of rural water facilities and wastewater disposal
systems, including the collection and treatment of sanitary, storm, and solid wastes, may be available through the
Wastewater and Disposal Systems for Rural Communities program. These facilities must primarily serve rural
residents, and grants are available only when necessary to reduce the annual benefitted user charges to a reasonable
level. Funds are available to communities or special improvement .districts, but not to individual residences. The
average size of loans is $490,000, and of grants is $357,000 (OMB 1991).
FHA also provides Industrial Development Grants to finance industrial sites in rural areas including acquisition ot
land, utility extensions, and necessary water supply and waste disposal facilities. Priority for these grants is given
to communities that have a population of less than 25,000.
The USDA administers the Agricultural Conservation Program and the Rural Clean Water Program, which can
provide up to 75% cost-sharing for measures taken on agricultural land to solve problems associated with point and
nonpoint source pollution. To the extent that some water quality issues in the FKNMS are related to stormwater
contaminated with upstream pollutants from agricultural areas in Dade County and other areas using SFWMD
Canals, these programs might be a useful source of revenue.
Additional assistance in the form of funds or expertise is provided by the USDA Soil Conservation Service (SCS).
SCS programs are aimed at protecting, developing and using land and water resources. Funds are available for the
development of flood control projects, erosion control, water quality protection, and resource enhancement. Some
of these funds are provided on a cost-share basis and have specific eligibility requirements.
3.3.1.3 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
The Department of Housing and Urban Development (HUD) provides Community Development Block Grants/
Entitlement Grants (CDBG) to localities with a population of more than 50,000 for a broad range of activities
including improvement or installation of public works. The grantee must certify that at least 60% of the grant
received will principally benefit low- and moderate-income persons. For nonentitlement communities, grants are
available through the CDBG Small Cities Grants Program. The majority of the Small Cities Grants are provided
for housing rehabilitation projects, but these funds can also be used for water and sewer projects (Buzzards Bay
Project 1991).
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Communities eligible for Small Cities Grants an also eligible for Feasibility Study Grants that can be to
identify environmental issues. The maximum amount of the grant is $30,000, and a minimum jo% matrh by the
local government is required (Buzzards Bay Project 1991).
3.3.1.4 NATIONAL PARK SERVICE
Hie National Park Service provides matching grants for planning, acquisition, and development of outdoor
recreation areas and facilities for the general public. Up to 50% of the cost of park facilities or of acquiring land
for protecting natural resources may be provided through this program. In the FKNMS, this program may be able
to be used to enhance public facilities for boaters, including the development of pump-out facilities. This program
may also be used for the purchase and protection of wetlands that may be able to be used for mitigating nonpoint
source pollution from storm water.
3 J. 1.5 U.S. FISH AND WILDLIFE SERVICE
The U.S. Fish and Wildlife Service (FWS) has fluids coastal activities through the National Coastal Wetlands Grants
program. These grants are available to states for remediation, land acquisition, and water control. The level of
state matching is determined by the nature of the project being funded. Grants have ranged from a few thousand
dollars up to $1.2 million. In the Guana River, FL, a restoration project was funded to fill mosquito ditches to allow
re-hydration of 382 acres of interdunal swale.
The FWS also has two other grant programs that may be applicable to the FKNMS. Through regular federal aid
grants, FWS provided $351 million in 1992 for fisheries and wildlife restoration. A formula is used to allocate each
state is a portion of the yearly money. The FWS reviews applications for these state grants and approves their use.
FWS grants are also available under the North American Water Fowl Management Plan. These funds can be used
to improve waterfowl habitat, including coastal wetlands. These grants are available to federal, state, and local
agencies and private groups, such as Ducks Unlimited. Although these are single year grants, applications for
additional funds can be submitted yearly. This allows of use of the grants in multi-phase projects, however, FWS
will not guarantee follow-on funds for succeeding years.
3.3.1.6 U.S. DEPARTMENT OF COMMERCE
The National Oceanic and Atmospheric Administration (NOAA) is responsible for managing designated national
marine sanctuaries. Significant research has been conducted at the Key Largo Marine Sanctuary on modeling
environmental behavior in response to natural and pollution events. Additional research was supported in assessing
the damage to coral from the grounding of the M/V Wellwood in August 1984, and the recovery rate of the coral
since that time.
NOAA also administers two other programs of direct import to marine water quality. These are the Sea Grant
Ocean Pollution Program and the Coastal Zone Management Program. The Sea Grant program awards grants to
academic institutions for research oriented toward fostering wise use of the nation's estuaries and coastal and ocean
resources through directed research and education (DOC 1991). Sea Grant publications are a significant source of
public information on marine and estuarine water quality issues. The Coastal Zone Management program provides
funds to states for coastal zone management activities.
The Public Works Division of the U.S. Department of Commerce (DOC) provides project grants for funding of
public facilities, such as water and sewer systems, to support the development or retention of permanent jobs in the
private sector in areas of lagging economic growth.
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3.3.1.7 U.S. DEPARTMENT OF THE INTERIOR
The Clean Vessel Act of 1992 will require coastal states to ensure that adequate pumpout stations and waste
reception facilities are available for use by recreational boaters. Coastal states will be required to conduct surveys
of existing facilities and develop plans for ensuring that aH^imre facilities are available. The Secretary of the
Interior will oversee the distribution of $5 million in FY93 for up to 75 % of the cost to coastal states for conducting
the surveys, developing and submitting plans, constructing and renovating pumpout stations, and public education
on impacts of vessel waste. Priority for awarding grants will be based on the proposed construction of facilities,
provisions for public/private partnerships to develop and operate the facilities, and proposed innovative methods for
increasing the availability of the facilities. The Act does not apply to commercial vessels.
3.3.2 State
In addition to the State Revolving Loan Fund, the state of Florida also has a Bond/Loan Program. Under this
program, the state issues bonds and turns the money over to the local government for financing improvements. The
local government is responsible for paying off the debt. This program can be used for financing improvements in
wastewater, storm water, solid waste, and hazardous waste treatment. The advantage of the Bond/Loan Program
is that it allows the municipality to receive a lower rate of interest by utilizing the state's credit rating. This
program has not been widely used, in part because of the relatively strong credit rating of most Florida
municipalities, and in part because of the planning requirements the state places on applicants. It is, however, a
potential revenue source for large projects in which an incremental decrease in the interest rate can have a
substantial impact in the total debt, or for a smaller community that lacks the revenue or tax base to issue debt at
a favorable interest rate.
3.3.3 Impacts
Grants have a relatively limited impact on the local population, except to the extent that they require provision of
local revenues in the form of matching funds. The impacts will vary depending on the source of this revenue, i.e.,
bonds, taxes, rates, or fees. A similar situation is true in the case of loans. The State Revolving Loan Fund
requires repayment of the loan over a 30-year period. The local government has a number of options for securing.
funds for repayment, and the type of option chosen will determine the potential impacts.
One of the main disadvantages to using grants for financing water quality improvement programs is that there are
relatively few grants available, and those that are available are strictly limited in the types of activities they will fund
and the populations that qualify. There is significant competition for both the available grants and the State
Revolving Loan Fund. This requires local governments to comprehensively plan their programs in a way that allows
flexibility in implementation.
3.4 RATES
3.4.1 Utility Rates
Consumers of services provided by public or private utilities are charged either a flat rate or unit consumption fees.
Sewage treatment, water delivery, garbage collection, gas, and electricity are all examples of utilities that charge
rates. In some districts a flat rate or "Service Charge" is charged to each consumer connected to a service. In
other instances, consumption is metered and rates are charged on per-unit rate scale. In situations for which the
costs for the service are metered, utility rates can be used to encourage water conservation by increasing the
incremental costs of successive units of consumption over a specified base level. Public and private utilities collect
rate revenue to finance continuing operation (including monitoring), debt management, and profit.
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Ia many instances, users of a specific service are charged a one-time fee for access ng the system. Both wastewater
and stormwater utilities use access charges in order to recover the costs for providing services to new customers.
The SFWMD charges industrial users of its stormwater canals an access fee. Access and connect charges may also
be used to finance debt management or to provide revenue for future capital improvements. For wastewater, access
charges could be based on the number of bathrooms in a residence or building (Apogee Research, Inc., 1991).
These charges could be used to finance construction for increasing capacity of regional treatment plants, or larger
more modem package plants as discussed in the management and engineering options.
In Florida, utilities are self-regulating and are able to establish their own rate schedules. The City of Key Colony
Beach charges a flat rate of $15 per unit (i.e., house) per month for sewage treatment and disposal, and a $3,500
connect fee. The City of Key West charges a flat rate of $17.50 per base consumption unit (2,900 gallons) plus
$3.97 per 1000 gallons. Residential connect charges are $1,000 per residence, and commercial connect charges
are $1,500 plus $1,000 per each 6,000 gallons of average monthly flow. The Florida Keys Aqueduct Authority
(FKAA) charges $5.18 per 1000 gallons on the first 12,000 gallons of water consumption, and $6.18 per 1,000
gallons over 12,000 gallons. These rates are for both residential and commercial water users (M. Goldent, Division
of Water and Wastes Rate Section, Public Service Commission, personal communication, 1992).
There are three private sewage treatment facilities in the Keys. These are: KW Resorts Utilities, Inc., Key Haven
Utilities, and Ocean Reef Utilities. These facilities are regulated by the state and charge flat rates of $29.09 per
month, $33.16 per month, and $26.51 per month respectively.
3.4.1.1 CAPACITY FUTURES
One option for financing construction of wastewater treatment facilities is through the sale of capacity futures.
Under this program, residential and industrial users, and developers agree to pay the charges associated with
connecting to the facility in advance of the facility's construction. These connect charges, which can be discounted
from the rate that would be charged to users after the facility is constructed, are used to provide some of the capital
for construction. This approach was used to finance wastewater treatment facilities in Escondido, California, and
Houston, Texas (EPA 1990a). This method has worked especially well in areas with high levels of development
where developers can secure their rights to a specified level of treatment capacity. It is likely that this approach
could also be used in constructing wastewater treatment facilities to replace on-site septic systems in portions of
Monroe County.
3.4.2 On-site Sewage Disposal Systems
Once permitted in Florida, OSDSs and package plants are not required to pay any taxes or fees associated with their
impacts on the environment. Routine maintenance and inspection are left to the individual landowner. These
systems generally escape the oversight required of wastewater treatment utilities. In response to the impacts
associated with OSDSs, some local governments are looking at ways of increasing management and oversight of
these systems. In Washington state, septic tank users in two counties are required to pay a septic tank use fee. The
proceeds of this fee are used to cover the costs of interceptor sewers (EPA 1990a). Development of a septic utility
or special district may also provide a mechanism for monitoring the impacts of these systems (see Section 4.2.1.1).
This utility would charge rates for monitoring and inspection activities similar to a wastewater utility.
3.4.3 Impacts
Rates are generally considered an equitable form of finance because they charge the population using a utility or
other service for the services provided. Rates that go beyond the immediate costs of providing the service are also
equitable to the point that the activities for which the revenue is spent still primarily benefit those who are paying.
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3.5 FEES
Fees are a direct method of matching the costs for program activities with the population most likely to benefit from
the action, or the population with the greatest responsibility for the problem the program is designed to address.
To make a fee system work, it is necessary to identify, as accurately as possible, the costs of the project and the
portion of that cost that should be carried by the individuals involved. If this is done, impact and user fees can be
a significant source of revenue for financing improvement projects, as well as providing an impetus for pollution
reduction and wise resource use.
Because fees may be assessed without requiring the consent of the community affected, they have been criticized
as a way around the constraints imposed on taxes. In addition, it is possible to assess a fee on so many activities
that, even though the incremental effect of the fee is slight, the cumulative effect of all of the fees becomes a burden
to the public. Care must be taken to ensure that the cumulative effect of impact and user fees is not excessive.
3.5.1 User Fees
As the name implies, a user fee is charged to those members of the population that partake in an activity or will
gain the most benefit from the proposed project. Such fees may be charged on a myriad of items ranging from use
of parks and public facilities to monitoring and maintenance fees for utilities. Because they are generally collected
for ongoing activities, user fees can provide a long-term source of financing for developing and maintaining projects.
3.5.1.1 MOORAGE FEES AND PRIVILEGE FEES
Moorage Fees and Privilege Fees are two types of user fees that may be applicable in the FKNMS. Moorage fees
have been used in other parts of the country to cover the costs associated with public provision of services related
to recreational boating. This has included sanitary waste and garbage service, as well as docks, boat launches, and
other types of public access to harbors. Moorage fees are currently charged by individual marinas. An additional
flat-rate surcharge could be assessed on these fees to provide revenue to the local government for boat-related
activities.
Privilege Fees have been used in several communities in Massachusetts (EPA 1990a) to offset the costs of providing
specific pnvileges such as access to beaches or shellfish beds. Revenue from access fees can be used to provide
beach maintenance and protection, as well as increased litter collection. The town of Narragansett places its fees
in an enterprise fund that is used to finance beach maintenance and operation, repay a bond issue, and provide
additional revenue for the town (EPA 1990a). Rhode Island and Delaware charge access fees to both residents and
nonresidents, but the rates for nonresidents are often twice as high. This type of fee is limited in its application
because of the requirement for a close connection between the costs associated with providing these activities and
the amount of the fee. In addition, while this type of fee is often popular with local communities, it is generally
unpopular with the tourists who make up a large portion of the Florida Keys revenue base.
A way to increase the popularity of privilege fees is to charge a single rate for access to an area or activity, but to
provide the option of purchasing seasonal passes. Both residents and long-term tourists will benefit by paying lower
prices over time, and short-term visitors will tend to feel less discriminated against.
One of the options for reducing the impact to coral communities is the designation of specific mooring fields.
Requiring boaters to purchase a sticker giving them permission to use these fields could provide revenue for
maintenance and enforcement. This is more comprehensive than the aquatic lands lease tax, which only charges
marinas and other lessees of public submerged lands. Rhode Island is currently investigating the use of a similar
fee for the use of submerged lands including, long-term storage of boats and other vessels and discharge of
pollutants (EPA 1990a).
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3.5.1.2 DISCHARGE AND RUN-OFF FEES
Many local governments use a system of discharge fees and permits to partially finance wastewater and stormwater
management activities. In addition to being required to obtain a permit for discharge, users of wastewater and
stormwater systems are also charged a discharge fee, based either on the amount of impervious land surface or on
a per-unit basis.
In Florida, requirements to obtain a SFWMD permit for activities that will impact stormwater runoff are limited
to properties tea acres or larger with two or more acres of impervious surface. One of the water quality
improvement management options recommends removing this limitation and requiring all activities to receive a
permit. An additional option is to charge a monthly stormwater discharge or runoff fee. Collections of the fees
could be managed either by the SFWMD or through the development of a stonswater utility (see Section 4.2.2).
If they are charged to both residential and commercial landowners, runoff fees can be an equitable method for
paying for stormwater collection, treatment, or disposal.
In other parts of the country, residential areas have not escaped the imposition of discharge fees. These fees are
charged on a unit basis and are designed to offset the impacts of structures, such as roads and driveways, that
contribute to nonpoint pollution in stormwater runoff. Because residential infrastructure is publicly owned, it has
been difficult to assess costs associated with nonpoint pollution from road runoff and residential storm drains.
Dividing this cost across all residential property owners can provide funds to be used for stormwater treatment and
nonpoint pollution abatement, as well as public education and outreach activities designed to heighten awareness of
water quality issues associated with residential activities.
For both residential and commercial users served by a wastewater utility, wastewater discharge fees are generally
incorporated into utility rates. In situations for which there is no utility, as with the on-site septic systems and
package plants in the Keys, a wastewater discharge fee could be assessed to pay for impacts associated with these
activities. Essentially, the fee pays for the privilege of discharging to surface or groundwaters. (Discharge to
boreholes or deep wells could also be assessed a fee based on the eventual impact to groundwater from the
discharge.) The fee could be based on either a flat rate per residence or tied to water consumption.
When discharge fees are tied to overall - iter consumption on a graduated scale, where an incrementally higher rate
is charged on consumption over a certain base amount, discharge fees can serve as an incentive for water
conservation. This type of fee system has encouraged industries to pursue "zero discharge" systems (EPA 1990a).
Certain types of industries can realize significant cost savings in both water use and discharge fees by using low-
or no-discharge technologies. Funds generated by discharge fees may be used to provide guidance to industry on
the types of zero discharge technologies available.
3.5.1.3 INSPECTION FEES
At present, the SFWMD requires industries to treat their stormwater prior to discharging it into the canals. Many
wastewater treatment facilities also require on-site pretreatment of wastewater prior to discharge by the industry into
the system. In situations for which the regulatory agency lacks sufficient staff with expertise to perform on-site
inspection of pretreatment activities, local governments have contracted with private engineering firms to provide
on-site inspections and testing. A combination of permit and inspection fees are used to fund this type of program
(EPA 1990a).
This type of inspection fee could also be used for requiring routine inspections of OSDSs and package plants to
ensure that they are being properly maintained." The Stinson Beach, California, septic utility requires homeowners
to have their systems inspected semiannually and charges residents for this service (PSWQA 1991).
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3.5.2 Tolls
Tolls i~. a type of user fee in that they are charged for the use of a bridge or road. They have frequently been used
to collect revenue for road improvements and bridge construction. In the area of water quality, tolls are somewhat
different from user fees in that the revenue collected can be used to pay for projects, such as stormwater treatment
and control, that do not directly benefit the road users but do seek to mitigate the impacts of the road's existence.
3.5 J Impact Fees
Impact fees are similar to user fees; however, they are oriented toward requiring a section of the population to pay
for the impacts associated with their activities. Development and other activities often create direct impacts to the
local infrastructure and environment. An impact fee is charged to a developer or other party to offset these impacts.
Impact fees can be one-time charges for an activity or can be charged on an on-going basis. One-time impact fees
are generally not a reliable source of revenue because the amount of revenue generated is dependent upon several
economic factors including the level of growth and development in an area. Impact fees charged for mitigating the
effects of a continuing activity, such as automobile use, could be charged on a yearly basis and therefore become
a much more reliable source of income. Impact fees may also be used as a irปซnซ to discourage specific activities
that have an impact on water quality or the environment, or to provide some level of mitigation for the impacts.
3.5J.1 DEVELOPMENT FEES
Impact fees on development are generally designed to offset the impacts of that development on utilities, police and
fire protection forces, transportation, and recreation. A number of impact fees are charged by various counties and
municipalities in Florida. Both Dade and Monroe counties charge impact fees for police, transportation, and parks.
They do not currently require impact fees for water and sewer systems. Impact fees have been criticized by
developers on the basis that developers are being required to pay for services that were provided to the original
residents for free.
Impact fees associated with increased stormwater runoff have been assessed in other areas of the country (EPA
1990a). The SFWMD requires developers to obtain a one-time permit for construction on sites larger than ten acres
and containing two or more acres of impervious surface. The cost of these permits generally covers only the
administrative costs of permit issuance. In addition to the permitting requirements, developers could also be
required to pay a one-time impact fee based on the effects that their development would have on current water
management systems. Funds generated by this fee could be used to upgrade stormwater management systems or
help finance stormwater treatment.
Not all development impact fees are necessarily monetary, because one of the goals of an impact fee can be to
discourage specific activities. In East Greenwich, Rhode Island, a recreational impact fee is charged on new
development to provide public lands for recreation. This fee is generally a land set-aside of one acre for every 20
housing units (EPA 1990a). Monetary payment may be accepted in some circumstances.
3.5.3.2 USE IMPACT FEES
Impact fees do not have to be associated with a new activity, such as development. Impact fees have also been
charged to users of equipment, such as cars, that create a impact to the environment. This type of fee is similar
to a motor vehicle licensing tax. One advantage of the fee over the tax is that a fee charged for the incremental
contribution of personal autos to increased pollution in stormwater runoff would be tied directly to a specific water
quality improvement activity (such as treating the stormwater). while a portion of the tax would need to be allocated
to the general fund. Florida currently charges new residents a New Cars on the Road fee for the first time a vehicle
is registered in the state. Several states have car impact fees associated with automotive contributions to air
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pollution. For example, under Washington State's Clean Air Act, a clean air excise tax is imposed for the privilege
of using a motor vehicle. The annual amount of the tax is $2.25. [RCW (70.94.011) 1990],
Boats are another category of good that has an impact on water quality in the Keys. An impact fee on boats could
be established as a yearly charge on the sale of a moorage or boat activity sticker allowing boats to use Florida
waters. It would be charged to both resident and transient boaters. Boats designated as live-aboards would pay a
higher fee than non-live-aboards. The proceeds from this fee could be used to fund public education on the impacts
of boat-related marine pollution on water quality, monitoring and study of water quality in marinas, and water
quality improvement programs.
Impact fees can also be assessed for ongoing activities that affect surface and groundwater. Thus, an impact fee
could be assumed against an OSDS user, or package plants, that discharge their effluent to boreholes for the impacts
that their activities have on the FKNMS. The revenue generated from these fees could be allocated to phasing out
underground injection and connecting these systems to a subregional treatment facility.
3.5.4 Fines and Penalties
Fines and penalties are assessed for violations of regulations, or late payment of outstanding debt. While the
assessment of fines and penalties may result in a significant amount of revenue, it cannot be counted upon to
generate a specific level of revenue that can be directed toward a specific project or water quality option. Fines
and penalties should not be considered viable mechanisms for "funding" water quality activities; they should instead
be viewed as a type of windfall profit that can be used to enhance proceeds from traditional funding sources.' For
this reason, they are not further discussed as potential revenue generating mechanisms in this report.
3.5.5 Impacts
Fees are a direct method for tying the costs of an activity or impact to either the population receiving the benefits
of the program, or the population creating the impact. Several courts have determined that impact fees must be
established in such a way that creates a nexus between the activity causing the impact and the fee. Because of this,
the revenue generated by the fees should be spent on activities or programs related to the impact. Depending on
the type of fee, this funding mechanism can provide a source of continuing revenue for financing water quality
improvement activities. In addition, fees have been used to encourage resource conservation and behavioral
changes. This is especially true for situations in which the fees are tied to some type of public education that
informs the public of the impacts that a specific activity or product has on the environment.
As with taxes, fees can become burdensome in a number of ways. In many cases, activities on which a specific
tax could be levied may also be a good candidate for use of a fee. Because fees generally, do not require public
approval, and taxes generally do, fees have been criticized as a way of getting around the requirements imposed
by taxes to provide an unwelcome or unpopular additional cost. Developers have criticized development impact
fees as being an unfair burden on new development, and charging development for services that were provided to
the original residents or tenants for free (ACIR 1991b). Whether to charge a fee or a tax, or both, will depend on
the goals of the program and the sensitivities of the local population.
The equitability of fees depends on the activities for which the fee is charged. Unlike a tax, fees do not necessarily
have to charge all users of a good or service the same rate. Certain fees may charge different rates for residents
and nonresidents, but may still be equitable to the extent that the nonresidents increase the need for specific services
that would otherwise not be required or would be required in smaller quantities. An example of this is garbage
collection because the amount of garbage tends to increase during seasonal tourist periods when there is a larger
population. To the extent that fees are attached to activities or products that have a measurable impact on water
quality and the environment, they have been viewed as an equitable application of the "polluter pays" principle.
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Budget: The amount of revenue currently being generated by ail relevant sources of funding should be identified
and calculated. This will include state revenue, local revenue, and special program monies, such as sales and use
taxes, rates, and fees already allocated to water quality programs. Available sources may also include funding
mechanisms that are not currently being used but that are specifically available for the types of projects being
implemented. An example of this type of revenue is the State Revolving Loan Fund, which provides funds for
specific projects in wastewater management. As part of the budget assessment, a review of the current level of
taxation in the state or area where the project is to be implemented, anH an assessment of the state of the economy
should also be performed in order to develop a comprehensive picture of areas where additional revenue may be
obtained.
Budget Shortfall: This is essentially a calculation to determine the difference between the available budget and the
costs of the project or program. This information, and an estimation of the requirements for short-term financing,
will be used to determine the funding needs.
Funding Mechanisms: With the above information in place, it should be possible to select the suite of funding
options most appropriate for the project or program being implemented. Knowledge of the fiscal health of the local
economy and the ability to use specific funding sources will be helpful in choosing between similar funding
mechanisms. Once the funding mechanisms are selected, changes may need to be made to the estimation of the
project costs and the overall funding needs.
4.2 APPROACHES TO FINANCE
Florida has a number of agencies responsible for water quality and environmental management in the Florida Kiys.
Task 3 identified a wide range of options for addressing water quality issues in the Keys. The agencies and
institutions that will be involved in implementing these options are diverse in terms of capabilities and res0ur7.es.
Many of the funding mechanisms discussed in this report could be used to address a number of different
management and engineering options, and it will be the task of the agencies and institutions involved to determine
which options are more appropriate for them. This section presents some examples of implementation strafe, ^ies
for wastewater and stormwater management that have been used in estuary programs across the country to address
similar issues. These examples are provided for illustration purposes only and are not meant to represent the jniy
combination of funding options available for addressing wastewater and stormwater management. When applicable,
a discussion of how these strategies could be used in Florida is provided.
4.2.1 Wastewater Treatment
As discussed in Task 3, Monroe County has a large number of OSDSs and "package plants" that are impacting on
water quality in the FKNMS. Although permits are required for their installation, these OSDSs are relatively free
from regulation once they are installed. In addition, many OSDS owners have not been required to upgrade their
systems to bring them into compliance with current regulations. In effect, this gives OSDS users an advantage over
households connected to sewage treatment systems because the OSDS users are not required to pay rates reflecting
the impacts of their OSDS on the environment. Because the majority of these OSDSs are found in the
unincorporated areas of Monroe County, they do not readily fit into existing management structures for wastewater
management.
Several options for converting OSDSs and package plants to larger wastewater treatment facilities have been
identified in Task 4. Construction of these systems is likely to be costly both in terms of construction and rates to
finance the debt incurred. A primary source of funding for construction of wastewater facilities is the use of bonds
that are paid off through tax or rate revenue. Another option is use of the State Revolving Loan Fund. In addition
to these primary sources of revenue, a utility approach to OSDS management could be used both for building the
capital required for construction of wastewater management facilities and to finance monitoring and regulation of
OSDSs until such time as the wastewater facilities can be built, or in lieu of building larger facilities.
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4.2.1.1 COMPREHENSIVE ON-SITE SEWAGE DISPOSAL SYSTEM MANAGEMENT PROGRAM
Use of OSDSs has certain legal constraints that differ from state to state. This section presents some of these issues,
but specific information on the area in which such a program would be implemented would be necessary prior to
implementation.
In Florida, FDHRS is responsible for overseeing construction, installation, and operation of domestic sewage
systems of less than 5,000 gallons per day. Current law limits FDHRS to restricting use of OSDSs only for public
health reasons. There is currently no system for continuing management of these OSDSs once they have been
installed. In addition to lacking jurisdiction for requiring repair or replacement of OSDSs that do not pose a threat
to public health but are having adverse environmental impacts, FDHRS also lacks the resources for inspection and
enforcement of the estimated 25,000 septic systems (EPA 1992) in the Florida Keys.
Stinson Beach, California: One option for providing funding for OSDS management is through a comprehensive
management program. An example of such a program is the Stinson Beach County Water District administration
of an OSDS maintenance program. Start-up costs for this program were funded through the use of EPA
Construction Grants using money originally targeted for construction of a wastewater treatment facility. Operation
and maintenance is financed through fees and property taxes. A comprehensive OSDS management program was
developed because a number of OSDSs were failing and county residents defeated a proposal to construct a
wastewater treatment facility.
The major functions of the utility are conducting mandatory inspections of all OSDSs every 2 years, issuing of
discharge permits for all OSDSs, ordering remediation of failing OSDSs, monitoring surface and ground waters
(surface waters are tested bimonthly for nitrates, nitrites, ammonia, and fecal coliform bacteria; groundwater is
tested quarterly for bacteria), and permitting of new construction including review of plan designs. The District
has the authority to require that failing OSDSs be replaced, and has the authority to turn off the customer's water
if remedial actions are not taken within a specified time period.
Operation and maintenance costs are covered through a combination of fees and property taxes. All households are
required to purchase a yearly discharge permit at a rate of $155 per year. The proceeds from the permit make up
approximately 60% of the operation and maintenance budget. The District also receives funds from county property
taxes. Additional revenue sources include monitoring and inspection fees, new connection fees, and variance
application fees. Fees are also collected for design review and permitting of new construction to ensure that
development does not reverse progress made in septic system management. The District has the right to deny water
service to proposed development that does not meet standards for on-site disposal (PSWQA 1991).
Potential Application in Monroe County, Florida: Under Florida Statute 153, counties are given the authority
to establish water and sewage districts in unincorporated areas of the county (Florida Statutes 153). The FKAA
currently provides water to the Florida Keys and has authority to provide wastewater treatment to all areas within
its defined service area. Whether through creation of a new utility, or by using the existing structure provided by
the FKAA, OSDSs in the Florida Keys could be managed under a program similar to the one being used in Stinson
Beach. The use of a utility or management program can decrease the administrative costs associated with funding
and provide a structure for the administration of funds and collection of fees.
One of the major tasks of a utility or management program would be the repair and replacement of failing or
noncomplying OSDSs. Individual homeowners are generally responsible for maintaining and upgrading their
OSDSs. If a utility or management program is authorized to enforce compliance with required modification or
replacement via some mechanism such as suspension of water service or eviction (for health-related problems), this
may place a significant burden on the individual property owner for the costs of repair. The utility or management
program may be able to take on some of this cost through issuance of bonds or provision of low-interest loans.
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According to information from the BLGFA, the State Revolving Loan Fund (Section 3.3.1.1) could possibly be used
to finance capital costs of upgrading these OSDSs. In addition, the county could issue bonds (Section 3.1) that
could serve as the basis for low-interest loans to homeowners to pay for upgrades, or the county could undertake
the repairs and pay back the bonds through special assessments (Section 3.7) on the homeowners. There are some
legal limitations on making repairs on private property. One way to get around these constraints may be through
some sort of contractual arrangement between the county, utility, or management program and the property owner
to deed the OSDS to the management agency until the costs of the repair or replacement has been paid off through
special assessments or direct payment (PSWQA 1991). Similarly, repairs could be financed through rates, discharge
permits, connect fees, and other charges. The BLGFA has suggested the creation of a septic utility that would use
revenue from such charges to accrue the necessary capital for construction of a wastewater treatment facility. One
of the drawbacks to using rates and charges for financing repairs and upgrades is that the number of repairs would
be limited by available funds, thereby limiting the number of OSDSs that could be repaired in any one year.
The other major function of a septic utility or management program would be environmental monitoring and OSDS
inspection. These could be made up through the use of rates, charges, and fees. The types of rates and fees
discussed in this report that may be applicable include utility rates (Section 3.4.1), discharge fees (Section 3.S. 1.2),
inspection fees (Section 3.5.1.3), development fees (Section 3.5.3.1), and use impact fees (Section 3.5.3.2).
Additional funding available for both OSDS repair, wastewater treatment facility construction, or operations and
maintenance of the utility or management program could be provided through impact taxes (Section 3.2.3.9) and
property taxes (Section 3.2.3.10). Depending on the size of the area that is contained in the utility or management
program, the community may be able to qualify for USDA grants or loans for rural community pollution programs
(Section 3.3.1.2). Potential combination of funding sources for a comprehensive OSDS is illustrated in Table 5-2.
4.2.2 Storm water Treatment
Storm water management in the Keys is under the purview of the SFWMD, which issues permits for construction
that may affect stormwater and charges access fees for industry use of its canals. Development on properties under
10 acres in size or with less than 2 acres of impervious surface are exempt from SFWMD permit requirements,
although they may still be required to obtain a permit from the local government. In addition, existing surface water
management systems in the Keys are not required to be retrofitted to meet current water quality standards.
Industrial users are required to treat their stormwater prior to its release into the canals. In the primarily residential
areas of the Keys, the majority of development projects received either a general permit or are exempt from the
permitting process. The stormwater runoff from these areas is not required to be treated.
4.2.2.1 STORMWATER UTILITY
A funding alternative for management of stormwater is the creation of a stormwater utility. The SFWMD has the
authority to create and manage stormwater utilities in the Florida Keys. In addition to construction and maintenance
of canals and ditches, the activities of the stormwater utility will depend on the local stormwater management plans.
At a minimum, they should include monitoring, treatment, discharge, and public education. Potentially applicable
funding options for a stormwater utility are illustrated in Table 5-3.
Capital construction of new canals, ditches, or stormwater collection and treatment facilities could be financed
through bonds (Section 3.1) or special assessments (Section 3.7). The SFWMD has the authority to levy special
assessments on property owners and to create stormwater management benefit areas. The properties within these
benefit areas may be assessed per acre fees (F.S. 403.0893). Additional funding may be available from federal
grants for the prevention or limitation of nonpoint pollution (Section 3.3). Additional capital could be derived from
impact taxes (Section 3.2.3.9) or development impact fees (Section 3.5.3.1).
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Table 5-2. Potential combination of funding sources for a comprehensive on-site sewage disposal system.
State Bonds Special	Utility Discharge Inspection Pmfapuunt Um Impact Impact hupalji Other
R evolving	Assessment! Ratca Fco	Fees	Fees	Fm Tun Taxes Grant* and
Loan Fund	Leant
Repair and Replacement of OSDS	• • • •	•	•
Operations and Maintenance	*	*
Environmental Monitoring	•
On-iile Inspection	• • •	•	•
Building Capital for CoMUuctkm of	• ••••••
Wastewater Treatment Facility.
Table 5-3. Potential combination of funding sources for a storm water utility.
Special Utility Discharge Access Fees Derdopaeot Inspection Impact Impact Sales and Piopei ty Other Grant*
Assessments Rates Fees	Fees	Fees Fees Taxes the Taxes Taxes and Loans
New Canals and Ditches
Construction of Collection
and Treatment Facilities
Operations and Maintenance
On-iile Inspection (Industrial
Facilities)
Public Education/Ouucach
Household Hazardous Waste
Programs
Environmental Monitoring

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Operations and mainterance funds could be provided through a combination of rates and fees. For residential and
agricultural areas, most stormwater utilities charge a flat rate based on the surface area of the lot. Commercial
areas are generally handled in a manner similar to SFWMD permit regulations: by examining the amount of
impervious surface area. In Snohomish County, Washington, single-family residential property pays a flat rate of
$22 per year, farms pay a flat rate of $88 per year, and commercial properties are charged on a sliding scale from
$7 to $66 per quiarter acre per year (PSWQA 1991). New developments, both residential and commercial, could
be charged a one-time access rate for use of the stormwater system (Section 3.4.1).
Monitoring, public education, and a portion of activities such as household hazardous waste collection programs
(to prevent household chemicals such as paints and solvents from being disposed of in storm drains) could be
financed through various fees. These would include inspection fees (Section 3.5.1.3) for industrial facilities required
to treat their own stormwater prior to discharging it into SFWMD and development fees (Section 3.5.3.1).
A portion of the funding for stormwater management could also be derived from impact fees or taxes on
automobiles, pesticides, fertilizers, and other activities or products that have the potential to increase stormwater
pollutant loads.
5.0 CONCLUSIONS
This paper has presented a wide range of funding options that could be used for financing any necessary institutional
or structural corrective actions in the FKNMS. Because there is significant overlap between different funding
mechanisms, it is not envisioned that all of these options will be implemented. The agencies and institutions tasked
with implementing the corrective actions will need to determine which options best fit their requirements,
capabilities, and the financial climate of the economy in which they will be used.
6.0 REFERENCES
ACIR. 1991a. Local Government Financial Handbook. Florida Advisory Council on Intergovernmental Relations,
Tallahassee, FL. July 1991.
ACIR. 1991b. 1991 Florida Impact Fee Report. Florida Advisory Council on Intergovernmental Relations.
Tallahassee, FL. September 1991.
ACIR. 1991c. Ad Valorem Taxes: Public Reaction <ฃ Policy Response. Florida Advisory Council on
Intergovernmental Relations, Tallahassee FL. November 1991.
ACIR. 1991d. The Private'Activity Bond Allocation Program in Florida. Florida Advisory Council on
Intergovernmental Relations, Tallahassee, FL. December 1991.
ACIR. 1992. Special Assessments; Current Status in Law and Application. Florida Advisory Council on
Intergovernmental Relations, Tallahassee, FL.
Apogee Research, Inc. 1991. An Inventory of Financing Options for the Albemarle-Pamlico Sound. Apogee
Research, Inc., Bethesda, MD.
Barzel, D. 1988. "Financing Programs For Local Government Agencies; A Regional Approach," Government
Finance Review. V.4, No. 4.
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BEBR. 1991. Florida Statistical Abstract. Bureau of Economics, Business, and Research. University Press,
Jamesville, FL.
Buzzards Bay Project. 1991. Funding Sources for the Buzzards Bay Project Comprehensive Conservation and
Management Plan. Buzzards Bay Project, RI.
DOC. 1991. Summary of Federal Programs and Projects. U.S. Dept. of Commerce, National Ocean Pollution
Program, Washington, DC.
EPA. 1990a. Inventory of Funding Sources for Cleanup and Maintenance of the Narragansett Bay. Environmental
Protection Agency, Washington DC.
EPA. 1990b. Paying for Progress: Perspectives on Financing Environmental Protection. Environmental Protection
Agency, Washington DC.
EPA. 1990c. Public Private Partnerships for Environmental Facilities. Environmental Protection Agency,
Washington DC.
EPA. 1992. Water Quality Protection Program for the Florida Keys National Marine Sanctuary: Phase / Report.
Environmental Protection Agency Region IV, Atlanta, GA.
Florida Statutes 153.
FFCC. 1991a. Florida Tax Handbook. Florida Senate; Finance, Taxation, and Claims Committee, Tallahassee,
FL.
FTCC. 1991b. Florida Tax Sources—Fiscal Impact of Potential Changes, 1992-93. Florida Senate; Finance,
Taxation, and Claims Committee, Tallahassee, FL, December 1991.
Holcombe, R.G. 1991. "Privatization of Municipal Wastewater Treatment." Public Budgeting A. Finance. V. 11,
No. 3.
MacManus, S.A. 1991. "Financing Florida's Governments." Government and Politics in Florida. Robert J.
Huckshome, (Ed.) Univ. of Florida Press, Gainsville, FL.
Olson, S. 1992. Foundation Directory, 1992 Edition. The Foundation Center, New York, NY.
OMB. 1991. 1991 Catalog of Domestic Federal Assistance. Executive Office of the President, Office of
Management and Budget, Washington, DC.
PSFC. 1989. Funding the Cleanup and Protection of Puget Sound. Puget Sound Finance Committee, Seattle,
WA.
PSWQA. 1991. Draft Local Government Water Quality Finance Guidebook. Puget Sound Water Quality Authority,
Seattle, WA.
RCW. 1990. Revised Code of Washington 70.94.011.
Roefam, H.A., J.F. Castelano, and A.K. David. 1989. "Contracting Services to the Private Sector; A Survey of
Management Practices." Government Finance Review. V.5, No. 1.
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TASK 6 - WATER-QUALITY MONITORING PROGRAM
CONTENTS
Acronyms		 vi
1.0 INTRODUCTION	 6-1
2.0 OBJECTIVES	 6-1
3.0 BACKGROUND	 6-2
4.0 COMPONENTS	6-3
4.1	STATUS AND TRENDS MONITORING 	 6-3
4.1.1	Water Quality 	 6-3
4.1.2	Biological Resources 	 6-3
4.2	REMEDIAL ACTION MONITORING	 6-4
5.0 GENERAL DESIGN CONSIDERATIONS		6-4
5.1	HYPOTHESES		6-4
5.2	PROGRAM STRUCTURE AND EVALUATION 			6-5
5.3	STRATIFICATION		6-6
5.4	SAMPLING DESIGNS		6-6
5.5	EXISTING STUDY LOCATIONS		6-7
5.6	REMOTE SENSING 		6-7
5.7	SELECTION OF PARAMETERS AND METHODS 			6-7
5.8	ANALYTICAL METHODS		6-8
6.0 WATER QUALITY STATUS AND TRENDS MONITORING . 	 6-8
6.1	OVERVIEW 	 6-8
6.2	SAMPLING LOCATIONS	 	6-11
6.2.1	Nearshore/Offshore Waters 	6-11
6.2.2	Pollution Sources (Hot Spots)	6-14
6.3	PARAMETERS AND METHODS	6-21
6.3.1	Water Quality — Periodic Monitoring	6-21
6.3.2	Water Quality — Continuous Monitoring	6-22
6.3.3	Water Quality — Remote Sensing 	6-23
6.3.4	Sediment Quality 	6-23
6.3.5	Biological Body Burdens	6-24
6.4	DATA ANALYSIS AND INTERPRETATION	6-25
7.0 BIOLOGICAL RESOURCE STATUS AND TRENDS MONITORING	6-25
7.1 HARD-BOTTOM COMMUNITIES			6-25
7.1.1	Overview		6-25
7.1.2	Sampling Locations		6-28
7.1.3	Parameters and Methods	6-28
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CONTENTS (contini ed)
7.2	SEAGRASS COMMUNITIES	6-31
7.2.1	Overview	6-31
7.2.2	Sampling Locations	6-33
7.2.3	Parameters and Methods	6-33
7.3	MANGROVE COMMUNITIES 	 	6-34
8.0 REMEDIAL ACTION MONITORING	6-34
9.0 QUALITY ASSURANCE/QUALITY CONTROL 	6-35
9.1	QUALITY ASSURANCE PROGRAM GOAL	6-35
9.2	QUALITY ASSURANCE PROJECT PLANS	6-35
9.3	RESPONSIBILITIES 	6-37
10.0 DATA MANAGEMENT 	6-37
11.0 REFERENCES 	6-38
APPENDICES
A Field Protocols for Water Column, Sediment, and Tissue Monitoring
B Laboratory Methods and Analytical Protocols
C Seagrass Monitoring Protocols
D Existing Monitoring and Research Programs
E Volunteer Monitoring
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3.6 LICENSES AND FIRMHS
3.6.1 Licenses
Licenses are commonly issued to give people the right to participate in an activity that is controlled by the state or
local government. Fishing, hunting, and operating a motor vehicle are good examples of licensed activities.
Business licenses and many professional certifications are also in the category. Usually a nominal license fee is
charged to offset the cost of	god processing. In some instances, additional fees may be charged to fund
activities related to the licensed activity. Such is the case for fishing and hunting for which fees are often charged
to help pay for fisheries and game habitat and stock enhancement programs.
3.6.1.1	FISHING AND HUNTING
Florida currently requires licenses for the taking of fish and shellfish. The proceeds from the sale of saltwater
fishing licenses helps pay for research activities conducted by the FDNR. In many states, the sale of a license is
augmented by requiring users to purchase an additional stamp allowing the taking of specific species. Washington
state has a Duck Stamp program in which they contract with a well-known local artist each year to create a special.
stamp for duck hunting licenses. Revenue is generated by the sales of the stamp to hunters and stamp collectors,
as well as sales of limited number of prints made from the stamp to collectors (PSFC 1989). The potential revenue
generation from the program depends on several factors including the extent to which people connect the sale of
the stamp and prints to a preservation or mitigation function, the number of fishermen or hunters purchasing the
stamps, and the name recognition of the artist who creates the stamp. Combining the sale of the stamps with a
public education and outreach program that emphasizes the uses of the revenue from the stamp can increase the
stamps' revenue generating potential (PSFC 1989).
3.6.1.2	BOAT LICENSES AND REGISTRATION
Several states require purchase of a license and registration for recreational boats. Depending on how they are
implemented, registration fees can be either one-time or yearly charges on specific goods. In Rhode Island, a one-
time charge of SS is required to register outboard motors (EPA 1990a). A one-time fee is also charged to secure
an owner's title to a boat. This latter fee is imposed on both motorized and nonmotorized watercraft. North
Carolina, Washington, and Rhode Island also charge annual boat registration fees. North Carolina charges a flat
yearly fee, while Rhode Island uses a graduated scale based on the size of the boat. In Washington, the fee is an
excise tax of 0.5% of the fair market value of the registered watercraft, or a minimum of $5.00.
Proceeds from this fee could be allocated to boating safety activities and other boating related services such as
maintenance of mooring fields, parks, and boat launches. Because boats and automobiles contribute to water quality
degradation, registration fees could be charged at a rate that reflects these impacts. The proceeds could be allocated
to mitigating boat- and automobile-related water quality impacts.
3.6.2 Permits
State and local governments require permitting for many construction and development activities. In addition,
ongoing activities such as discharges to surface waters or operation of private waste treatment facilities are often
allowed only by permit. A permit fee is often charged for processing of the permit application. In addition, permit
fees could be levied to fund ongoing inspection and monitoring activities, or as a disincentive for specific activities
such as discharges. Permit fees could be assessed as a per-application flat fee, or may be based on the size of the
project or amount of impact the permitted activity will have on the environment.
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The SFWMD requires permits for certain activities that may affect stormwater runoff. FDER and Florida
Department of Health and Rehabilitative Services (FDHRS) permit wastewater treatment facilities and OSDSs. In
addition, permits are required for dredging and filling of wetlands, discharges to surface waters National Pollutant
Discharge Elimination System (NFDES), and underground injection. In general, permits fees are established at a
level that covers the costs of processing the permit. The potential for additional revenue generation from permits,
to cover the costs of enforcement and monitoring, depend* on the number of permits being issued and any
limitations placed on permit fees by law. Revenues collected by FDHRS are given to the state for allocation.
Nothing in the legislation establishing these permit fees requires the revenue to be used for enhancing or protecting
water quality. Changes in legislation to allocate present revenues for water quality improvement and enforcement
could provide additional fluids for these activities.
3.6.3 Impacts
Both licenses and permits are generally considered equitable because they assign the costs of an activity to the
population using the resource or impacting an area. Hunting and fishing licenses charge users for the taking of
public goods and a portion of the costs for the management of those resources. Licenses for using a boat or car
are also viewed a means for offsetting the costs of providing services, such as roads and navigational aids, related
to those activities. Permits charge for ensuring that activities comply with specific regulations.
Both licenses and permits tend to be relatively small sources of revenue. Licenses rarely cover all of the costs of
monitoring, enforcement, and resource enhancement activities. Likewise, permits are often set at a rate that does
not reflect the actual costs associated with the activity for which they are granted. In addition, permits for
development or alteration, such as wetlands filling, rarely reflect the social costs of the activities being undertaken.
3.7 SPECIAL ASSESSMENTS
In some instances certain improvements to infrastructure benefit a small sector of the population. Examples include
new road construction, extension of water delivery systems to new areas, and extension of sewer connections to a
specific district. In such cases, special assessments may be levied to each property owner in the district to pay for
the improvements. A form of Revenue Bond, called a Special Assessment Bond, may be issued to finance U>e
improvements. In some instances general tax revenue may be used to supplement the assessments.
Several sections of the Florida Statutes currently allow counties to levy special assessments (ACIR 1992). Section
125.01 F.S. allows counties to establish a municipal service benefit unit that may levy taxes and special assessments.
Section 125.01 is quite liberal in defining allowable purposes for use of special assessments. Among the many
purposes allowed are beach erosion control, recreation service and facilities, water, streets, garbage and trash
collection and disposal, waste and sewage collection and disposal, drainage, and other essential facilities and
municipal services (F.S. 125.01). This statute effectively allows the use of special assessments for most of the
proposed water quality improvement options presented in Task 3.
An additional authorization of special assessments is contained in Chapter 170, Florida Statutes Supplemental and
Alternative Method of Making Local Municipal Improvements. It provides municipalities the following authorization
for the use of special assessments:
•	Order the construction, reconstruction, repair, renovation, excavation, grading stabilization, and
upgrading of greenbelts, swales, culverts, sanitary sewers, storm sewers, outfalls, canals, primary,
secondary, and tertiary drains, water bodies, marshlands, and natural areas, all or part of a
comprehensive storm water management system, including the necessary appurtenances and structures
thereto and including, but not limited to, dams, weirs, and pumps;
•	Order the construction or reconstruction of water mains, water laterals, and other water distribution
facilities, including the necessary appurtenances thereto;	
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•	Provide for the drainage and reclamation of wet, low, or overflow ec lands;
•	Provide for mass transportation systems; and
•	Provide for the payment of all or any part of the costs of any such improvements by levying and
collecting special assessments on the abutting adjoining contiguous, or other specially benefitted
property (FS 170).
In addition to these municipal authorizations, certain special districts are given authority to levy special assessments.
Of particular interest to financing water quality improvements are such authorizations for Water Control Districts,
Water Managements Districts (SFWMD), and Water and Sewer Districts. FS 403.0893 further authorizes the use
of stormwater utilities and stormwater utility fees "sufficient to plan, construct, operate, and maintain stormwater
management systems." The creation of "stormwater management system benefit areas" is allowed by the statute,
and property within the area may be assessed per acre fees (F.S. 403.0893).
It is clear from the Florida Statutes discussed above that municipal use of special assessments is authorized for many
activities related to the water quality improvement options. There are, however, significant legal considerations in
the levying of a special assessment. Generally, special assessments must be levied only when a special benefit to
the property to be assessed will occur as a result of the assessment (ACIR 1992). In addition, apportionment of
the assessment among property owners must be fair and reasonable (ACIR 1992).
Despite the apparent widespread authorization, special assessments do not make up a large share of municipal or
special district revenue in Florida. In 1986-87 only 0.5 % of county revenues, 0.7% of municipal revenues, and
0.9% of special district revenues were generated via special assessments (ACIR 1992). In localities where special
assessments are used, the most prevalent purposes for their use have been to fund solid waste facilities, street
lighting, road paving, and fire protection. In addition, at least three counties were levying special assessments for
sewer projects in 1991.
3.7.1 Impacts
Special assessments are similar to taxes in that they are an enforceable contribution from property owners (ACIR
1992). However, special assessments are limited to the property directly benefiting from an activity, whereas taxes
are levied over a local-government-wide tax base. Because the base of the special assessment is smaller than the
overall tax base, they generally do not provide as large a source of revenue. The advantage is in the defined benefit
principle: apportioning the costs for improvements according to the benefit the property receives from them.
An additional benefit to using special assessments as a finance tool is that they are enforceable levies. Unlike rates
and charges, special assessments are generally limited to facility construction. Operation and maintenance will still
need to be funded through other forms of revenue, such as rate revenue. Special assessments also protect general
borrowing capacity by minimizing the requirement of the municipality to incur debt through other mechanisms, such
as bonds.
Special assessments have a definite, sometimes substantial, impact to the property owners being assessed. Property
owners are not able to deduct the amount of the special assessment from their taxes, as they would be able to do
with ad valorem property taxes (ACIR 1992). In addition, the start-up and administration of special assessments is
complex and can be costly.
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3.8 DONATIONS/CHARITABLE TRUSTS
3.8.1 General Description
Donations provide an attractive mechanism for financing environmental programs. Five percent of the available
grant dollars in 1991 was directed toward environmental and animal programs, with two-thirds of that money being
spent in programs for protecting natural resources (Olson 1992). Several foundations and trusts provide funding
for specific programs in their areas of interest. The size of grants can range from $20,000 for the One Thousand
Friends of Florida to assist communities in implementing the state's growth management plan, to $100,000 for
Collier City, Florida, to develop a new landfill recycling program (Olson 1992). Grants are available to local
governments, organizations, and interest groups, and specific application requirements usually apply. For the
purposes of the FKNMS, these grants are likely to be most useful in funding public education and outreach activities
to raise the awareness of Keys resource impacts and issues. A primary source for information on available grants
is the Found-. jion Crarus Index for 1992 published by the Foundation Center. (Olson 1- '2)
3.9 PRIVATIZATION
3.9.1 Operations Contracting
During the past several years, budgetary difficulties combined with the increasing complexity of providing services
has prompted the privatization of many public services traditionally provided by municipal governments (Roehm
et aL 1989). The most common form of privatization, known as Public/Private Partnerships, involves the
contracting of a private firm to operate and maintain public facilities. There are several types of Public/Private
Partnerships ranging from contract services (least private) to merchant owned and operated facilities (most private).
One example of such an arrangement is the contracting of a waste management firm to operate a municipal
wastewater treatment facility. Often, the operation of such facilities is quite complex and costly. Large and small
municipalities alike may suffer from lack of expertise in establishing management and operations of wastewater
facilities and may choose to contract the operation of the plant to a private firm. The private firm is contracted to
operate the plant for a negotiated fee designed to cover operating expenses and negotiated profit margins. While
contracting specifications vary, and can be quite complex, a usual component is a provision for sharing excess
profits realized through operating cost minimization between the private firm and the municipality (Holcombe 1991).
Such an arrangement provides operational efficiency incentives for the private firm and may result in a return of
profits to the municipality. In most cases the municipality owns the plant and retains responsibility for monitoring
and enforcement of contract provisions including regulatory compliance. It is important to note that the municipality
must be cognizant of the possibility of excessive cost cutting by the private firm to enhance profits. Unfortunately,
this is a built-in difficulty of a profit incentive based on operating cost minimization and must be prevented through
stringent monitoring of operations. A current example of this mechanism in the Florida Keys is the contracting of
operations of the Key Colony Beach WWTP to Anti-Pollution Associates. The City of Key West currently contracts
the operation of wastewater treatment to OMI, Inc.
3.9.2 Construction and Operations Contracting
The construction of a municipal WWTP is both a costly and lengthy proposition. Construction costs can be in the
tens of millions of dollars and in some cases municipal construction of a plant has taken more than ten years
(Holcombe 1991). Costs of construction will increase with the length of time required for completion. In addition,
if plant construction is funded through the use of bonds, the delay in establishing a stream of rate revenue from the
plant will require that other revenues such as tax revenues be raised to provide for debt maintenance during the
construction phase. Such problems have prompted the use of a more extensive form of privatization than the
common operations contracting method mentioned previously.
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In genera|, the construction of a wastewater treatment facility must proceed through a series of stages including
authorization, design, and construction. During this process, certain permits must be obtained, and construction
code inspections must be conducted. These'processes are generally the same for a municipality that is contracting
with a construction company to build a public plant or for a private company constructing a private plant that it will
then own and operate privately or on contract to a municipality. Thus, it would seem that the overall cost of
construction and the time required would be the same for both the public plant and the private plant. In fact,
however, this is simply not the case (Holcombe 1991).
A private firm operates with the primary purpose of earning a profit by providing goods and services. The
municipality, on the other hand, has no such "profit incentive" and is simply providing the services that it has
deemed necessary for orderly operation of the municipal government. Providing for such orderly operations has
resulted, over the years, in extensive layers of bureaucracy that may severely hamper the ability of a municipal
government to efficiently manage the construction of facilities. The result is that some municipal plants can take
as much as tea or more years for completion while similar private plants have been constructed in approximately
two years (Holcombe 1991). The total savings in administrative cost earned by elimination of the unnecessary
construction time, combined with the potential income from eight years of plant operation, foregone in the public
ownership case, may be quite an incentive for privatization of both the construction and operation of WWTPs or
other municipal facilities. In addition to the profit incentive, private firms may also have greater technical and
design expertise that enables them to assess opportunities for using more advanced technologies and make
knowledgeable predictions of cost and performance benefits (EPA 1990c). Private partners are often more free to
make cost-benefit decisions than public officials who are more directly influenced by political pressures.
In this more extensive privatization, the facility is constructed, owned, and operated by the private firm under
contract to the municipality. The municipality has traditionally issued a Revenue Bond to provide funds for
construction of the facility. These funds are then made available to the private firm to finance construction of the
plant, and the private firm repays the debt with rate revenue during the operation contract. Under this scenario,
the private partner has significant incentive to construct the plant quickly and at the least possible cost. In addition,
if the contract is wisely composed, incentive to operate the plant efficiently is built in as a profit motive via profit
sharing agreements as in the case of operations contracting. In practice, this type of arrangement has resulted in
planning and construction of a treatment plant in two years as compared to as much as eleven years for a municipal
plant (Holcombe 1991).
Public/Private partnerships are by no means the answer to all of the problems of providing municipal service needs.
There are significant contracting complexities to overcome, and, in some instances, inefficiencies in contracting may
create costs that exceed any benefit to be gained by privatization (Holcombe 1991). In addition, use of IDRBs to
finance such projects was severely curtailed by the 1986 Federal Tax Reform Act. Such bonds are issued by the
municipality as tax free revenue bonds and are repaid with revenue from private contracting of the facility
constructed with the bond financing. The 1986 Federal Tax Reform Act defines such bonds as private activity bonds
if any more than 10% of the bond repayment revenues come from private activities such as pnvate operation of a
WWTP. The Act established a statewide private activity bond cap based on a dollar amount per capita.
Florida is currently allowed $633.5 million in issuance of private activity bonds statewide (see Section 3.1.5) (ACIR
1991d). As Section 3.S. 1 discussed, the state facilitates the distribution of available private allocation bonds through
three pools and projects must compete for inclusion in the cap amount. If a private activity bond project is not
included in the cap allocation, the project cannot be financed with private activity IDRBs and must be funded
through alternate means or delayed for possible inclusion in future pools.
3.9.3 Impacts
One advantage of privatization is the greater expertise that is brought to management of facilities by private
contractors. This tends to decrease the level of bureaucracy by relieving the local government of the need to operate
a facility. In addition, private contractors have a profit incentive that tends to encourage more efficient management
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of activities than public agencies provide. Privatization has demonstrated an ability to significantly reduce the time
required to construct facilities, and the overall costs of construction.
A disadvantage to privatization is the potential for profit maximization to encourage lower levels of service and
product quality in order to achieve a higher level of profit. This requires a rigorous amount of oversight and
monitoring on the part of the public agency, which can increase costs. In addition, privatization requires a
sophisticated level of contracting ability, usually including extensive legal services.
Because privatization tends to decrease the costs of construction, it can significantly reduce rates, thereby having
a beneficial impact on the rate paying public. In certain circumstances, privatization can displace public workers
in favor of private ones.
4.0 IMPLEMENTATION
The preceding section outlines some potential funding mechanisms that could be used to finance water quality
improvement activities. The next step in the process will be selecting and implementing the most appropriate
funding mechanisms. This step will necessarily take place after a preferred set of water quality improvement
options has been identified, and with in-depth analysis of the local economy in which the options will be
implemented. This section outlines the issues that need to be addressed in selecting specific funding mechanisms
and identifies some strategies for combining the mechanisms discussed in Section 3.0 into a funding approach for
wastewater and stormwater management activities.
4.1 SELECTING FUNDING MECHANISMS - CONSIDERATIONS
Several factors will affect the choice of funding mechanisms. Foremost among these is a determination of the
amount of additional revenue needed in order to implement the preferred management and engineering options. In
addition, an understanding of the constraints imposed on collection of specific revenues, such as taxes, is also
required. This section identifies the major factors that should be considered in selecting the appropriate funding
mechanisms and outlines an approach to making that selection.
Authorization: Once specific water quality implementation options have been selected, the agency or institution
tasked with implementation will need to be identified. Task 3 suggests potential agency and institutional actions for
each of the major management and institutional options. The funding mechanisms available to these agencies and
institutions will depend on the legislative and constitutional authorization they have been granted. In Florida, as
with other states, there are specific limitations on implementing some of the funding mechanisms identified in this
report. An example is the Florida tax system, which limits municipalities and local governments to collection of
ad valorem property taxes and local option taxes. Determining which agency or institution is best suited to
implementing the water quality improvement options should be partly based on their ability to generate needed
revenue.
Project Costs: In determining the amount of revenue required, an assessment of the overall project costs is
required. This includes construction, management, and operational costs, as well as costs associated with managing
any debt incurred in financing the project. At the early stage of selecting funding mechanisms, the amount of debt
management required may not be known. The overall project costs are likely to change as funding mechanisms are
identified, and as the project is implemented. Early estimation of the level of funding required will allow the
implementing entities to more easily identify the most appropriate funding mechanisms. Once these mechanisms
have been identified, their impact to the debt management portion of the project cost assessment will need to be
calculated.
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CONTENTS (continued)
TABLES
6-1 Comparison of detection limits of EPA-approved and routine oceanographic
analytical methods for nutrients	 6"ฎ
6-2 Water quality status and trends monitoring	6-10
6-3 Locations of stations on transects in Segments 3, 5, 6, 7, 8, and 9 	6*15
6-4 Group designations of confined water sites with known or suspected
severely degraded water quality	6-16
6-5 Biological resource status and trends monitoring	6-27
6-6 Techniques that have been used for coral reef surveys 	6-30
6-7 Non-destructive visual census techniques for coral reef fishes . 	6-32
FIGURES
6-1 Geographic stratification scheme (segments) for the Florida Keys
National Marine Sanctuary	6-12
6-2 Locations of water quality sampling sites in Segments 1, 2, and 4 and
water quality transects in Segments 3, 5, 6, 7, 8, and 9	6-13
6-3 Results of the power analysis for nitrate, ammonium, total nitrogen, phosphate,
and total phosphorus	6-26
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ACRONYMS
AA
autnanalyzer
AAS
atomic absorption spectrophotometry
AIW
Advanced Inventory of Wetlands
APA
alkaline phosphatase activity
AVHRR
advanced very high resolution radiometer
BCD
Biological Conservation Database
BNP
Biscayne National Park
CARICOMP
Caribbean Marine Productivity Program
CAMRA
Coastal and Marine Resource Assessment
CM AN
Coastal Marine Automated Network
CMC
Center for Marine Conservation
C:N:P
caibon:nitrogen:phosphonis
DERM
[Dade County] Department of Environmental Management
DFAA
dissolved free amino acids
DIN
dissolved inorganic nitrogen
DIP
dissolved inorganic phosphate
DO
dissolved oxygen
DON
dissolved organic nitrogen
DQO
Data Quality Objectives
ECD
electron capture detector
EDF
Environmental Defense Fund
EMAP
Environmental Monitoring and Assessment Program
ENP
Everglades National Park
EPA
Environmental Protection Agency
FAAS
flame atomic absorption spectrophotometry
FDCA
Florida Department of Community Affairs
FDER
Florida Department of Environmental Regulation
FDNR
Florida Department of Natural Resources
FID
flame ionization detector
no
Florida Institute of Oceanography
FIU
Florida International University
FKLST
Florida Keys Land & Sea Trust
FKNMS
Florida Keys National Marine Sanctuary
FMRI
Florida Marine Research Institute
FWS
U.S. Fish and Wildlife Service
GC/MS
gas chromatography! mass spectrometry
GIS
Geographic Information System
GPS
Global Positioning System
HBOI
Harbor Branch Oceanographic Institution
HDPE
high density polyethylene
IC
inorganic carbon
IR
infra-red
KLNMS
Key Largo National Marine Sanctuary
LAI
leaf area index
LKNMS
Looe Key National Marine Sanctuary
MFP
methyl fluorescein phosphate
MOA
Memorandum of Agreement
NAS
National Audubon Society
NBS
National Bureau of Standards
NNED
N-( 1 -naphthyl)-ethy lenediamine dihydrochloride
NOAA
National Oceanic and Atmospheric Administration
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ACRONYMS (continued)
NPOC
non-purgeable organic carbon
NPS
National Park Service
NRC
National Research Council
NTU
nephelometric turbidity unit
NURC
[NOAA] National Undersea Research Council
OPA
o-phthaldialdehyde
OSDS
on-site sewage disposal system
PAR
photosynthetically active radiation
PCB
polychlorinated biphenyl
PTFE
polytetrafluoroethylene - (Teflon)
PVC
polyvinylchloride
QA
Quality Assurance
QAO
Quality Assurance Officer
QAPjP
Quality Assurance Project Plan
QC
Quality Control
RFA
Rapid Flow Analyzer
SEAWIFS
Sea-Viewing Wide Field of View Sensor
SFRL
South Florida Regional Laboratory
SFWMD
South Florida Water Management District
TDN
total dissolved nitrogen
TDP
total dissolved phosphorus
TN
total nitrogen
TNC
The Nature Conservancy
TOC
total organic carbon
TP
total phosphorus
TSS
total suspended solids
MM
micromoles per liter
jimhos
micro mhos
USGS
United States Geological Survey
WWTP
wastewater treatment plant
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1.0 INTRODUCTION
The goal of Task 6 is to develop a comprehensive water quality monitoring program for the Florida Keys National
Marine Sanctuary (FKNMS). For the Water Quality Protection Program, monitoring is defined as the continued
observation of FKNMS waters to determine the spatial and temporal variability in water quality and the status of
the biological resources to determine whether these conditions are improving or degrading. Theoretically, some
form of monitoring will continue as long as the FKNMS exists. Sanctuary managers will use the monitoring
program and the research results in conjunction with the institutional and engineering options (Tasks 3 and 4) to
accomplish the objectives of the Water Quality Protection Program.
The monitoring program is closely related to the research program discussed under Task 7. The monitoring
program will focus on documenting status and trends and measuring the success of remedial actions, whereas the
research program will focus on processes and cause/effect relationships. One way in which the research program
will interact with the monitoring program is through the development of new monitoring tools (e.g., indicators).
In addition, the monitoring program will provide data for the validation and refinement of predictive models
developed through research.
The monitoring program described here is developing through an iterative process. A preliminary draft monitoring
program was circulated to scientists for review prior to the Monitoring/Research Workshops held July 14-16, 1992
in Marathon, Florida. The monitoring program was then revised based on numerous comments and suggestions
provided by the workshop participants. A draft monitoring program (Task 6 report) was reviewed by the
Environmental Protection Agency (EPA) and the state of Florida.
Although an overall monitoring design has been developed, some aspects of design (e.g., coral reef sampling
locations and methodologies, seagrass sampling locations) and other details of implementation remain to be worked
out. In addition, the monitoring program was designed with no cost constraints, Therefore, before the monitoring
program can be implemented, it will be necessary to develop an implementation plan that will (1) revise the
monitoring program design based on anticipated funding and (2) describe specific steps to be taken in implementing
the program.
2.0 OBJECTIVES
According to the Florida Keys National Manne Sanctuary and Protection Act, the goals of the water-quality
monitoring program are to
•	Determine the sources of pollution causing or contributing to existing or anticipated pollution problems
in the FKNMS
•	Evaluate the effectiveness of efforts to reduce or eliminate those sources of pollution
•	Evaluate the progress toward achieving and maintaining water quality standards and toward protecting
and restoring the coral reefs and other living marine resources of the FKNMS
The EPA Statement of Work for Phase II of the Water Quality Protection Program provides an expanded set of
goals for the monitoring program based on the Florida Keys National Marine Sanctuary and Protection Act. These
goals are to
•	Provide a baseline for comparison with future conditions
•	Determine significant water quality trends
•	Evaluate the progress toward achieving and maintaining water quality standards
•	Provide a framework for testing hypothesized pollutant fate/effects relationships
•	Determine the sources of pollution causing or contributing to existing or anticipated pollution problems
in the FKNMS, including far-field pollution sources that may be affecting the FKNMS
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•	Evaluate the effectiveness of efforts to reduce or eliminate sources
•	Evaluate compliance with regulations (water-quality effluent limitations and other enforceable pollution
control *sasures)
3.0 BACKGROUND
The monitoring program was developed on the basis of the objectives listed in Section 2.0, the Phase I literature
review and workshops, and guidance from scientists familiar with the water quality and biological resource problems
in the Keys. In addition, guidance was provided by the following relevant documents:
•	National Oceanic and Atmospheric Administration (NOAA) Research Planning Workshop (Harwell
1991)
•	FKNMS Strategy Identification Sessions
•	National Estuary Program: Monitoring Guidance Document (EPA 1991)
•	Managing Troubled Waters: The Role of Marine Environmental Monitoring (National Research
Council [NRC] 1990)
•	Proceedings, International Symposium on the Design of Water Quality Information Systems (Ward et
al. 1989)
•	Biological Criteria: National Program Guidance for Surface Waters (EPA 1990)
•	Environmental Monitoring and Assessment Program (EM AP) Guidelines for Preparing Logistics Plans
(Baker and Merhtt 1991)
•	1990 Demonstration Project: Quality Assurance Project Plan (QAPjP) for EMAP Near Coastal
(Valente et al. 1990)
These documents were used to define the primary characteristics and constraints of the monitoring prr ;ram. In
particular, they provided information regarding monitoring objectives, stratification of the Sanctuary, rumpling
design, allocation of the sampling effort, and the selection of parameters of interest. The documents vere also
useful for determining the characteristics of successful monitoring programs and identifying common p falls.
Based on these general sources of guidance, the following broad characteristics of the monitoring pro ram were
determined:
•	The program should monitor the status and trends of water quality parameters throughout the
Sanctuary, including areas near the known pollution sources.
•	The program should monitor the status and trends of biological resources potentially affected by water
quality problems.
•	In addition to status and trends, the program should monitor remedial actions (e.g., engineering and/or
institutional actions to reduce or eliminate pollutant sources) with a program design appropriate to the
specific action.
During the initial phases of the monitoring program development, a preliminary monitoring framework that
described the approach being taken to develop the monitoring program was prepared and circulated to the natural
resource managers and scientists. These individuals were interviewed to determine their opinions on the monitoring
framework, information needs (resource managers), and opinions on specific parameters/methods (scientists).
Participants at the Monitoring/Research Workshops (July 14-16, 1992) provided further guidance for monitoring
program development, including suggestions for sampling locations. The following points were emphasized.
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•	Everglades/Florida Bay system
The monitoring program design should take into account the close relationship between the Sanctuary
and adjacent areas, especially the Everglades/Florida Bay system. To the extent possible, proposed
monitoring methodologies and those methodologies currently used in the adjacent areas should be
consistent. For complete geographic coverage, monitoring stations should be established outside the
FKNMS boundaries.
•	Monitoring of "hot spots"
There is ample evidence of pollution problems at known or suspected "hot spots." The monitoring
program should include a representative sampling of such areas, but its main focus should be detecting
degraded water quality in nearshore and offshore waters.
•	Remote sensing
Remote sensing can be used to monitor biological resources (hard-bottom communities, seagrass
communities, and mangrove communities) on a broad scale. This approach can be used to augment
field sampling efforts and to help generalize findings obtained from a limited number of fixed stations.
4.0 COMPONENTS
4.1 STATUS AND TRENDS MONITORING
The purpose of the status and trends monitoring is to provide a base of information concerning the condition of
water quality and biological resources in the FKNMS. The status and trends monitoring will be geographically
comprehensive, providing a baseline of information and documenting trends in water quality and biological
resources. The status and trends monitoring effort is expected to continue as long as the FKNMS exists.
4.1.1 Water Quality
Nearsjore and offshore waters will be sampled as part of the water-quality monitoring program. This sampling will
be conducted to gather representative data for determining the status and trends in water quality and to examine
gradients associated with distance from the land mass. This sampling will be conducted during periodic surveys
when water quality measurements are made and water samples are collected and analyzed. In addition, water
quality measurements will be made by using continuously recording in situ instrumentation.
Water quality in confined waters that are known or suspected to be severely degraded will also be monitored by
periodically collecting water quality measurements and collecting and analyzing water samples. These data will be
used to determine the status and trends of pollution sources and will be useful in designing remedial action
monitoring efforts (Section 4.2).
4.1.2 Biological Resources
The status and trends of biological resources in tl)e FKNMS will also be monitored. Of the biological resources
in the FKNMS, those to be monitored include coral reef, hard-bottom, seagrass, and mangrove areas. Hard-bottom
communities, which include nearshore hard-bottom and offshore coral reef communities, will be monitored by in
situ sampling and remote sensing. Data pertaining to the seagrass communities will also be collected by in situ
sampling and remote sensing. Changes in mangrove communities will be monitored using remote sensing.
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4.2 REMEDIAL ACTION MONITORING
Remedial actions will be taken to control pollution sources in the Keys, probably on both policy and engineering
levels. This remediation monitoring should document the success or failure of engineering and/or institutional
alternatives to reduce or eliminate pollution sources. The scope of the monitoring will be determined on a
case-by-case basis; this monitoring could be broad or site-specific (e.g., a pilot project).
5.0 GENERAL DESIGN CONSIDERATIONS
Several general aspects of the monitoring program design are considered in this section.
•	Hypotheses
What questions will the data collected during the monitoring program be used to answer?
•	Program structure and evaluation
Is there enough data concerning the spatial and temporal variation in water quality to design a
long-term monitoring program? If not, a phased approach may be appropriate, with the program
design being reevaluated and refined after the completion of an initial baseline monitoring period.
•	Stratification
What stratification will be incorporated into the monitoring program design to control different sources
of variability?
•	Sampling designs
How will transect-oriented and stratified random-sampling designs be incorporated into the monitoring
program?
•	Existing study locations
To what extent will existing study sites be incorporated into the monitoring program?
•	Remote sensing
How will the remote sensing of biological resources be incorporated into the program?
•	Selection of parameters
What parameters will be measured in the water quality and biological resources monitoring program?
•	Analytical methods
What analytical methods will be used in the monitoring program?
5.1 HYPOTHESES
The hypotheses for the water-quality monitoring program will determine what data are collected and how they will
be analyzed and interpreted. The hypotheses must be related to the overall objectives of the Water Quality
Protection Program so that the Sanctuary managers can use the information from the monitoring program to
determine appropriate management actions.
Because a primary objective of the Water Quality Protection Program is to improve water quality in the Sanctuary,
a basic question for the status and trends monitoring efforts for water quality and biological resources is whether
water quality in the Sanctuary is remaining relatively constant, deteriorating, or improving. Therefore, hypotheses
for the status and trends monitoring are related to temporal changes. The null hypothesis for water quality and
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biological community parameters is that there is no long-term change with respect to present conditions. The
alternative to this hypothesis is that there is a trend (i.e., the parameters are changing in one direction or the other
[improving or deteriorating]). If trends are identified in the biological communities during the course of the status
and trends monitoring, then additional hypotheses relating changes in the biological communities to changes in water
quality parameters can be investigated.
Engineering and institutional alternatives will be considered to reduce or eliminate pollutant sources (see Tasks 3
and 4). An appropriate null hypothesis to evaluate such actions is that a particular remedial action has no effect
on water quality in areas where the effects of the pollution source have been observed. The alternative hypothesis
is that a particular remedial action improves water quality b areas where the effects of the pollution source have
been observed. This null hypothesis can be applied in site-specific monitoring programs for wastewater treatment
plants (WWTP), on-site sewage disposal system (OSDS) foci, injection wells, marinas and live-aboard mooring
sites, commercial and industrial facilities, stormwater runoff, and mosquito spraying. The remedial-action
monitoring program would be designed to test the null hypothesis, and if the action proves effective, regulatory
agencies would have a justification for implementing changes over a larger area.
5.2 PROGRAM STRUCTURE AND EVALUATION
One aspect of the program design that had to be considered was whether there were sufficient available data to
design a long-term monitonng program that would require minimal refinement during its execution. Based on the
results of Phase I of this project, it is clear that sufficient data concerning spatial and temporal variations in water
quality are not available to design a final long-term monitoring program. The monitoring program will therefore
be conducted in phases, with the design of each phase dependent upon the results of the preceding phases.
Because a comprehensive, temporally continuous baseline does not exist for the FKNMS, the first phase of the status
and trends monitonng program will begin with a baseline monitoring effort. This baseline effort will continue for
5 years because this is thought to be sufficient to (I) evaluate the sources of variability in water quality; (2)
determine what parameters are most effective to measure and what methodologies are most effective to use; and
(3) evaluate what sampling frequency and sampling design are effective in terms of the density and distribution of
the sampling locations. This baseline monitoring effort is described in this document. After the completion of the
baseline monitoring, the data will be evaluated and a long-term monitoring effort will begin. The scope of this long-
term monitoring effort will be evaluated every year and refined as needed.
Dunng the baseline monitoring period, status and trends data will be collected for water quality and biological
resources. Dunng the initial survey, sediment and tissue samples will also be collected to evaluate the distnbutions
of sewage tracers such as coprostanoi and toxic compounds such as heavy metals, pesticides, polychlonnated
biphenyls (PCBs), and petroleum hydrocarbons. These sediment and tissue data will be evaluated to determine if
the scope of the baseline monitoring should be expanded with respect to these compounds routinely.
The most important use of the data collected during the baseline monitoring will be to develop and calibrate the
water quality/hydrodynamic and ecological models that will provide the central framework for the long-term
monitoring design, as discussed in Task 7. These models are not presently available, and adequate data are not
available for their development. Baseline monitoring data will be used to identify important spatial and temporal
scales of water quality variability. In addition, these data will be used to evaluate the ability to detect changes.
Data collected during the baseline monitoring program will also be used to identify sources of redundant
information. Examples of such sources are (1) stations that are strongly correlated with respect to water quality
and, therefore, provide essentially the same information, and (2) parameters that are strongly correlated and,
therefore, data for one parameter is sufficient to compute the other. Correlations among parameters may be useful
for the interpolation between measurements made at discrete times from data collected continuously.
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5.3 STRATIFICATION
The purpose of stratification in a monitoring program design is to control the different sources of variability (i.e.,
quantify the variability that may be associated with different sources so that real trends are not masked by variability
from these sources). Because regions of the FKNMS differ with respect to the sources of variability, such as
different oceanic regimes, distance from the mainland, physiography, and biological resource habitats, stratification
is incorporated into the status and trends monitoring program design.
Considering the Sanctuary as a whole, a geographic stratification (segmentation) framework will be incorporated
in the monitoring program design (see Section 6.0). These strata were determined based on the distance from the
South Florida mainland and oceanic regime (Atlantic Ocean, Gulf of Mexico, and Florida Bay). Geographic regions
are generally related to distance from the South Florida mainland and differences between the Upper Keys, Middle
Keys, Lower Keys, and Western Extension. Oceanic regimes are separated because proximity to the Loop
Current/Florida Current system affects water quality. Physiography was incorporated to use a separate sampling
design for the segment surrounding the Lower Keys. Boundaries between segments were refined based on a spatial
framework developed by Klein (1993), which divides the FKNMS into segments based on dominant hydrodynamic
scales. Congruence between the water quality sampling design and hydrodynamic spatial framework will facilitate
modeling of hydrodynamic processes important to water quality in the Sanctuary.
A second level of stratification was established within segments where large passes between Florida Bay and the
Atlantic Ocean occur (e.g., in the Middle Keys). Water quality may vary among the transects depending on an
association with the land mass and movement of water through the passes. Therefore, water quality transects will
also be stratified according to whether their shoreward end is adjacent to land or a pass.
In the biological resource status and trends monitoring, stratification will also be established to account for different
habitat types. Within the coral reef study sites, the stations will be stratified as bs k reef, reef flat, shallow and
deep spur-and-groove, fore reef, and deep reef. Nearshore hard-bottom areas \ ill be stratified into different
distributional patterns — sparse, moderately dense, and patchy — based on t. preliminary list of benthic
communities to be mapped in the Florida Department of Natural Resources (FD^ il)/NOAA mapping study (F.
Sargent, FDNR, personal communication, 1992). Seagrass communities will also c stratified based on the benthic
communities to be mapped by the FDNR/NOAA. These strata will be contiguous moderate and dense), sparse,
and patchy areas of seagrass distribution.
5.4 SAMPLING DESIGNS
Different aspects of the status and trends monitoring program require different san pling designs, such as transects
and stratified random sampling. Transects are applicable in situations where a gradient in the parameters of interest
exists. This is certainly the case for water quality in relation to the Florida Keys land mass. In addition to a natural
land mass effect, there are also sources of pollution associated with the land mass. Random sampling or stratified
random-sampling designs are means of obtaining representative data when there is not evidence of an underlying
trend. Because there are natural strata associated with the FKNMS system, randomized sampling within these strata
is applicable to these situations.
Transect-oriented and stratified random-sampling designs are incorporated into the monitoring program, depending
on the component. For water quality, transects are used in all but one particular geographic stratum to provide
spatial information concerning gradients related to distance from shore. The physiography of this one geographic
stratum, which encompasses much of the Lower Keys, is not conducive to using a transect-oriented sampling design.
In this stratum, a randomized sampling design is used. Within each geographic stratum, there are natural biological
strata. To obtain representative data within these biological strata, a randomized design was used in the biological
resource status and trends monitoring.
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5.5 EXISTING STUDY LOCATIONS
Ongoing research programs [e.g., the cooperative SEAKEYS/National Undersea Research Center (NURC)/Harbor
Branch Oceanographic Institution (HBOI) program (see Appendix D)], address specific questions concerning water
quality, such as the high-frequency variability of water quality. These data are important because they provide
information on aspects of water quality that will not be addressed in the status and trends monitoring program. The
sampling sites in such studies are generally selected to investigate specific scientific questions; therefore,
incorporating these sites into the status and trends monitoring program is not appropriate because the sites were not
selected based on the overall objective of the status and trends monitoring program. Water-quality sampling is
routinely conducted in the Everglades National Park ([ENP] Florida Bay) and in Biscayne National Park ([BNP]
Biscayne Bay). Coordination (in terms of sampling methodology and analysis) and exchange of data between these
programs and the FKNMS status and trends monitoring program is needed because they are part of the South
Florida system.
Seagrass monitoring stations do not currently exist in the Sanctuary, therefore, it was necessary to develop a
sampling design that incorporates the selection of seagrass monitoring stations into the monitoring program.
However, there is a series of monitoring stations in Florida Bay (investigators from ENP, University of Virginia,
and FDNR). Because this region is part of the same system and is adjacent to the Sanctuary, monitoring methods
used in this program will be comparable to those used in Florida Bay.
There are a number of existing coral reef study sites in the Sanctuary (Appendix D). Because much of the
information concerning the status of coral reefs at these sites within the Sanctuary is valuable baseline data, sampling
at these sites is recommended for incorporation into the monitoring program.
5.6 REMOTE SENSING
Remote sensing and mapping are valuable tools for gaining perspective of the overall distributions of benthic habitats
in large areas such as tht FKNMS. Comparison of the results between mapping efforts allows the evaluation of
changes in the distributions of the habitats. FDNR/NOAA are currently conducting a mapping effort of FKNMS
benthic habitats, including seagrass and hard-bottom communities; results are anticipated to be released in December
1993 (K. Haddad, FDNR Marine Research Institute, personal communication, 1992). In addition, a separate remote
sensing effort, the Advam^d Inventory of Wetlands (AIW), is being conducted to map mangroves. The monitoring
program design includes repetition of these mapping efforts every few years to assess any broad-scale changes in
habitat distribution.
5.7 SELECTION OF PARAMETERS AND METHODS
The selection of parameters to be measured in the monitoring program was based on a number of considerations.
The Florida Keys National Marine Sanctuary and Protection Act specified that a water-quality monitoring program
be designed to monitor the status and trends in water quality and biological resources, particularly coral reefs,
seagrass communities, and mangroves, within the Sanctuary. Specific guidance on program priorities was taken
from the Phase I document and workshop problem statements. The Core Working Group of the FKNMS also
provided a prioritized (though subjective) ranking of the sources of pollutants in the Sanctuary based on known,
suspected, or potential effects on natural resources. Nearfield sources of nutrients and both nearfield and farfield
sources of toxics were judged to be the pollutants of most concern. In addition, recommendations from the FKNMS
Research Planning Workshop (Harwell 1991) were examined to develop a more complete list of parameters.
Literature was reviewed and technical experts were consulted to determine the appropriate methodologies to employ
to measure the parameters. The preliminary list of parameters and recommended methods were then presented for
discussion during the Monitoring and Research Workshops.
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The selection of sediment quality and biological body burden jjaramete*s was based on postulated nearfield and
farfield pollution sources. Hie specific compounds were identified through available literature and by consultation
with the Monroe County Mosquito Control District, the Florida Cooperative Extension Office, and the NOAA
National Status and Trends Program.
In the Monitoring and Research Workshops, experts discussed the preliminary parameter and methods list. The
experts recommended that a number of standard water quality measurements not be measured because of their lack
of utility in the Keys environment or redundancy. These parameters included silicate, total suspended solids (TSS),
Secchi disk depth, chlorophyll b and c, sediment porosity, and particulate nitrogen and phosphorus. Based on the
recommendations, a final parameter and methods list was developed and is presented in Sections 6.0 and 7.0.
5.8 ANALYTICAL METHODS
The choice of analytical methods is an important concern in the monitoring program. In particular, there has been
some debate about the appropriateness of using "oceanographic" rather than "regulatory" (i.e., EPA) methods to
measure nutrient concentrations in the oligotrophic waters of the Florida Keys.
Standard EPA methods for nutrients that were developed for use in freshwater and wastewater, have levels of
detection or applicable ranges that are higher than what is found naturally in the Florida Keys (Table 6-1). The
monitoring program incorporates the use of "oceanographic" methods that have detection limits lower than natural
concentrations found in FKNMS waters. Generally, the proposed methods are analytically similar to EPA methods
but are optimized to improve the detection limits (Appendix B). To ensure that the methods used in the monitoring
program will allow the detection of changes in conditions, performance criteria for each parameter are specified in
Appendix B. The specified performance criteria will ensure that the methods used are sensitive enough to detect
anthropogenically-induced changes above the background levels of natural variability. A quality assurance (QA)
program (Section 9.0) will be instituted to specify and document the quality control (QC) procedures required to
ensure the scientific soundness and success of the monitoring effort.
Much of the discussion during the workshops centered on nutrients and their measurement; less attention was paid
to the measurement of toxics. However, there was general agreement that, as with the nutrient analyse, analytical
methods for toxics, including heavy metals and pesticides, employ methods appropriate for the environmental
conditions. As appropriate, NOAA National Status and Trends Program methods or other suitable methods were
selected for incorporation, rather than using EPA-approved methods that are based on requirements for analysis of
solid wastes. The NOAA National Status and Trends Program takes a performance-based rather than a
protocol/methods-based approach in the analytical program. The satisfaction of performance standards is monitored
and documented in QA plans and in an annual program-wide intercalibration exercise among participating
researchers and laboratories. All participating contract laboratories analyze sets of "unknowns" of sediment and
tissue samples prepared by expert laboratories (U.S. National Institute of Science and Technology and National
Research Center of Canada) (A. Cantillo, NOAA, personal communication, 1992).
6.0 WATER QUALITY STATUS AND TRENDS MONITORING
6.1 OVERVIEW
Table 6-2 summarizes sampling types, locations, frequency, and parameters for the water quality status and trends
monitoring program. The program includes
•	Collection and analysis of water samples from nearshore/offshore waters and confmed waters near
pollution sources (hot spots)
•	Continuous monitoring of water-quality parameters at selected locations
6-8

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Table 6-1. Comparison of detection limits of EPA-approved and
routine oceanographic analytical methods for nutrients.
Parameter
Detection
Detection Natural Range
Natural Range Natural Range
Proposed

Limit,
Limit, (R. Jones, FIU
(Ogden 1991) (Lapointe and
Method

EPA
Oceanographic pers. comm.,
Clark 1990)


Methods
Methods 1992)



(EPA 1979a)



Ammonium 1.6
Nitrate + nitrite 1.6 pM
Nitrite
Phosphate
Total nitrogen 14 pM
0.1 filA
0.01 nM
0.32 (M 0.01 /iM
2 nM	0.02 nM
1.4 /iM
0.020-10000 0.15-1.0/aM UD-5.75/iM Indopheaol
fiM
0.01-33 fiM 0.25-2.5 (tM UD-5.77|*M Diazo (after
Cd reduction)
0.01-1.5	NAV
NAV
Diazo
Total phosphorus 1.4 /iM 0.03
Chlorophyll a NA	NA
0.01-1	0.08-0.20.05-0.6	Ascorbic acid
2-75 nM	12.5-35/iM	2-18.2	High
Total N	temperature
combustion
0.1-3 /iM	0.5-2.5	0.1-2.85 /*M	Ignition w/
Total P	MgS04
0.1-3/ig/L	0.15-1.0/ig/L	0.1-4.53/xg/L	Fluoromet
UD: Undetected.
Total N: Total nitrogen.
Total P: Total phosphorus.
NA: Not applicable.
NAV: Not available.
6-9

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Table 6-2. Water quality status-and trends monitoring.
Sample Type
Sampling Locations
Sampling
Frequency
Parameters
Notes
WATER (discrete
sampling times)
Minimum 4
transects/segment; distances
of 10 m, SO m, 100 m,
250 m, 500 m, 1 km, 5 km,
10 km (plus 15 km, 20 km,
30 km in certain cases) from
shore or U.S. 1; samples at
mid-depth for stations < 3 m
deep; samples at 0.5 m
below the surface and 1 m
above bottom for stations
3-5m deep; 0.5 m below the
surface, mid-depth, and 1 m
above bottom for stations
> 5 m deep; plus sampling
near known/suspected
pollution sources (hot spots)
Every 6 weeks for
~earshore/offshore
waters; quarterly
on a rotating
schedule for hot
spots
Profiles:
Temperature,
salinity, DO, pH,
and PAR.
Discrete water
samples:
Nutrients,
chlorophyll a,
alkaline
phosphatase, and
turbidity.
WATER (continuous
observations)
Most central transect in each
segment; distances of 50 m,
1 km, 10 km
Continuous (by
using in situ
instrumentation)
Temperature,
salinity, DO, and
PAR
Continuous
observations will
be considered for
seagrass monitor-
ing stations
SEDIMENT
Same as for water samples
Single survey only
(unless data
warrant more
sampling)
Grain size,
mineralogy,
organic matter
content, heavy
metals,
tributyltin,
pesticides, PCBs,
petroleum
hydrocarbons,
and coprostanol
Coprostanol and
tributyltin ana-
lyzed at selected
stations only
ORGANISMS (tissue
samples)
Selected hard-bottom and
seagrass monitoring stations
Single survey only
(unless data
warrant more
sampling)
Body burdens of
heavy metals,
tributyltin,
pesticides, and
PCBs
Organisms include
corals, seagrasses,
macroalgae,
sponges, bivalves,
crustaceans, and
fish
6-10

-------
*	Collection and analysis of sediments to obtain integrated measures of toxics
*	Collection and analysis of representative organisms to estimate body burdens of toxics
Different sampling schemes will be used for status and trends monitoring in (1) nearshore/offshore waters and
(2) confined waters near pollution sources (hot spots). For nearshore/offshore waters, the Sanctuary will be
stratified based on the segmentation scheme presented in Figure 6-1. Within each segment (except for Segment 4),
stations will be located on transects that extend from nearshore to at least the offshore boundary of the Sanctuary.
Transect positions will be randomized to insure that representative water quality samples are obtained. In segments
where passes occur (e.g., Segment 7), transect placement will also be stratified relative to the passes and land
masses.
Nearshore and offshore waters will be sampled during the 5-year baseline monitoring period to gather representative
data to determine the status and trends in water quality, to examine gradients associated with distance from the
land mass. Water-quality measurements will be made and water samples will be collected at monitoring stations
at six-week intervals. In addition, water-quality measurements will be collected at selected stations using
continuously recording in situ instrumentation. This instrumentation will be maintained through the 5-year baseline
period to gain information concerning phenomena that have periods shorter than six weeks and infrequent or
unpredictable phenomena, such as storms and hurricanes.
Confined waters near pollution sources (hot spots) will be sampled quarterly on a rotating schedule. After 4 years,
each hot spot will have been sampled four times, each during a different quarter of the year (see Section 6.2.2).
This effort is less intensive than the nearshore and offshore sampling, based on the consensus of the expert panel
assembled for the July 1992 Monitoring/Research Workshop. It was the panel's opinion that degradation near
known pollution sources was well known and that extensive sampling was not necessary.
A suite of water-column parameters will be measured at ซ"*h station. These water column parameters include
physico-chemical parameters (temperature, salinity, dissolved oxygen (DO). pH. turbidity, and photosynthetically I
active radiation [PAR]), nutrients (dissolved ammonia, nitrate, nitrite, and phosphate; total nitrogen (TN) and total
dissolved nitrogen (TDN); total phosphorus (TP) and total dissolved phosphorus (TDP); and organic/inorganic
carbon), and biological parameters (chlorophyll a and alkaline phosphatase activity (APA]).
Some toxic compounds tend to be present in water samples in extremely low or undetectable quantities. However,
these compounds are detectable in sediment and tissue samples because they are associated with particulate material
or are bioconcentrated. Sediment and tissue concentrations can serve as time-integrated measures of the exposure
of the water to these compounds. To address the status of these compounds, during the initial baseline survey
sediment samples will be collected and analyzed for heavy metals, tributyltin, pesticides, PCBs, petroleum
hydrocarbons, and a sewage tracer (coprostanol). In addition, tissue samples will be collected and analyzed for
heavy metals, tributyltin, pesticides, and PCBs. If the results from these analyses indicate that more sampling is
needed, then the sampling program will be modified accordingly.
6.2 SAMPLING LOCATIONS
(.2.1 Nearshore/OfTshore Waters
Water quality sampling stations for determining the status and trends in nearshore and offshore waters will be
located on onshore-offshore transects (with the exception of Segment 4 as discussed below). The location of
transects in the segments are presented in Figure 6-2. To provide comprehensive coverage of the Sanctuary, a
minimum of four transects will be located within each segment. Transects will vary in length depending on the
distance to the Sanctuary boundary, but each will be at least 10 km long. The exception to this length are three
transects in Segment 8, where portions of the transects occur over the Florida mainland (Figure 6-2). To ensure
a broader coverage of the transects within segments, each segment will be divided into approximately equal
subsegments, with one transect randomly located within each subsegment. This method of randomization ensures
6-11

-------

-------
SEE INSET FIGURE
(SEGMENT 4)
ATLANTIC
OCEAN
ซTRANSECT
	= ARBITRARY TRANSECT EXTENSION
• -SAMPLING LOCATION (SEGMENTS
1. 2, AND 4)
S 10 IS 20 NAUTTCM. MLฃS
10	20	30 40 K10METCRS
82*30"
	I	
81W
I
80*30"
6-1)
Figure 6-2. Locations of water quality sampling sites in Segments 1, 2, and 4 and water quality
transects in Segments 3, 5, 6, 7 ,8, and 9. Sampling site locations on water quality transects
are presented in Table 6-3.

-------
that transect' will be more uniformly spread over each segment than if a purely random method had been used.
The design robust relative to periodic phenomena that could potentially occur along the segment. Where
appropriate, transect locations will be stratified based on land mass and passes. The number of transects allocated
between land mass and pass areas will be based on the percent contribution to these two strata in a particular
segment.
A minimum of eight stations will be located on each transect. Stations will be located on the transects in a manner
to insure that representative results are obtained and that the gradient of water quality from the land mass to offshore
areas can be observed. Stations will be equally spaced along each transect for the two oceanic segments (Segments
1 and 2 in Figure 6-1). For the segments associated with the Florida Keys land mass (except Segment 4 in
Figure 6-1), one station will be located at 10 m from the mean low water line. Seven stations will be located
nominally at the following distances from shore (or U.S. 1, in the case of passes): SO m, 100 m, 250 m, 500 m,
1 km, 5 km, and 10 km. To overcome bias inherent in arbitrarily selecting stations, locations were randomized
following Cochran (1963) for systematic sampling. Distances between these seven stations will be fixed on
individual transects. The 50-m station will be randomly located between 25 and 100 m from shore, based on a
random draw from a uniform distribution. This randomization makes the design robust relative to potential
phenomena that are periodic relative to the shore. Additional stations were added to the offshore end of transects
(15 km, 20 km, and 30 km), if necessary, to reach the boundary of the Sanctuary. Station locations on the transects
are presented in Table 6-3. For Segment 4, stations are randomly located within the marine areas (Figure 6-2).
If the depth at a station is less than 3 m, water samples will be collected at mid-depth between the sea surface and
seafloor. At stations 3-5 m in depth, samples will be collected from 0.5 m below the surface and 1 m above the
bottom. At stations deeper than 5 m, an additional sample will be collected at mid-d;pth. Profiles of temperature,
salinity, DO, pH, and PAR will be performed at each station. Stations will be revisited at six-week intervals for
water quality sampling. Additional sampling efforts can be mobilized to respond i- episodic phenomena such as
storms and hurricanes.
Continuously recording instrumentation will be deployed at the 50 m, 1 km, and 0 km stations along the most
central transect in each segment. Information from these continuously recording u ;truments will serve to fill in
gaps between sampling visits. These data will be used to examine phenomena with . eriods shorter than six weeks
and episodic phenomena, such as storms.
6.2.2 Pollution Sources (Hot Spots)
Water quality will be monitored in confined waters that are suspected or known to be severely degraded (hot spots)
to determine the status and trends of pollution sources. These hot spots include outfalls from sewage treatment
plants, canals, landfills, marinas, and live-aboard areas. Each of these 103 hot spots have been assigned randomly
to one of four groups (Table 6-4). Sampling of each group will occur at quarterly intervals over the first 4 years
of the baseline study. The sampling period (quarter) for each group will be rotated so that each group will be
sampled during each of the four quarters. This sampling strategy is as follows:
r—^			
Quarter of Sampling for the Four Groups of Hot Spots
Hot Spot Group
Year of Baseline Period
Year 1
Year 2
Year 3
Year 4
1
1st Qtr.
2nd Qtr.
3rd Qtr.
4th Qtr.
2
2nd Qtr.
3rd Qtr.
4th Qtr.
1st Qtr.
3
3rd Qtr.
4th Qtr.
1st Qtr.
2nd Qtr.
4
4th Qtr.
1st Qtr.
2nd Qtr.
3rd Qtr.
6-14

-------
Table 6-3. Locations of stations on transects in Segments 3, S, 6, 7, 8, and 9
(Transect locations are presented in Figure 6-2).
Transect		Station Location on Tranw^ the following nominal distances (m from starting point)
10 50 100 250 500 1,000 5,000 10,000 15,000 20,000 30,000
3-1
10
28
78
228
478
978
4,978
9,978
14,978


3-2
10
55
105
255
505
1.005
5,005
10,005
15.005
	
	
3-3
10
52
102
252
502
1.002
5,002
10,002
15,002
	

3-4
10
53
103
253
503
1.003
5,003
10,003
15,003
	
_
3-5
10
29
79
229
479
979
4,979
9,979
14,979
	
_
3-6
10
45
95
245
495
995
4,995
9,995
14.995
_
	
3-7
10
51
101
251
501
1.001
5,001
10,001
15,001
—
—
5-1
10
65
115
265
515
1.015
5,015
10,015
15,015
20,015

5-2
10
60
110
260
510
1.010
5,010
10,010
15,010
20,010
_
5-3
10
31
81
231
481
981
4,981
9.981
14,981
19,981

5-4
10
55
105
255
505
1,005
5,005
10,005
15,005
20,005
_
5-5
10
65
115
265
515
1,015
5,015
10,015
15,015
20,015
	
5-6
10
58
108
258
508
1,008
5,008
10,008
15,008
20,008
	
5-7
10
40
90
240
490
990
4,990
9,990
14,990
19.990
	
5-8
10
74
124
274
524
1.024
5,024
10,024
15,024
20,024
	
5-9
10
34
84
234
484
984
4,984
9,984
14,984
19,984
—
6-1
10
58
108
25B
508
1,008
5,008
10,008
15,008
20,008
30,008
6-2
10
51
101
251
501
1,001
5,001
10,001
15,001
20,001
30,001
6-3
10
54
104
254
504
1,004
5,004
10,004
15,004
20,004
30,004
6-4
10
25
75
225
475
975
4,975
9,975
14,975
19,975
29,975
6-5
10
72
122
272
522
1,022
5,022
10,022
15,022
20,022
30,022
7-1
10
41
91
241
491
991
4,991
9,991
14,991

mmmm
7-2
10
74
124
274
524
1,024
5,024
10,024
15,024
_
_
7-3
10
41
91
241
491
991
4,991
9,991
14,991
_
	
7-4
10

76
226
476
976
4,976
9,976
14,976
_
	
7-5
10
34
84
234
484
914
4,984
9,984
14.984


7-6
10
l
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Table 6-4. Group designations of confined water sites with known
or suspected severely degraded water quality.
Location
Pollution Source
Group
Cow Key Channel
Islamorada
Matecumbe Harbor
Pine Channel
Kampgrounds of America Marina
Ocean Reef Marina
Campbell's Marina
Marathon Seafood
Wink en, Blynken, and Nod
Dispatch Creek
Alex's Junkyard
Key West Landfill
Doctor's Ann
Gulfrest Park
Hammer Point
Key Colony Subdivision
Marian Park
Orchid Park Subdivision
Port Pine Heights
Rock Harbor Estates
Tamarac Park
Treasure Harbor
Venetian Shores
Coco Plum Beach
Boat live-aboards
Boat live-aboards
Boat live-aboards
Boat live-aboards
Boat-related activities
Boat-related activities
Boat-related activities; live-
aboards
Boat-related activities: live-
aboards
Boat-related activities; live-
aboards
Canal configuration; H2S
groundwater intrusion
Hazardous waste site
Landfill
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS; Boat-related activities
6-16

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Table 6-4. Group designations of confined water sites with known
or suspected severely degraded water quality, (continued)
Location	Pollution Source	Group
Safe Harbor
Seafood processing; commercial
and industrial development;
Stock Island Power Plant
1
Outdoor Resorts of America
Trailer park with RV camping
1
Boot Key Harbor
Boat live-aboards
2
Carsound Bridge
Boat live-aboards
2
Garrison Bight
Boat live-aboards
2
Mile Marker 84.5, Bayside
Boat live-aboards
2
Plantation Yacht Harbor
Boat-related activities
2
Sea Camp
Boat-related activities
2
Key Largo Fishery Marina
Boat-related activities; live-
aboards; seafood processing
2
Faro Blanco Marina
Boat-related activities; live-
aboards
2
Key Colony Beach STP Outfall
Discharge to surface waters
2
U.S. Navy Base WWTP
Discharge to surface waters
2
Key Largo Landfill
Landfill
2
Bay Point Subdivision
OSDS
2
Blue Water Trailer Park
OSDS
2
Conch Key
OSDS
2
Cross Key Waterways Subdivision
OSDS
2
Cudjoe Ocean Shore
OSDS
2
Pirate Cove Subdivision
OSDS
2
Porpoise Point
OSDS
2
Port Antigua
OSDS
2
Port Largo
OSDS
2
Sands Subdivision
OSDS
2
Sea-Air Estates
OSDS
2
Seaside Resort
OSDS
2
6-17

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Location
Sugar Loaf Shore Subdivision
Ming Seafood
Venture Out Trailer Park
Cross Key
House Boat Row
Key Colony Beach
Worlds Beyond (Carysfort Manna)
Sunshine Key Marina
Bonefish Towers Marina
Caloosa Cove Marina
Winner Docks
C-lll Canal
Navy/Coast Guard Marina and Trumbo Point Fuel
Storage Facility
Truman Annex Marina
Long Key Landfill
90th Street Canal
Breezeswept Beach Estates
Cudjoe Gardens Subdivision
Eden Pines Colony
Indian Waterways
Knight Key Campground
Long Key Estates and City of Layton
Riviera Canal
Sexton Cove Subdivision
Group
OSDS	2
Seafood processing	2
Surface discharge from STP
Boat live-aboards
Boat live-aboards
Boat live-aboards
Boat-related activities and
OSDS
Boat-related activities
Boat-related activities; live-
aboards
Boat-related activities; live-
aboards
Boat-related activities; live-
aboards
Canal discharge
Fueling related operations
Fueling related operations
Landfill
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
Table 6-4. Group designations of confined water sites with known
or suspected severely degraded water quality, (continued)
Pollution Source
6-18

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Table 6-4. Group designations of confined water ~s with known
or suspected severely degraded water quality .ontir.ued)
Location
Tropical Atlantic Shores Subdivision
Tropical Bay
Whispering Pines Subdivision
White Martin Beach
City Fish Market
Boca Chica Gunnel
Christmas Tree Island
Community Harbor
Largo Sound
Holiday Isle Resoit
Sugar Loaf Lodge Marina
Oceanside Marina
Faro Blanco Oceanside Marina
Phase I
Key West Sewage Treatment Plant Outfall
Cudjoe Key Landfill
Submarine Pens
Bahia Shores
Boca Chica Ocean Shores
Cahill Pines and Palms
Coral Shores Estates
Cutthroat Harbor Estates
Jolly Roger Estates .
Key Haven Subdivision
Lake Surprise Subdivision
Lower Matecumbe Beach
Pollution Source	Group
OSDS
OSDS
OSDS
OSDS
Seafood Processing
Boat live-aboards
Boat live-aboards
Boat live-aboards
Boat live-aboards
Boat-related activities
Boat-related activities
Boat-related activities; live-
aboards
Boat-related activities; live-
aboards
Canal configuration; H2S
groundwater intrusion
Discharge to surface waters
Landfill
Naval base related activities
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
OSDS
6-19

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Table 6-4. Group designations of confined water s tes with known
or suspected severely degraded water quality, (continued)
Location	Pollution Source	Group
Pine Gunnel Estates	OSDS	4
Plantation Key Colony	OSDS	4
Summerland Key Cove	OSDS	4
Summerland Key Fisheries	Seafood processing	4
OSDS: On-site sewage disposal system.
RV: Recreational vehicle.
STP: Sewage treatment plant.
6-20

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Water quality samples will be collected as near to sewage treatment plant outfalls as practical. In marinas, a station
will be established in the center of the marina. Similarly, a station will be established in the center of live-aboard
areas not associated with marinas. In canal systems surrounded by subdivisions, mid-length and dead-end locations
in a representative canal in each canal system will be sampled. Sites near landfills will be located in marine waters
as near to the landfill as possible.
6.3 PARAMETERS AND METHODS
6.3.1 Water Quality — Periodic Monitoring
To characterize the spatial patterns and temporal trends in water quality conditions within the Sanctuary, the
following parameters will be measured.
Physico-chemical parameters
•	Temperature
•	Salinity
•	DO
•	pH
•	PAR
•	Turbidity
•	Depth
Nutrients
•	Dissolved ammonia
•	Dissolved nitrate, nitrite, and phosphate
•	TN and TDN
•	TP and TDP
•	Organic/inorganic carbon
Biological parameters
•	Chlorophyll a
•	APA
This suite of physico-chemical parameters was selected to characterize the environmental regime. Additionally, the
parameters can potentially affect the growth and survival of biological resources. The nutrient parameters are
measured because their levels can be affected by anthropogenic sources of nutrients. The nutrient parameters are
related to the biological parameters (e.g., chlorophyll a). The biological parameters (chlorophyll a and APA) are
measured as indicators of nutrient status in the system.
Except for nutrient forms in the particulate fraction (which is usually estimated by difference), the suite of nutrient
parameters to be measured in this program is comprehensive. These measurements are intended to provide the
nutrient status of nearshore and offshore waters and to track the surface transport of nearshore waters to offshore
areas.
Nitrite is generally found in low concentrations in the open ocean environment and may not be of immediate value.
However, this measurement is readily available because it is routinely performed whenever analyses of dissolved
inorganic nutrients are made using automated continuous flow methods. The nitrite concentration may be important
in areas where leachate from landfills or sewage discharge is suspected. Similarly, chlorophyll measurements in
open ocean environments are generally low. They are being measured in this program primarily as a "tracer" of
more eutrophic nearshore waters that may be transported to offshore reef areas. Chlorophyll a,'along with turbidity
and temperature measurements, also are important to provide calibration for remote sensing data.
6-21

-------
Only a general description of the parameters and methods is presented here. Detailed protocols for those anal; tical
methods that are not EPA-approved are included in Appendix B. In particular, detailed analytical protocols are
presented for nutrient determinations because routine oceanographic, rather than EPA-approved, analytical methods
are recommended.
A multi-sensor, water-quality monitoring instrument, the Hydrolab H20, will be used to measure basic
physico-chemical parameters in the field. This particular instrument is recommended for the following reasons.
•	Hydrolab also manufactures the Datasonde III (an H20 with datalogging capabilities and an internal
battery pack) — a cost-effective environmental monitoring instrument package.
•	The current Coastal Marine Automated Network (CMAN) system uses Hydrolab units.
•	The current ENP, BNP, and Dade County Department of Environmental Management (DERM)
monitoring programs use Hydrolab instruments.
•	EPA's EMAP has adopted the Hydrolab as its primary water-quality monitoring instrument.
Although other instruments may provide better performance, the workshop panel agreed that the Hydrolab
equipment would be adequate for the monitoring program. Field measurements to be made with the Hydrolab H20
include temperature, salinity, DO, pH, and depth.
A light extinction coefficient will be determined by measuring the attenuation of PAR at depth using underwater
quantum sensors (see Appendix A). The physico-chemical parameters will be measured at the surface and at depth
as described in Appendix A. At depths greater than 3 m, continuous profiles will be made. Water samples will
be collected using a Niskin sampler and analyzed for turbidity, nutrient content, and biological parameters. Nutrient
parameters to be analyzed primarily by autoanalyzer include dissolved ammonium, dissolved nitrate, dissolved
nitrite, TDN, TN, soluble reactive phosphorus, TDP, TP, and organic/inorganic carbon.
Dissolved nutrients will be defined using Whatman GF/F filters with a nominal pore size of 0.8 fim. Ammonium
will be analyzed by the indophenol method (Koroleff 1983). Nitrite will be analyzed using the diazo method and
nitrate will be measured as nitnte after cadmium reduction (Grassoff 1983a,b). The ascorbic acid/molybdate method
will be used to determine dissolved phosphorus (Murphy and Riley 1962). High-temperature combustion or
persulfate digestion will be used to measure total and TDN and phosphorus (Sol6rzano and Sharp 1980a.b: Walsh
1989). Organic/inorganic carbon will be determined using the high-temperature combustion method of Sugimura
and Suzuki (1988). Detailed protocols are presented in Appendix B.
Samples will be analyzed for chlorophyll a content by fluorometry of acetone extracts (Yentsch and Menzel 1963).
The degree of phosphate limitation in the water column will be estimated using an assay of APA (R. Jones, Florida
International University, personal communication, 1992). Protocols are presented in Appendix B for chlorophyll
a and APA.
6.3.2 Water Quality — Continuous Monitoring
The periodic monitoring conducted every six weeks will provide information on a certain level of variability in water
quality parameters. An important and crucial source of variability in water quality conditions are periodic and
episodic phenomena that have time scales of hours to days or weeks. These phenomena are related to diumal
cycles, tides, storm events, wind events, and regional and local current patterns that greatly affect water quality and
biological resources. A continuous, water-quality monitoring network will be set up to account for the variability
associated with periodic phenomena and to ensure,that the variability caused by episodic and stochastic events can
be captured. This network will supplement data from the CMAN system developed by the SEAKEYS program
(Ogden 1991).
The CMAN system currently includes four monitoring stations located at Fowey Rocks, Molasses Reef, Sombrero
Reef, and Sand Key (Figure D-3, Appendix D). The CMAN stations are associated with the-National Data Buoy
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Center towers and provide near real-time meteorological and water quality information. Two additional CMAN
sites are scheduled to be installed in 1992 (one in Florida Bay near Long Key and one at Iowa Rock, Dry Tortugas).
In addition, Hydrolab units are deployed in several areas around the Keys (Figure D-3, Appendix D) to measure
temperature, salinity, depth, and DO.
Continuous instrumentation will be deployed at the SO m, 1 km, and 10 km stations along the most central transect
in each segment of the FKNMS. The instrumentation will consist of the following:
•	A water-quality sensor package (Hydrolab Datasonde III/H20) with probes for temperature,
conductivity/salinity, depth, and DO
•	Two PAR sensors (Licor quantum sensors), one mounted at 1 m above the bottom and another 0.5 m
higher
•	A datalogger (Campbell Scientific CR10 or Licor) and power supply
In addition, similar continuous monitoring equipment will be considered for deployment at selected seagrass
monitoring sites. Continuous water quality data is expected to be available from coral reef locations through the
existing CMAN system.
6.3.3 Water Quality — Remote Sensing
Advanced very high resolution radiometer (AVHRR) and Sea-Viewing Wide Field of View Sensor (SEAWIFS)
imagery will be used to provide synoptic and temporal coverage of temperature, turbidity, and chlorophyll a
distributions in the Sanctuary that are unattainable by field sampling. Regional satellite coverage capable of
providing synoptic water color to assess regional trends in turbidity and chlorophyll will be collected on a near
realtime basis. AVHRR sensors can provide daily images in the visible spectrum; temperature ranges and turbidity
distributions also can be generated. After SEAWIFS is launched in the summer of 1993, data from the satellite can
be used to generate turbidity and chlorophyll a distributions. In addition to the collection of this satellite imagery,
a calibration station for the satellite sensors will be established at the Florida Keys Marine Laboratory (Long Key)
in conjunction with the C-MAN station (K. Haddad, FDNR Marine Research Institute, personal communication,
1992). Data collected during the periodic water-quality monitoring also will be used for image calibration.
6.3.4 Sediment Quality
Because of the discharge of wastewater and stormwater, presence of boat yards, and marinas (petroleum spills and
boat bottom painting) and landfills near marine waters, and the use of pesticides (mosquito spraying) and herbicides
(road right-of-ways), certain parameters were selected for analysis in sediments. Sediment samples will be collected
only once during the initial baseline period (Table 6-2) to provide an overall evaluation of the status of the sediment
quality in the Sanctuary. This evaluation includes basic sediment parameters and toxic constituents. The basic
sediment parameters are measured to provide a means of normalizing the concentrations of toxic constituents so they
can be interpreted properly.
These parameters are
Basic sediment parameters
•	Organic matter
•	Grain size
•	Mineralogy
Heavy metals
•	Copper
•	Lead
•	Zinc
•	Cadmium
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•	Aluminum
•	Mercury
•	Chromium
•	Arsenic
Tributyltin
Pesticides
•	Insecticides from mosquito spraying
•	Fenthion (Baytex)
•	Cythion (Malathion)
•	Pennethrin (Biomist)
•	Methoprene (Altosid)
•	Naled (Dibrom)
•	Right-of-way control and agricultural herbicides
•	Triclopyr
•	Hexazinone
•	Sulfometuron-methyl
•	Glyphosate
•	2,4-D
•	Paraquat
•	Atrazine
•	Persistent pesticides
•	DDT and breakdown products
PCBs
Petroleum hydrocarbons
Sewage tracers
•	Coprostanol
A brief description of methods is provided below while more detailed methods for the determination of heavy
metals, tributyltin, pesticides, PCBs, petroleum hydrocarbons, and coprostanol are presented in Appendix B. The
methods are primarily based on the NOAA National Status and Trends Program.
If possible, sediments will be collected by scuba divers using hand cores. In water depths precluding diver
collection, a Smith-Mclntyre grab sampler will be used. Sediments collected by grab sampler will be subsampled
by using hand cores in the field. The top 2 cm of each sediment core sample will be retained for analysis. Acetyl
butyrate cores will be used for the basic sediment parameters, tributyltin, and heavy metal samples. Teflon cores
will be used for pesticide, petroleum hydrocarbon, PCBs, and coprostanol samples. Basic sediment parameters such
as organic matter content, grain size distribution, and mineralogy will be determined in the subsamples. Organic
content will be measured gravimetrically, grain size distribution by the hydrometer method, and mineralogy by
X-ray diffraction. Heavy metals will be analyzed by flame atomic absorption spectrophotometry (FAAS) of acid
digests. Petroleum hydrocarbons will be determined by gas chromatography (GC) with a flame ionization detector
(FID) of methylene chloride extracts. Tributyltin concentrations in sediments will be determined by GC with flame
photometric detection of methylene chloride/toluene with 0.05% tropolone extracts. Pesticides will be analyzed
primarily by GC with electron capture detectors (ECD) of methylene chloride/hexane extracts. Coprostanol
concentrations in sediments will be determined by GC/FID of methylene chloride/hexane extracts.
6.3.5 Biological Body Burdens
To estimate the presence and concentrations of xenobiotic substances in living organisms, samples from
representative producers and consumers (including corals, seagrasses, macroalgae, sponges, zooanthids, bivalves,
crustaceans, and fish) will be collected by scuba divers or traps. The samples will be obtained at biological resource
monitoring stations. Tissue sample collections will be made at each biological resource site and should include three
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to five species. ILese species should be representative of different phylogenetic categories and consistent for each
biological resource type (s grass, nearshore hard bottom and coral reef)- Actual species for tissue collection will
be selected at a workshop convened by EPA among participating researchers and laboratories. Each sample will
be analyzed for heavy metals, tributyltin, pesticides, and PCBs. Samples will be processed for analysis as described
in Appendix B.
6.4 DATA ANALYSIS AND INTERPRETATION
Hypotheses for nearshore and offshore water quality address temporal and spatial trends. Data collected during the
water quality status and trends monitoring will be evaluated to determine if there are changes in the water quality
parameters. This will necessitate separating natural variability (e.g., seasonal) from long-term treads. Spatial
variability, such as distance from shore, will also be assessed. Long-term trends in water quality will be related
to long-term trends in the biological resources. Relationships among water quality parameters measured during the
at situ sampling should be examined. If meaningful correlations among parameters are observed, then the possibility
of extrapolating tb the continuously recorded data should be examined.
The power associated with detecting various levels of change in water quality parameters was estimated. The
procedures of Dixon and Massey (1969) for paired data were used because stations will be reoccupied on successive
surveys. Dita for this analysis were provided by Dr. Alina Szmant from the Key Largo study site for Phase 1 of
the SEAKEYS project (Szmant 1991). At the Key Largo study site, Szmant sampled canal stations, inshore stations.
Hawk Channel stations. White Banks stations, and offshore stations. Canal stations were not considered in the
power analysis. An among-station variance estimate was computed for each of the remaining four groups of
stations, and a pooled variance estimate was computed by using the four station group variance estimates. This
pooled variance estimate was used in the power analysis. The results of the power analysis are presented in
Figure 6-3. Data collected during the baseline period should be evaluated to determine the power of the appropriate
analytical procedures and analyses used to detect trends.
7.0 BIOLOGICAL RESOURCE STATUS AND TRENDS MONITORING
The status and trends of biological parameters in hard-bottom, seagrass, and mangrove communities will be
monitored. Monitoring will include both in situ sampling (hard-bottom and seagrass communities) and remote
sensing (hard-bottom, seagrass, and mangrove communities). Table 6-5 provides an overview of sampling types,
locations, frequency, and parameters for each community type.
7.1 HARD-BOTTOM COMMUNITIES
7.1.1 Overview
During the 5-year baseline monitoring period, both offshore coral reefs and nearshore hard-bottom areas will be
sampled annually. Parameters to be measured include coral cover, diversity, growth, and recruitment; incidence
of bleaching and disease; octocoral abundance; sponge and macroalgal cover; and the abundance of Diadema, reef
fishes (sampled quarterly), and coralivores (e.g., bristleworras).
Monitoring locations for coral reefs will include existing study sites, additional sites suggested by panelists at the
Monitoring/Research Workshop, and randomly selected sites within the mapped strata from the FDNR/NOAA
remote sensing/mapping project. Monitoring locations for nearshore, hard-bottom areas will consist of randomly
selected sites within mapped strata and within each segment where hard-bottom communities exist.
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s
o>
c
to
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e
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Table 6-5. Biological resource status and trends monitoring.
Type of Sampling Sampling l-warintn
Sampling Frequeocy Parameters
Notes
HARD-BOTTOM
COMMUNITIES
Remote leasing .
In tint - offshore
coral reefs
SEAGRASS
COMMUNITIES
Remote sensing
Remote sensing
Qualitative swim-
over surveys
Photo/count
stations
In tiai - nearshore
bard bottom
Sanctuary-wide
Segments 1, 2, 3, 7, 9
(see Figure 6-1); includes
existing study siics, sites
suggested by workshop
panelist!. and randomly
selected sites in segments
5. 7,9
Randomly selected sites
in each segment
containing nearihore
hard bottom; stratified
using FDNR/NOAA
mapping categories
Sanctuary-wide
1 km photo-conidors in
each segment
Permanent study sites in
each segment; selected
randomly from FDNR/
NOAA remote sensing
maps
Permanent study sites in
each segment, as above
MANGROVE	Remote sensing
COMMUNITIES
Every 5-7 years
Annual
Annual
Every 5-7 years
Every 2 years
Bimonthly
Bimonthly
Productivity plots Permanent study sites in Quarterly
each segment, ss above
Faunal plots	Permanent study sites in Quarterly
each segment, as above
Every 5-7 years
Geographic extent of hard-
boaom communities (mapping
categories)
Coral species composition,
coral cover, growth, bleaching,
disease incidence; octocoral
abundance; sponge cover,
macroaigal cover, Diodema
abundance; fish abundance;
corslivore abundance
Same parameters as for coral
reefs (if applicable)
This is a repetition of the
ongoing FDNR/NOAA
remote sensing/mapping
project
FDNR/NOAA remote
—maps will be used to
generate the random site
locations
FDNR/NOAA remote
sensing msps will be used to
generate the random site
locations
Geographic extent of seagrass
communities (mapping
categories)
Geographic extent of sesgrass
communities (mapping
categories)
Extent of bottom covered by
sesgrasses snd mscroalgae;
species composition; die-off
conditions; recolonization by
Halodule: degree of epiphytism
Number of short shoots;
number of blades per lhon
shoot; number of new shoots,
frails, snd flowers: canopy
height; numbers of individuals
of cslcsrcous algse; presence of
fleshy algae
Above-ground standing crop
and productivity; leaf-area
index; below-ground standing
crop
Abundance, biomass, diversity,
etc. of sca|rass-associated
epifauna
Geographic extent of mangrove
communities
This is a repetition of the
ongoing FDNR/NOAA
remote sensing/mapping
project
FDNR/NOAA remote
senaing maps will be used to
generate the random site
locations
This is a repetition of the
ongoing Advanced Inventory
of Wetlands remote sensing/
mapping project
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7.1.2 Sampling Locations
7.1.2.1 NEARSHORE HARD-BOTTOM COMMUNITIES
Because nearshore hard-bottom communities have not been well studied and there is little previous information, a
stratified random design will be used to locate permanent sampling sites. Remote sensing maps being prepared by
the FDNR/NOAA will be used to define the strata, and three permanent sampling sites will be selected at random
within each stratum and within each segment of the Sanctuary. Based on the potential benthic communities to be
mapped by FDNR/NOAA (F. Sargent, FDNR, personal communication, 1992), monitoring should include areas
of sparse, moderately dense, and patchy distributions of nearshore hard bottom. The FDNR/NOAA mapping effort
is expected to be completed in December 1993 (K. Haddad, FDNR Marine Research Institute, personal
communication, 1992). If the maps are not complete by the time the biological monitoring is ready to begin, it will
be necessary to discuss alternative methods for site location. By using the remote sensing maps as a framework
for stratified random sampling, it should be possible to generalize findings from the sampling sites to the broad areas
of the Sanctuary.
7.1.2.2 CORAL REEFS
Coral reef monitoring locations will include existing study sites, sites suggested by panelists at the
Monitoring/Research Workshop, and randomly selected sites in segments 5, 7, and 9 (see Figure 6-1). The
continuation of existing sites will ensure that previous monitoring data are incorporated into the long-term database;
randomly selected sites will help to ensure that results can be generalized to the rest of the reef tract in each
segment.
Several existing sites for coral reef monitoring have been identified as being potentially appropriate. These include
sites at the Dry Tortugas (Bird Key Reef, Pulaski Shoal, Loggerhead Key, White Shoal, and Texas Rock), Western
Sambo, Looe Key, John Pennekamp Coral Reef State Park (Mosquito Banks and Basin Hill Shoals), Carysfort Reef,
Pacific Reef, and Triumph Reef. Final sites will be selected at a workshop convened by EPA among potential
participating researchers and laboratories. Sampling at these selected study sites will continue, but sampling
methods may need to be altered so that all sites are monitored to yield comparable data.
During the Monitoring/Research Workshops in July 1992, panelists discussed several other general areas of interest
for coral reef monitoring. Some of the areas discussed are already represented by existing monitoring sites and are
not considered further. Three additional study sites will be established at the Marquesas, Tennessee Reef, and
Molasses Reef .
In addition to the locations listed above, three study sites will be located randomly along the reef tract in each of
segments 5, 7, and 9. The purpose of these additional stations is to ensure that results can be generalized to the
reef tract in each segment. Coral reef stations will be located in all habitats represented at a particular study site
(e.g., back reef, reef flat, shallow and deep spur-and-groove, fore reef, and deep reef).
7.1.3 Parameters and Methods
Hard-bottom community monitoring will involve both remote sensing and in situ measurements. These methods
are described in general in this section. By agieement during the July 1992 Monitoring/Research Workshops,
specific methods and protocols will be developed and recommended by potential participating researchers and
laboratories in a workshop to be convened by EPA.
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7.1.3.1	REMOTE SENSING
Remote sensing techniques will be used to provide a broad area] coverage for monitoring the hard-bottom
community status and trends at the landscape level within the Sanctuary. After completion of the FDNR7NOAA
benthic mapping project, aerial photography of the FKNMS will be repeated every 5-7 years. Aerial photography
will be interpreted, ground-truthed, and digitized for entry into Geographic Information System (GIS) data layers.
GIS techniques will be used to determine the changes in hard-bottom community distribution and cover. The
information derived from remote sensing will be integrated with information from in situ monitoring to determine
significant patterns and trends.
7.1.3.2	IN SITU SAMPLING
In general, in situ sampling refers to data collected by diving. Parameters to be measured include coral species
composition, coral cover, growth, and recruitment; incidence of bleaching and disease; octocoral abundance; sponge
and macroalgal cover; and abundances of Diadema, reef fishes, and coralivores (e.g., bristleworms). Although the
objective is straightforward, there are many different approaches that can be taken. Methodological issues will need
to be resolved among the participating researchers and laboratories.
7.1.3.2.1 Benthos
Because of the difficulties in the comparability of data derived from different survey methods, a consensus among
the researchers and laboratories participating in the monitoring program will have to be reached during the workshop
as to the specific methods to use. If more than one survey method is to be used, an effort will need to be made
to calibrate existing data with future measurements. Some methods that could be used for conducting surveys of
hard-bottom communities (nearshore hard bottom and coral reefs) are listed in Table 6-6.
In general, in situ monitoring of hard-bottom communities will be conducted annually in selected study sites, using
primarily non-destructive sampling methods. Each study site will consist of an area of defined size wherein
monitoring will be conducted. Within each study site, a system of randomly located permanent quadrats and
transects will be demarcated. An initial survey of each selected study site will be conducted. These data will be
evaluated to determine community structure and sampling adequacy (e.g., species area curve). The length and
number of the permanent transects and the size and number of the permanent quadrats will be determined by
agreement among the participating researchers and laboratories.
Permanent plots and quadrats will be sampled to provide data on year-to-year variation in community level
parameters while minimizing or accounting for spatial variability associated with strict random sampling. In coral
reef sites, permanent plots will be measured by scuba divers for the following parameters:
•	Coral cover
•	Coral species composition
•	Coral growth/mortality
•	Incidence of diseases/morbidity
•	Black-band disease
•	White-band disease
•	Incidence of bleaching/loss of zooxanthellae
•	Octocoral abundance and species composition
•	Sponge cover and species composition
•	Macroalgal cover
•	Diadema and other echinoderm abundance
•	Coraiivore (e.g., bristleworm) abundance
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Table 6-6. Techniques that have been-used for coral reef surreys.
NON-PHOTOGRAPHIC METHODS
Line Transect Methods
Line transect methods include Continuous Recording Line Transect, Chain Transect, Linear Percentage Transect,
Line Intercept Transect Method, or Intersected-length Transect. Identify corals (or other taxa) falling directly below
a taut transect deployed across the reef and measure length of the line crossing each of the corals. May also run
secondary transects parallel to depth contours off a main traverse at regular or random intervals to more thoroughly
characterize community. Beginning and endpoints of transects can be permanently marked allowing indefinite
collection of data along specific transects for yearly comparisons (Dustan and Hal as 1987, Loya 1972, 1978; Dodge
et al. 1982; Jaap a aL 1989).
Transect/Quadrat Method
Quadrats are deployed at regular or random intervals along transects across or along the reef. All attached epifauna
or specific groups (e.g., turd and soft corals) are identified and counted within the quadrat. Quadrat may be
subdivided into smaller quadrats to facilitate identification/counting (Wheaton and Jaap 1988).
Point Centered Quadrant Method
Also known as Quarter Point and Point-auarter Methods. Method assumes the average abundance of corals and
other attached epi fauna can be determined by measuring the average distances from random points along a line or
from a randomly selected point to the centers of the nearest colony or individual organism in each of four quadrats
around the point (Dodge a aL 1982). Also measured are the length (longest dimension of the organism) and the
width (perpendicular to the length) of the organism.
PHOTOGRAPHIC METHODS
Belt Quadrat Method
Also known as Photographic Transect Method. A continuous set of photographs is taken along a transect line.
Photographs are taken with a camera and strobe system mounted to a camera mount/framer placing camera at a
specific distance from the seafloor. Photographs are analyzed at a later date for species identification, number of
colonies or individuals, and percent cover. If transect beginning and endpoints are permanently marked, data can
be collected indefinitely and year-to-year comparisons can be made (Goldberg 1973).
Photostation Quadrats
Quadrats are set up in specific locations and permanently marked with stainless steel stakes. The size of the
quadrats should be optimized relative to the habitat being sampled. A grid framework is placed over the quadrat
to allow repetitive photography of smaller subumts within the quadrat. A camera/strobe system similar to that used
for Belt Quadrat Method is then used to take photographs at a specific distance from the seafloor. Photographs are
analyzed at a later date for species identification, number, and percent cover. Comparisons can be made of data
collected from year to year (white and Porter 1985; Porter and Meier, in press).
Videocamera Data
Underwater videocamera data can be collected along all previously mentioned transects. Video data are valuable
in providing a permanent record of the transect when photographic data are not collected. Where photographs are
taken as the primary data set, the video can provide a different perspective when videocamera data are collected
with the camera in a nearly horizontal to 45 degree orientation to the bottom. Data may also be collected for future
analyses with yet-to-be-developed video image analysis techniques (Porter and Meier, in press).
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Methods for the measurement of the parameters listed above will use direct counts by scuba divers, measu.i~ *ots
using photostation quadrats, and video recordings of bottom cover along transects. In addition, a permanent record
of the bottom characteristics at each study site will be made with photographs taken from oblique angles. Each of
these methods will be standardized and adopted by participating researchers and laboratories prior to their use.
Randomly located quadrats and transects will also be measured annually for the parameters listed above to provide
better data on spatial variability. Quadrats and transects of standardized size and length will be used.
Collections of macroalgae from randomly located quadrats within each study site will also be made to determine
standing crop and carbon:nitrogen:phosphorus (C:N:P) ratios. Standing crop will be measured by gravimetric
techniques. Carbon ปnri nitrogen content will be measured in the subsamples by flash-combustion in a
carbon/nitrogen analyzer using National Bureau of Standards (NBS) standards. Phosphorus content will be
determined as TP by combustion in a muffle furnace with magnesium sulfate, and analysis of the residue for
orthophosphate will be determined by using the ascorbic acid method.
In nearshore hard-bottom sites, the increased dominance of soft corals and sponges will require modification of the
sampling effort, similar sampling techniques will be utilized to obtain the following parameters:
•	Octocoral cover and species composition
•	Sponge cover, size, and species composition
•	Scleractinian coral cover and species composition
•	Macroalgal cover and species composition
•	Vagile macro invertebrate abundance and species composition.
7.1.3.2.2 Nearshore Hard Bottom and Coral Reef Fishes
Scuba divers will conduct a census of fish populations within each study site. Randomly selected nodes within a
grid established in each study site will be used for performing visual censuses. These censuses will be conducted
quarterly. Various, non-destructive visual census techniques, as listed in Table 6-7, will be considered by
participating researchers and laboratories at the inception of the monitoring program. A standardized method and
detailed protocol will then be developed.
7.2 SEAGRASS COMMUNITIES
7.2.1 Overview
Seagrass communities will be monitored using both remote sensing and in situ sampling. Remote sensing surveys
of the entire Sanctuary will be conducted every 5-7 years, and surveys of 1 km "photo-corridors" in each segment
will be conducted every 2 years. For in situ sampling, a stratified random design will be used to locate permanent
study sites in each segment of the Sanctuary. Remote sensing maps currently in preparation by FDNR/NOAA will
provide the basis for stratification. The in situ monitoring will provide measures of population- and community-
level characteristics in the seagrass community, including seagrass cover, density, growth rate, standing crop, and
productivity. In addition, macroalgal cover and epiphytic and macroalgal standing crop will be estimated. Epifauna
associated with the seagrass community will also, be sampled. In situ sampling of the seagrass communities will
be performed bimonthly and quarterly (depending on the type of sampling).
Although there are no existing monitoring stations in the Sanctuary, stations do exist in Florida Bay (see
Appendix D). To allow comparison of data from the two areas, similar, methodologies will be used (Section 7.2.3).
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Table 6-7. Non-destructive visial census techniques for coral reef fishes.
Traditional Transect Method (Brock 1954)
A line of appropriate length (e.g., 75 m) is laid underwater and a scuba diver counts all the individuals of each
reef species that occur within 2 m of the line on either side of the line and any fish above the line. Data are
recorded on a prepared species list compiled from previous experience. The length of time for traversing the
transect is standardized (e.g., SO min)
Rapid Visual Technique (Jones and Thompson 1978)
A scuba diver conducts a census of fishes for a period of SO min while swimming in an irregular or random
pattern. The period is broken up into S, 10-min intervals and species that are present are noted on prepared
lists according to the intervals in which they are sighted. Abundance scores are compiled for each species.
Visual Fast Count (Kimmel 1985)
This method is similar to the Rapid Visual Technique except that the actual number of individuals are counted
during the initial 10-min period during which a species is sighted.
Stationary Visual Census Technique (Bohnsack and Bannerol 1986)
Fish occurring within an imaginary cylinder extending from the surface to the bottom within a radius of 7.S m
from the scuba diver and over a 5-min period are recorded by species and number of individuals on prepared
lists. The scuba diver selects random points within a study site in which to conduct a census. While facing
seaward and rotating in a clockwise direction, the scuba diver notes new species as they occur. Over the next
5-mm period, statistical data are collected for the species that occurred during the initial S-minute period; all
other species are ignored. The number of individuals and the minimum, maximum, and mean length for each
observed species are recorded.
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7.2.2 Sampling Locations
Based on the currently available information (which will be revised in the FDNR/NOAA mapping study), seagrasses
occur in all segments. Because the results of the FDNR/NOAA mapping study will not be available until December
1993, the actual locations of seagrass community monitoring stations cannot be determined at this time. If biological
monitoring is scheduled to begin before the results are available, it will be necessary to discuss alternative methods
for site location selection. Based on the potential benthic communities to be mapped by FDNR/NOAA (F. Sargent,
FDNR, personal communication, 1992), monitoring should include areas of contiguous (moderate and dense),
sparse, and patchy areas of seagrass distribution. Within each geographic segment, three stations will be randomly
located in each of these seagrass habitat (i.e., seagrass density) strata.
7.2.3 Parameters and Methods
The overall approach for monitoring seagrass communities will involve both remote sensing and in situ
measurements. The methods are described in general in this section; more detailed methods are presented in
Appendix C.
7.2.3.1 REMOTE SENSING
Remote sensing techniques will be used to provide broad areal coverage for monitoring seagrass community status
and trends at the landscape level within the Sanctuary. After completion of the FDNR/NOAA benthic mapping
project, biannual overflights will be conducted along three "photo-corridors" measuring I-km wide for each
segment. Aerial photography, using aerocolor film, a digital camera, or a multispectral scanner, will be centered
on seagrass monitoring transects. Surveys of the entire FKNMS will be conducted every 5-7 years. The aerial
photographs will be interpreted, ground-truthed, and digitized for entry into GIS data layers. G1S techniques will
be used to determine the changes in the seagrass distribution and cover within these "photo-corridors", and
comparisons will be made with other monitoring areas. The information derived from remote sensing will be
compared with information from in situ monitoring to determine significant patterns and trends.
7.2.3.2 IN SITU SAMPLING
The sampling techniques to be used in this monitoring program are based on the methodology currently used by
Robblee and Zieman in the ENP in Flonda Bay, primarily related to the seagrass die-off (J. Zieman, University
of Virginia, personal communication, 1992). The techniques include both rapid, qualitative visual assessments and
more tedious quantitative methods.
A range of in situ techniques will be used to monitor seagrass communities at randomly selected, permanent study
sites in each segment of the FKNMS:
• Swimover surveys (bimonthly)
Qualitative visual swimover surveys will be conducted by scuba divers at permanent seagrass study
sites to detect gross changes. The following parameters will be estimated:
•	Percent of bottom covered by seagrasses and algae
•	Percent composition by species for species with coverage greater than 10%
•	Species present with coverage less than 10%
•	Die-off status and conditions
•	Recolonization by Halodule
•	Degree of epiphytism: fleshy or calcareous
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•	Photo and count stations (bimonthly)
Photo and count stations will be established at each of the permanent study sites. Within each count
station, the following parameters will be measured:
•	Number of short-shoots for each seagrass species
•	Number of blades per short shoot
•	Number of new shoots, fruits and flowers
•	Canopy height
•	Number of individuals of calcareous algae and presence of fleshy algae
After the counts are made, 0.25 m2 quadrats centered within the count stations will be photographed
to provide a permanent visual record that can be used to calibrate rapid visual methods against
quantitative methods.
•	Productivity plots (quarterly)
Productivity plots will be established at each of the permanent study sites to obtain quantitative
measurements of seagrass standing crop, growth rate, and productivity, as well as epiphytic and
macroalgal standing crop. Above-ground productivity will be monitored in randomly selected 0.02 m2
plots using a modification of the leaf-marking method. Cores will be taken to estimate below-ground
standing crop.
•	Faunal plots (quarterly)
Randomly selected faunal quadrats at each permanent study site will be sampled quarterly using a
suction dredge to estimate the abundance, biomass, and community parameters of seagrass-associated
epifauna. Three to six quadrats measuring 0.2 m2 will be sampled for fauna in each study site.
Samples will be collected in a 3-mm mesh bag and sorted. All organisms collected will be identified
to the lowest taxonomic level possible and counted. Subsamples will be collected, dried, and weighed
to estimate biomass.
At selected study sites, water-quality parameters, including PAR attenuation, may be monitored using continuously
recording instrumentation. The deployment of continuous monitoring instrumentation will be considered after
examination of the water quality and seagrass community data for significant patterns. These methods may be used
when phenomena of interest occur at study sites.
7.3 MANGROVE COMMUNITIES
Distributions of mangrove communities in the FKNMS will be determined by remote sensing. Changes in mangrove
coverage will be determined by comparison of remote sensing surveys from different time periods. The initial
coverages will be determined from the results of the AfW project (K. Haddad, FDNR Marine Research Institute,
personal communication, 1992). Remote sensing surveys encompassing the FKNMS and adjacent areas will be
repeated every 5-7 years.
8.0 REMEDIAL ACTION MONITORING
Engineering and management/institutional alternatives will be considered to abate pollution in the FKNMS (Tasks
3 and 4). The effectiveness of these actions will be evaluated by remedial actipn monitoring. Examples are the
evaluation of alternative OSDS designs for nutrient removal and the installation of small, expandable WWTPs
utilizing advanced wastewater treatment in Marathon to serve an area of dense septic tank use where nearshore water
quality problems have been identified. Such remedial actions may have a relatively high priority because members
of the Core Working Group ranked nutrients as the most important water quality parameter for the Water Quality
Protection Plan. A pilot project may be undertaken to demonstrate the effectiveness of such actions on a limited
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scale before widespread adoption throughout the Florila Keys. A site-specific monitoring program would be
instituted as part of the pilot project to evaluate the effectiveness of the action in improving water quality.
Because specific actions have not been identified, details of a remedial action monitoring program cannot be
specified. The project should include sampling of the source, pathways of introduction into marine waters (e.g.,
groundwater), and FKNMS waters, including reference sites if possible. Sampling sites should be located in a
pattern sufficient to ascertain the pollution gradient with respect to the source. The program should begin prior to
implementation of the remedial action and continue until sufficient data are available to judge the effectiveness of
the action. Biological resources affected by effluents from the pollution source should be monitored to ascertain
the effectiveness of the remedial action.
9.0 QUALITY ASSURANCE/QUALITY CONTROL
QA refers to "those operations and procedures whiah are undertaken to provide measurement data of stated quality
with a stated probability of being right" (Taylor 1985). Simply stated, QA is the total integrated program for
assuring reliability of monitoring and measurement data. The requirement for establishing a QA program for the
water quality monitoring and research program is based on the EPA's policy and authority stipulated by the
Administrator of EPA in memoranda of 30 May and 14 June 1979. This policy and requirement not only covers
EPA organizations, but also monitoring activities supported or specified through contracts, grants, regulations or
other formal agreements. The policy also extends to states with cooperative programs implemented through EPA
regional offices.
In accordance with EPA policy, the FKNMS water-quality monitoring program will adhere to existing rules and
regulations governing QA and QC procedures as described in EPA guidance documents. Because the
implementation of the monitoring program will be a collaborative (cooperative) effort among several federal and
state agencies, academic and research institutions, and non-governmental organizations, a single QA plan will not
be developed at this time. It will be the responsibility of all participating entities to develop and submit for approval
a QA Project Plan (QAPjP) for their component of the program.
9.1 QUALITY ASSURANCE PROGRAM GOAL
The FKNMS QA program will be implemented to ensure that all data and information produced and used for
decision-making and resource management will be of known quality, scientifically valid and defensible, and
thoroughly documented. To achieve this goal, the program will use standardized and fully characterized methods
and procedures that will be validated for their intended use and rigorously followed. All data will be reported with
measures of quality (accuracy and precision). All non-standard or modified methods will be documented.
9.2 QUALITY ASSURANCE PROJECT PLANS
All federal and state agencies, academic institutions, and other non-governmental organizations that are funding
recipients or participants in the monitoring program will be required to submit a QAPjP prior to any work. For
any data to be accepted and utilized, a QAPjP'must have been submitted and approved. Through the QAPjP,
participants will explicitly commit to incorporating procedures that will reduce and maintain random and systematic
errors within specified tolerable limits (QC). In addition, they will document their QC procedures and evaluate the
quality of the data being produced. Plans should include or refer to a description of safety, training, and equipment
maintenance.
QAPjPs will be prepared according to the format prescribed in Guidance for the Preparation of Combined
Work/Quality Assurance Project Plans for Environmental Monitoring (EPA 1984) and Guide for Preparation of
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Quality Assurance Project Plans for the National Estuary Program (EPA 1988). Participating laboratories should
develop their QAPjP in close coordination with the EPA Region IV QA section and the Florida Department of
Environmental Regulation (FDER) QA section tj n.inimiz<; delays in the process. The Handbook for Analytical
Quality Control in Water and Wastewater Laboratories (EPA 1979b) should be consulted for guidance on QC
procedures for participating laboratories.
Through the QAPjPs, participating entities will provide a description of
•	The project that explicitly defines the sampling strategy and design to be used, and the scientific and
statistical basis for selection of specific sampling sites
•	The sampling, analytical methodology, calibration procedures, and standard operating procedures to
be used, along with detailed information on probes, collection devices, storage containers, and
preservatives to be used
•	Any special operating conditions related to sample storage and preservation
•	The reference, equivalent, or alternate test procedures, along with the appropriate instrument selection
and use (in addition to tht primary methodology)
•	The preventative and remedial maintenance that will be required for each instrument
•	Specific procedures for estimating and documenting accuracy and precision of analytical procedures,
such as replicate samples, blind and spiked samples, and field and analytical blanks
•	Any inter-and intra-laboratory QC procedures (e.g., internal QC checks, split samples, etc.) associated
with analytical methods
•	Methods for documenting the QC procedures, including acceptance criteria
•	Procedures for corrective action
•	Performance and system audits
•	A mechanism for maintaining sample chain-of-custody
•	Procedures for data reduction, validation, and reporting
A QAPjP will also describe the project organization and responsibilities. When appropriate, the use of the data
generated during the project will be described.
The QAPjPs to be submitted for review and approval should address the following aspects of QA.
•	Identification and establishment of specific data quality goals to be achieved during the monitoring
project
•	Description of the procedures that will be used to measure or assess the quality of the environmental
measurements obtained during the project
•	Description of the nature of the report that will be prepared to document the quality of the
measurements
In general, the development of a QAPjP will involve the following activities:
•	Establishment of data quality objectives
•	Compilation of method performance data
•	Specification of measures of data quality
All participants in the water-quality monitoring program will be required to establish clear Data Quality Objectives
(DQO). In establishing DQOs, tradeoffs between data quality and incremental costs associated with increasing
quality in terms of time, personnel, and expense should be closely examined. DQOs should satisfy project
objectives, but these goals must be reasonably attainable within the available time, resources, and methodology.
All methods to be used within the program should be well established and have performance data available. In
addition, all monitoring activities will specify and document the measures of data quality that will be achieved. To
ensure data accuracy and comparability, the monitoring program should participate in the Quality Assurance Project
of the National Status and Trends Program. Participation in the yearly comparison exercises may reduce
interlaboratory and intralaboratory analytical variation.
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9.3 RESPONSIBILITIES
The QA Program will be implemented by a Quality Assurance Officer (QAO), who is appointed by the Management
Committee of the FKNMS.
The QA functions of the QAO will be to
•	Develop a mechanism to provide participating entities with the technical and material guidance and
assistance necessary to produce reliable and comparable data
a Develop and implement a system for continually evaluating the performance of participating
researchers, laboratories, and personnel, as well as the adequacy of the methods and instruments being
used
•	Enhance the overall capability and performance of monitoring activities through corrective action
•	Develop mechanisms to identify and correct methodological discrepancies between participating
laboratories
•	Continually review and improve the QA program while ensuring that the requirements placed on
participants achieve the goals of the program without becoming an undue burden
The QAO will be responsible for transmitting QAPjPs to the EPA Region IV QAO for review and approval. A
copy of the draft QAPjP will also be submitted to the designated FDER QAO for comment. The acceptance or
rejection of QAPjPs will be communicated to the submitting party through the QAO. Approved QAPjPs, which
will be subject to periodic review, will be filed with the QAO.
The EPA Region IV QAO will coordinate with the QAO in the requirements for performance and systems audits
which may be required of all participating entities. The performance and systems audits will be based on guidance
and procedures provided by EPA (1985) in Standard Operating Procedures for Conducting Surplus and Sample Bank
Audits. Unannounced audits may be performed by EPA/FDER to determine compliance with the approved QAPjP.
The QAO will also coordinate inter-laboratory calibration exercises to improve data reliability and comparability.
10.0 DATA MANAGEMENT
Data management will play an important role in the performance of the monitoring program because it will serve
as the central node for the flow of data. As this central node, data management will participate in and oversee the
data flow among the participants and to Sanctuary management. The objective of data management is to monitor,
control, and facilitate data flow, ensuring the integrity of the data through each phase of the project.
The entity conducting data management should develop the data management plan. The data management plan
should meet certain requirements but should reflect the facilities available at the designated entity. In this document,
an entity to conduct data management is recommended, Sanctuary management support is outlined, and requirements
for the data management plan are discussed. The data management entity will prepare a draft version of the plan
that meets the requirements, and the NOAA Core Group will review the draft plan to ensure that it meets the needs
of the Sanctuary program and approve the final plan.
The recommended entity to conduct data management for the FKNMS Water Quality Protection Program is the
Florida Marine Research Institute (FMRI). This agency is a logical choice because its representatives have been
involved in the development of the Water Quality Protection Program since its beginning. FMRI also has
experience in and facilities for providing data management services, and regularly coordinates with state and federal
agencies.
Data management should be overseen by the Water Quality Protection Program Management Committee, in
consultation with the Technical Advisory Committee, to ensure that data management meets the needs of the
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Sanctuary managers and the participating scientific community. In addition, a committee to coordinate information
exchange should be established to facilitate the flow of information among government agencies. This will ensure
that data exchanges between the Sanctuary database and the agencies will be coordinates' This committee should
be chaired by the Sanctuary data manager and be comprised of data managers from the „tute and federal agencies
that will exchange data with the Sanctuary database. Primary participants in the coordination committee should be
the EPA, FDER, FDNR, Florida Department of Community Affairs (FDCA), Florida Office of Planning and
Budget, Monroe County, NOAA, South Florida Water Management District (SFWMD), and the U.S. Fish and
Wildlife Service (FWS).
To accomplish the data management objective, four interrelated elements need to be incorporated into the data
management plan: (1) data management, (2) data control, (3) data utilization, and (4) archiving. Data management
is the element of the data management plan that ensures the continuous tracking and custody of samples and data
with evidence of data possession, comparison, and security with signatures, dates, times, and location of data. It
will also ensure proper formatting, reporting, and dissemination of data. The purpose of data control is to monitor
the progress of the data flow, identify gaps in the information supplied, and signal further processing requirements.
Data control procedures enable documentation of data availability, data reduction, and data analysis. Data control
also includes a routine backup of computer files. This should be addressed in the data management plan to ensure
efficient data recovery if a catastrophic event occurs, such as hardware failure. Data utilization ensures that all data
are processed, validated, and made available (as needed) to program participants and that these data are retrievable
(as needed) for analysis. QC via data entry and validation procedures ensures that only validated data are entered
into the project database. All necessary data are therefore available for analysis and interpretation. Data archival
is a method for the safe storage and easy retrieval of all accumulated data. An archival routine assures the
permanency of the data archives and is a necessary part of the data management plan.
The data management plan should include descriptions of the following items:
•	Data security including backup procedures
•	Data entry and validation protocols
•	Data processing protocols
•	Database documentation procedures
•	Data reduction and reporting requirements
•	Information exchange protocols (among agencies)
•	Data archival procedures
•	Data access and utilization protocols
•	Sample/data tracking and custody protocols
•	QA/QC requirements and procedures for data management activities
•	Structure of the data base
•	Tools for accessing data and developing data products for the Sanctuary management
•	Personnel training
•	Hardware specifications
•	Staffing requirements
•	Budgetary requirements
In addition, a strategy for evaluating and incorporating existing data from sources such as FDER and FDNR into
the database should be developed.
11.0 REFERENCES
Baker, J.R., and G.D. Merritt. 1991. Environmental Monitoring and Assessment Program guidelines for preparing
logistics plans. EPA 600/4-91/001. Environmental Protection Agency, Office of Research and
Development, Washington, DC.
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Bohnsack, J.A., and S.P. Bannerol. 1986. A stationary visual census technique for quantitatively assessing
community structure of coral reef fishes. U.S. Dept. of Commerce, NOAA Tech. Rep. NMFS 41, IS pp.
Brock, V.E. 1954. "A preliminary report on a method for estimating reef fish populations." J. Widl. Mgmt.
18:296-308.
Cochran, W.G. 1963. Sampling techniques. John Wiley & Sons, Inc. New York, NY. 413 pp.
Dixon, W.J., and F.J. Massey, Jr. 1969. Introduction to statistical analysis. McGraw-Hill Book Company, New
York, NY. 638 pp.
Dodge, R.E., A. Logan, and A. Antonius. 1982. "Quantitative reef assessment studies in Bermuda: A comparison
of methods and preliminary results." Bull. Mar. Sci. 32:745-760.
Dustan, P., and J. C. Halas. 1987. "Changes in the reef-coral community of Carysfort Reef, Key Largo, Florida:
1974 to 1982." Coral Reefs 6:91-106.
EPA. 1979a. Methods for chemical analysis of water and wastes. EPA-600/4-79-020. Environmental Protection
Agency, Office of Research and Development, Environmental Monitoring and Support Laboratory,
Cincinnati, OH.
EPA. 1979b. Handbook for analytical quality control in water and wastewater laboratories. EPA 600/4-79-019.
Environmental Protection Agency, Environmental Monitoring and Support Laboratory, Cincinnati, OH.
EPA. 1984. Guidance for preparation of combined work/quality assurance project plans for environmental
monitoring. OWRS QA-1. Environmental Protection Agency, Office of Water Regulations and Standards,
Washington, DC.
EPA. 1985. Standard operating procedures for conducting surplus and sample bank audits. EPA/600/4-85/003.
Environmental Protection Agency, Washington, DC.
EPA. 1988. Guide for preparation of quality assurance project plans for the National Estuary Program. Interim
Final. EPA 556/2-88-001. Environmental Protection Agency, Office of Marine and Estuarine Protection,
Washington, DC.
EPA. 1990. Biological criteria: - National program guidance for surface waters. EPA-440/5-90-004.
Environmental Protection Agency, Criteria and Standards Division, Office of Water Regulations and
Standards, Washington, DC.
EPA. 1991. National Estuary Program: Monitoring guidance document, draft. EPA 556/2-88-001. Environmental
Protection Agency, Office of Marine and Estuarine Protection, Washington, DC.
Goldberg, W. 1973. "The ecology of coral-octocoral communities off the southeast Florida coast: geomorphology,
species composition and zonation." Bull. Mar. Sci. 23:465-488.
Grassoff, K. 1983a. Determination of nitrate'. In Grassoff, K., M. Erhardt, and K. Kremeling, Methods of
seawater analysis. Verlag Chemie, Weinheim, Germany.
Grassoff, K. 1983b. Determination of nitrite. In Grassoff, K., M. Erhardt, and K. Kremeling, Methods of
seawater analysis. Verlag Chemie, Weinheim, Germany.
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Harwell, C. (Ed.)- 1991. Report on the research planning workshop for the Florida Keys National Marine
Sanctuary, Miami, Florida, 7-9 October 1991. National Oceanic and Atmospheric Administration,
Sanctuaries and Reserves Division, Washington, DC.
Jaap, W.C., W.G. Lyons. P. Dustan, and J.C. Halas. 1989. Stony coral (Scleractinia and Milleporina) community
structure at Bird Key Reef, Ft. Jefferson National Monument, Dry Tortugas, Florida. Florida Marine
Research Publ. No. 46, Florida Marine Research Institute, St. Petersburg, FL.
Jones, R.S., and M.J. Thompson. 1978. "Comparison of Florida reef fish assemblages using a rapid visual
technique." Bull. Mar. Sci. 28:159-172.
Kimmel, J.J. 198S. "A new species-time method for visual assessment of fishes and its comparison with
established methods." Env. Biol. Fish. 12:23-32.
Klein, J. 1993. Considerations of a spatial framework for the Florida Keys National Marine Sanctuary. Submitted
to Bull. Mar. Sci.
Koroleff, F. 1983. Determination of ammonia. In K. Grassoff, M. Erhardt, and K. Kremeling, Methods of
seawater analysis. Verlag Chemie, Weinheim, Germany,
Lapointe, B.E., and M.W. Clark. 1990. Ambient water quality assessment ui nearshore waters of Monroe County
during winter 1990. Report to the J.D. and C.T. Mac Arthur Foundation. Florida Institute of
Oceanography, St. Petersburg, FL.
Loya, Y. 1972. "Community structure and species diversity of hermatypic corals at Eilat, Red Sea." Mar. Biol.
13:100-123.
Loya, Y. 1978. Plotless and transect methods. Pp. 197-217 in Stoddart, D.R., and R.E. Johannes (Eds.), Coral
reefs: research methods. UNESCO Monograph on Oceanographic Methodology S.
Murphy, J., and J.P. Riley. 1962. "A modified single solution method for the determination of phosphate in
natural water." Anal. Chim. Acta. 27:31-36.
NRC. 1990. Managing troubled waters: The role of marine environmental monitoring. National Academy Press,
National Research Council, Washington, DC.
Ogden, J. 1991. SEAKEYS Phase I Final Report to the J.D. and C.T. MacArthur Foundation. Florida Institute
of Oceanography, St. Petersburg, FL.
Porter, J. W., and O.W. Meier. In press. "Quantification of loss and change in Floridian reef coral populations."
Amer. Zool., Dec. 1992.
Soldrzano, L., and J. Sharp. 1980a. "Determination of total dissolved nitrogen in natural waters." Limnol.
Oceanogr. 25:751-754.
Sol6rzano, L., and J. Sharp. 1980b. "Determination of total dissolved phosphorus and particulate phosphorous
in natural waters." Limnol. Oceanogr. 25:754-758.
Sugimura, Y., and Y. Suzuki. 1988. "A high temperature catalytic oxidation method for determination of
non-volatile dissolved organic carbon in seawater by direct injection of liquid samples." Mar. Chem.
24:105-131.
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Szmant, A.M. 1991. Inshore-offshore patterns of nutrient and chlorophyll concentration along the Florida Reef
Tract. Pp. 42-62 in SEAKEYS Phase I, Sustained Ecological Research Related to Management of the
Florida Keys Seascape. A final report to the John 0. and Catherine T. Mac Arthur Foundation Wor'
Environment and Resources Program from the Florida Institute of Oceanography, St. Petersburg, FL.
Taylor, J.K. 1985. Principles of quality assurance of chemical measurements. NBSIR 85-3105. National Bureau
of Standards, Gaithersburg, MD.
Valente, R., C. Strobel, J.E. Pollard, K.M. Peres, T.C. Chiang, and J. Rosen. 1990. Environmental Monitoring
and Assessment Program near coastal demonstration project quality assurance project plan. U.S.
Environmental Protection Agency, Office of Research and Development, Washington, DC.
Walsh, T.W. 1989. "Total dissolved nitrogen in seawater: A new high-temperature combustion method and a
comparison with photo-oxidation." Mar. Chem. 26:295-311.
Ward, R.C., J.C. Loftis, and G.B. McBride (Eds.). 1989. Proceedings, international symposium on the design
of water quality information systems. Information Series No. 61. Colorado Water Resources Research
Institute, Fort Collins, CO.
Wheaton, J.L., and W.C. Jaap. 1988. Corals and other prominent benthic cnidaria of Looe Key National Marine
Sanctuary, Florida. Flonda Marine Research Publication No.43. Florida Manne-Research Institute. St.
Petersburg, FL.
White, M.W., and J.W. Porter. 1985. The establishment and monitoring of two permanent photograph transects
in Looe Key and Key Largo National Manne Sanctuaries (Florida Keys). Proc. Int. Coral Reef Congr.,
5th, 1985.
Yentsch, C.S., and D.W. Menzel. 1963. 'A method for determination of phytoplankton chlorophyll and
phaeophytin by fluorescence." Deep-Sea Res. 10:221-231.
Zieman, J.C. 1974. "Methods for the study of growth and productivity in the turtlegrass Thalassia testudinum
Konig." Aquaculture 4:139-143.
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APPENDIX A
Field Protocols for Water Column, Sediment, and Tissue Monitoring

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FIELD PROTOCOLS FOR WATER COLUMN, SEDIMENT, AND TISSUE MONITORING
A.l SAMPLING SCHEDULE
Sampling for water column, sediment, and tissue monitoring will be conducted as described in detail in Section 6.0
of this document. In general, water column monitoring within the first five years of the program will be conducted
every six weeks. Sediment sampling will be conducted on an initial survey during the first year of the program.
Tissue samples will be collected during a single survey to the biological resource study sites.
AJ, SAMPLING SITES AND STATIONS
The activities described below will be conducted at sites and stations specified in Section 6.0 of this document.
After a station is selected, the site's coordinates will be determined, the site will be located by using a Global
Positioning System (GPS) unit, and the site will be examined for appropriateness. The selected station will be
marked or reliable references points will be identified and noted. A station description form will be completed and
entered into the Registry of Sites and Stations maintained in the Florida Keys National Marine Sanctuary (FKNMS)
Data Management System. Each site and station will be assigned a unique code that will be used as an identifier
for all data collected at that station.
A J FIELD METHODS
Because field collections vail likely be made by different teams based in three or more areas of the Keys, for quality
control (QC) purposes, the number of laboratories where the analyses are to be conducted will be minimizrxl.
At each water column sampling station, the physico-chemical parameters to be measured in the field are
•	Water temperature
•	Conductivity/salinity
•	Dissolved oxygen (DO)
•	pH
•	Photosynthetically active radiation (PAR)
These parameters (except PAR) will be measured at 0.5 m below the surface at stations less than 3 m in depth.
At stations 3-5 m in depth, measurements will be made at 0.5 m and 1 m above the bottom. At depths greater than
5 m, an additional measurement will be made at mid-depth. PAR will be measured at several depths (as described
in the attached protocol) to calculate a light extinction coefficient. In addition, ancillary information such as air
temperature, wind speed and direction, tidal stage, sea state, and cloud cover will be noted. Precision, accuracy,
and reporting requirements for each parameter will be specified in the Quality Assurance (QA) Plan. A multi-sensor
environmental package such as the Hydrolab Datasonde III or H20 Sensor with a Surveyor 3 display unit/datalogger
are recommended for use as the primary instrumentation. The recommended instrumentation for PAR measurement
includes the Licor 4 pi underwater quantum sensors with an LI-1000 datalogger. All field data with clear station
identification codes and times (as Eastern Standard Time) will be entered on appropriate data sheets.
Water samples will be collected at each water column sampling station by using a 5 L Niskin sampler deployed at
depths as described above. Water samples of adequate volume will be collected, stored in appropriate containers,
packed in ice, and transported to the laboratory within 4 h of collection. In the field, subsamples will be filtered
through a Whatman GF/F glass fiber filter for dissolved nutrient determinations. The used filter will then be placed
in a microcentrifuge tube and kept under ice until it can be stored in a freezer. All bottles will be appropriately
labeled and, if necessary (e.g. when the field sampling and analytical work is performed by separate laboratories,
particularly for sediment), a protocol for sample chain-of-custody will be observed following the procedures in the
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approved QA Plan for the program. Appropriate field blanks and control samples will be prepared as required by
QA/QC procedures.
Sediment samples of adequate volume will be collecte- with a Smith-Mclntyre grab or by scuba divers, then placed
in wide-mouth Teflon-lined glass jars or polyethylene tubes/bottles, sealed, packed in ice, and transported to the
laboratory.
A.4 FIELD SAMPLING PROTOCOL
This protocol describes the activities to be conducted at the designated sampling stations. Basic station descriptions
are presumed to have been conducted prior to the actual sampling effort. This protocol may be employed for all
phases of the monitoring program. Sediment quality measurements are likely to be conducted during the initial
survey.
Although the sampling activities described in the following sections are relatively straightforward, training and
review of protocols and the appropriate QA/QC plans by all personnel involved should be conducted prior to
conducting the field work.
A.4.1 Mobilization and Preparations
1.	Review appropriate protocols and QA/QC plan.
2.	Clean sampling equipment and materials.
3.	Check battery power, calibration, and function in all electronic equipment. Record results in a
Maintenance and Calibration Log Book.
4.	Check data sheets and checklists.
5.	Check labels on sample bottles.
6.	Assemble all field sampling equipment and materials including backup equipment, field blanks, and
standards. Use and initial the appropriate checklist.
7.	Check vehicle and boat for fuel, safety, and communications equipment.
8.	Check station locations for current sampling session.
9.	Prepare a Float Plan.
A.4.2 Field Work
Because of the minimal tidal range and the greater influence of wind-driven "tides," sampling will be conducted
without regard for tidal stage. However, sampling will be suspended or delayed if weather conditions render field
work hazardous or if wind conditions generate unusual turbidity. This protocol assumes that samples will be
collected from docks (with at least 1 m depth) or from a boat. Only personnel with proper training and knowledge
of the procedures may conduct the sampling.
Assuming that station locations are appropriately marked or adequate reference points are located, personnel should
proceed to the designated sampling site according to the sampling schedule.
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A.4.3 Parameter Measurements and Sample Collections
Sampling includes the following activities:
I.	Physico-chemical measurements and ancillary notes (water-column stations):
(a)	Water temperature
(b)	Conductivity/salinity
(c)	pH
(d)	DO
(e)	PAR by depth (light extinction coefficient)
(f)	Water depth
(g)	Air temperature
(h)	Wind speed and direction
(i)	Cloud cover
(j) Tide stage
(k) Sea state
II.	Water sample collections (water-column stations):
(a)	Nutrients
(b)	Chlorophyll a
(c)	Alkaline phosphatase activity (APA)
(d)	Nephelometer turbidity
m. Sediment sample collections (water-column stations):
(a)	Basic sediment parameters
(b)	Toxic constituents
IV. Tissue sample collections (biological resource study sites):
(a)	Organic matter content
(b)	Toxic constituents
A.4.3.1 PHYSICO-CHEMICAL MEASUREMENTS
Measurements and sample collections will be conducted in the order listed above to minimize contamination of the
water samples. The boat operator should approach each sampling station slowly to prevent stirring up the bottom
and resuspending sediments that will cloud up the water column and "contaminate" the water samples. If an anchor
must be dropped, any sediment that has been resuspended should be allowed to clear before starting the sampling
procedures.
The recommended instrument for measuring physico-chemical measurements in the water column is the Hydrolab
H20 with a sensor package for temperature, conductivity/salinity, pH, and DO connected to a Hydrolab Surveyor
2. A second, properly calibrated Hydrolab H20 should be brought along as a back-up. If a second Hydrolab H20
is not available as a back-up, then the following instruments should be available:
•	YSI Model 33 Salinity-Conductivity and Temperature meter with 3-m long cable
•	YSI Model 57 dissolved oxygen meter with 3-m long cable
•	Beckman or Orion field pH meter
These instruments should be calibrated daily and brought to the field whenever a backup Hydrolab H20 is not
available. Upon arriving at each sampling station and after the boat has been secured, turn t>n all instruments and
allow the electronics to warm up and stabilize, determine the depth at the sampling station, and set the Surveyor
3 to log the sensor readings every minute. When the Hydrolab H20 is ready, lower the instrument so that the
6A-3

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sensors are at 0.5 m depth. Allow the instrument to equilibrate for 1 min and then record the time, depth, water
temperature, conductivity/salinity, pH, and DO on a data sheet. Continue lowering the Hydrolab H20 slowly to
the next measurement depth. Allow the instrument to equilibrate for 1 min and record the time, depth, water
temperature, conductivity/salinity, pH, and DO on a data sheet. Although the data will be recorded on the Surveyor
3 datalogger, handwritten records should be kept for greater security.
Measurement depths will depend on the water depth at a station and are as follows:
•	< 3 m - mid-depth
•	3-5 m - 0.S m below the water surface and 1 m above the sea floor
•	S-SO m - 0.5 m below the water surface and at 2-m depth increments to 1 m above the seafloor
•	>50 m - 0.5 m below the water surface and at 5-m depth increments to 1 m above the seafloor
If a pycnocline or other abrupt change of measurements is observed during the downcast, the depths of change
should be profiled with greater resolution (e.g., 1-m depth increments) during the upcast.
When the primary instrument fails and a backup Hydrolab H20 is not available, the following procedure can be
employed using the backup instruments, a 5-gallon bucket and a Niskin sampler:
(1)	Empty the water sample from the Niskin sampler via the tubing to fill up the 5 gallon bucket.
(2)	Submerge the probes for the Salinity-Conductivity-Temperature (S-C-T) meter and DO meter into the
bucket to start equilibrating with the sample. After 2 min, the oxygen probe should be gently agitated
to prevent building up gradients across the membrane. The S-C-T meter probe does not need
agitation.
(3)	Measure the pH of the sample.
After recording the data obtained by using the above instrument(s), proceed as follows.
1.	Deploy the reference sensor. Using a calibrated line, lower the PAR sensor on a weighted lowering
frame over the unshaded side of the boat. Take measurements at the following depths: 0.15, 0.20,
0.40, 0.60, 0.80, 1, 2, 3 m, etc. (see PAR attenuation coefficient protocol). Ensure that the sensor
remains at each depth for a period longer than the averaging time set on the datalogger. Record all
measurements on an appropriate data sheet. After taking the PAR measurements, measure the depth
to bottom using the same calibrated line.
2.	Enter the following information on the data sheet: sampling station (code), date (MM/DD/YY), time
(HHMM) as Eastern Standard Time, station depth (m). tidal stage, weather conditions, etc.
3.	Estimate the wind direction and speed.
4.	Record, on the appropriate data sheet, water temperature (degrees Celsius [ฐC]), salinity (parts per
thousand [ppt or o/oo]), conductivity, DO content (mg Oj per liter [mg/L or parts per million (ppm)]),
and wind direction (e.g. northwest [NW]) and speed (miles per hour [mph]).
A.4.3.2 WATER SAMPLE COLLECTION
After completing the measurements of physico-chemical and ancillary parameters, proceed with water sample
collection as follows:
6A-4

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1.	After cocking open the Niskin sampler, lower it over the side of the boat to the appropriate depth (see
above) and collect a sample.
2.	Rinse the 125 mL high-density polyethylene (HDPE) sample bottle for nutrients with the sample three
times before filling it to capacity. Fill and tightly cap one sample bottle for each depth. Make sure
the bottle is properly labeled.
3.	Filter all samples immediately after collection. Rinse the 60 mL syringe and the 25 mm filter holder
with the remaining water from the Niskin sampler.
4.	Load the filter holder with a Whatman GF/F 25-mm glass fiber filter.
5.	Fill the 60 mL syringe by withdrawing the water from the 12S mL sample bottle. Filter the sample
by hand. Discard the first 10 mL of the sample. Rinse the 60 mL bottles three times with the filtered
sample before filling the bottle to capacity. Fill the syringe with another 60 mL of sample and filter
it through the same filter.
6.	Store the filtered water samples under ice while being transported to the lab.
7.	Open the filter holder and place one drop of saturated magnesium carbonate (MgCO^.on the filter.
Remove the used filter, carefully fold it in half, place it in a labeled microcentrifuge tube, and
transport it under ice until it can be frozen in the laboratory. These filters will be used for chlorophyll
measurements.
8.	Store each sample bottle in a cooler at ambient temperatures while being transported to the laboratory
after a subsample has been filtered.
9.	Note on an appropriate checklist that the above samples were collected.
10.	Rinse the used syringe and filter holder with deionized water and reload the filter holder after shaking
out any excess water. Complete this procedure prior to collecting sediment samples or proceeding to
the next site to avoid any possibility of contamination.
A.4.3 J SEDIMENT SAMPLE COLLECTION
The preferred method of sediment sample collection is by divers using hand cores. If diver sampling is not possible,
then proceed with sediment grab sampling as follows:
1.	Assemble the following equipment and materials in the appropriate area of the boat.
(a)	Smith-Mclntyre grab
(b)	Wash basin and scoop
(c)	Labeled and clean sample containers
(d)	Hand-cores
2.	Cock the grab open, bring it to die proper position over the side, and deploy. Retrieve the grab,
carefully raising it to the surface and on deck.
3.	Carefully examine the contents to ensure that an acceptable sample was collected.
(a)	The jaws of the grab should be completely shut.
(b)	The sediment-water interface should be undisturbed, as indicated by the presence of water between
the sediment surface at the top of the grab. There should be about 1 in. of space between the
sediment surface and the top of the grab.
6A-5

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(c)	There should not be any evidence that some portion of the sample was washed out.
(d)	The surface of the sample should not be canted more than 5 degrees.
4.	Using a hand-core, collect small subsamples of the sediment and put them in the appropriate labeled
containers.
5.	Store all sediment samples under ice while being transported to the laboratory.
6.	Clean and thoroughly rinse all sediment sampling equipment and the work area of sediment prior to
proceeding to the next site.
A.4J.4 TISSUE SAMPLING
Tissue samples will be obtained at the biological resource monitoring stations. Species to be collected will depend
on the habitat and will be selected during a workshop convened by EPA among potential participating researchers
and laboratories. Representative producers and consumers will be collected by scuba divers, traps, or other
appropriate means. All specimens.will be wrapped in aluminum foil, placed in plastic bags, and transported to the
laboratory on ice.
A.4.3.5 TRANSIT BETWEEN STATIONS
After checking that all the needed samples have been collected, discard all extra and unneeded samples. Rinse the
sampling equipment and store all the materials so that they are protected against spray and sun. Move to the next
station after ensuring all station information has been properly recorded, labels are properly logged, and equipment
and materials are stowed. Return all the water samples to the lab within 4 h of sampling.
A.4.4 Demobilization
1.	Upon returning to the laboratory, store the chlorophyll filters, filtered water, and sedimec samples
in designated refrigerators and freezers.
2.	Remove aliquots of the unfiltered water samples for determination of APA as described in ;*, separate
protocol.
3.	Filter any water samples soon after returning to the lab (if this has not been done in the field). See
filtering procedure (Section A.4.3).
4.	Rinse and dry all meters and sampling equipment to minimize corrosion. Soiled/used sampling and
filtering materials should be cleaned and washed.
5.	Transfer the data from the Surveyor 3 into a desktop or laptop computer; immediately copy the file
and store in a separate location.
6.	All data sheets should be collated, checked for clarity and completeness, and placed in appropriate
binders after each field session. A copy of the completed field data sheet should be made and stored
in a separate location.
6A-6

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A.5 MINIMUM PERFORMANCE CRITERIA FOR THE PHYSICO-CHEMICAL PARAMETERS
j PARAMETER
METHOD/
RANGE
REPORTING
UNITS
PRECISION
(%>
ACCURACY
<%)
COMPLETENESS
I*)
CALIBRATION
| Temperature
Thermistor
-5.0 to 45.0
ฐC
5
99
99
NBS certified
thermometer
Salinity
By
conductivity
0 to 45
ppt
5
99
99
Potassium
chloride
standards
PH
Electrometric
Oto 14
pH units
5
99
95
NBS traceable
buffers, 2
point
calibration
DO
Polarographic
sensor
0 to 20
mg/L
5
95
95
Water
saturated air
or Winkler
titration
Light
attenuation
coefficient. It
PAR
attenuation
0 to -
(negative
number)
- Im
NA
NA
95
Factory
calibration of
quantum
sensor
	1
NA: Not applicable
6A-7

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A.6 FHOTOSYNTHETICALLY ACTIVE RADIATION DIFFUSE ATTENUATION
COEFFICIENT METHODOLOGY
The following format follows EPA (1979).
1.	Scope and Application
1.1 This method provides a more ecologically important measure of light availability than Secchi disk
transparency. Measurement of PAR at multiple depths is the recommended method of assessing
transparency (Kenworthy and Haunert 1991). The method is also more flexible in that it can be used
in turbid or clear shallow water by adjustment of the depths at which PAR measurements are made.
The only limitation to the method will be in very turbid, shallow waters where there may not be
enough water below the lowering fnune to immerse the submarine sensor. A thorough discussion on
the physics and measurement of underwater irradiance is found in Kirk (1983). This protocol was
developed at a workshop of seagrass researchers (L. Morris, St. John's River Water Management
District, pers. comm., 1993).
2.	Summary of Method
2.1 Measurements of diffuse incident and reflected PAR (400-700 nm) are made at successive depths from
the surface to the bottom of the water column while simultaneous measurements are made in the air
on a deck sensor and on a reference sensor near the surface. A diffuse attenuation (extinction)
coefficient is calculated from the change in PAR intensity with depth after the readings are corrected
for changes in cloud cover.
3.	Sample Handling and Preservation
3.1 Not applicable
4.	Interferences
4.1 Not applicable
5.	Apparatus and Materials
5.1 The recommended instrumentation are the L1COR 4 pi underwater quantum (PAR) sensors tor PAR
measurements in the air (deck cell) and underwater with a Ll-1000 datalogger (J. Kenworthy, National
Marine Fisheries Service, personal communication, 1992). The spherical 4 pi sensor is reco amended
over the 2 pi which only measures downwelling radiation. The 4 pi sensors measwes both
downwelling and reflected light which are both important for photosynthesis. There are a. so major
leveling problems associated with using 2 pi sensors particularly at depths with significac- currents.
A datalogger with averaging algorithms is also recommended since these will provide a mo:j accurate
measure of light levels than single measurements. Underwater cable lengths of 25 m will be required.
Three sensors will be required: A fixed deck sensor mounted on a black plate, a fixed subsurface
sensor mounted on a floating frame, and a movable sensor mounted on a lowering frame. The
lowering frame should be weighted with lead as required. A separate line should be used to carry the
weight of the lowering frame and lead weights. The fixed submarine sensor is mounted on a floating
frame painted black which suspends it IS cm below the surface.
6.	Reagents
6.1 None
7.	Procedure
7.1 Adjust the instrument package by entering the calibration factor on the datalogger for the attached PAR
sensors. The reporting units will be in ^einsteins cm'2 sec"'. Adjust the averaging period to no less
than 20 sec. The calibration factor (in the air or underwater) is provided by the factory. Mount the
sensors on the deck mount, floating frame, and lowering frame and check all the connections for
water-tightness. It is recommended that measurements be taken between 10 a.m. and 2 p.m.
6A-8

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7.2	Lower the underwater sensor on the nnซhaHปH side of the boat/dock and record the PAR intensity from
the deck sensor and submarine sensor while the sensor on the lowering frame is at 0.1 m depth.
[NOTE: Keep the submarine sensor in position longer than the averaging time set on the datalogger],
7.3	Continue lowering the submarine sensor into the water and record the PAR intensity from the deck and
submarine sensors at each depth according to the following depth ranges.
Station depth less than 3m — Depths: 0.15, 0.20, 0.40, 0.60, 0.80, 1.00, 1.50, 2.00, and
at canopy height.
Station depth 3-5 m— Depths: 0.15,0.20,0.40,0.60,0.80,1.00, 1.50,2.00,3.00, and 4.00.
Station depth greater than 5m— Depths: 0.15, 0.20, 0.40, 0.60, 0.80, 1.00, 1.50, 2.00,
3.00, 4.00, and a depth of 1 m above the bottom.
Repeat measurements three times at each site.
8. Calculation
8.1 Light or irradiance is attenuated underwater in an exponential manner. The relationship between
underwater irradiance at a particular depth and irradiance at the water surface can be expressed as
In Ed(z) = -K,,z + In Ed(0)
where Ed(z) and Ed(0) are the values of irradiance at z m depth and at the surface,
respectively. Kd is the light attenuation coefficient.
The deck sensor readings are recorded for future use to make further corrections for sun angle and
immersion effects. They are not needed for the calculations described below.
Each reading made with the sensor on the lowering frame at depth Ed(z^l is corrected for changes in
cloud cover during the period of measurements by multiplying by a correction factor J[z) based on the
reference sensor readings E^z) (e.g., the correction factor for the reading at 0.20 depth,7(0.20) is
equal to E^O. 15)/Er(0.40), where E^O.15) is the reference sensor reading at the beginning of the
measurements (when the moveable sensor was at 0.15 m depth) and Er(0.40) the reference sensor
reading when the moveable sensor was at 0.40 m depth.
The PAR attenuation coefficient Kd is calculated by fitting a regression to the natural log of the
corrected PAR values Ec(j) against depth z. The slope of the regression line is equal to the light
attenuation coefficient. The average of the K,j values calculated for each site is calculated and
reported.
A light attenuation coefficient for each depth interval Kd(z) may also be calculated if there is significant
evidence for stratification in the water column which may be of interest. This may be calculated by
taking the difference between the natural logarithms of the corrected PAR values at each depth z [In
Ec(z)] and dividing it by the difference in depth (Zj-Zi).
1 Eefct)
Kd(z)	In	
(z2-zi) Ec(Z2)
6A-9

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9. Precision and Accuracy
9.1 Since this specific methodology is relatively new, estimates of its precision and accuracy are not
available.
References
EPA. 1979. Methods for chemical analysis of water and wastes. EPA 6000/4-79-020. Environmental Protection
Agency, Office of Research and Development, Cincinnati, OH.
Ken worthy, W.J., and D.E. Haunert (eds.). 1991. The light requirements of seagrasses: Proceedings of a
workshop to examine the capability of water quality criteria, standards and monitoring programs to protect
seagrasses. NOAA Tech. Mem. NMFS-SEFC-287.
Kirk, J.T.O. 1983. Light and photosynthesis in aquatic ecosystems. Cambridge University Press, Cambridge,
England.
6 A-10

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A.7 HYDROLAB CALIBRATION PROCEDURES
A. 7.1 Temperature
Note: Temperature is calibrated at the factory and is not adjustable.
*	Select T from variable menu.
*	Select (Qentigrade or (F)arenheit.
*	Return to screen 1.
*	Compare Hydrolab reading with calibration thermometer in water bucket.
*	Record values on calibration form.
A.7.2 Dissolved Oxygen
•	Select DO from variable menu.
•	Select (S)tandard membrane.
•	Select (S)alinity compensation.
•	Select % from calibrate menu.
•	Enter local barometric pressure in millimeters of mercury (local newspaper or weather radio;
in X 25.4 = mm).
•	Remove calibration cup from sensors.
•	Orient unit so sensors are facing up.
a	Screw on bottomLess cup and fill with freshwater to a level even with the o-ring used to secure the
membrane.
•	Carefully remove any water droplets from the membrane using the corner of a paper towel.
•	Set the calibration cup lid upside down on top of the cup (air flow blocked but not sealed).
•	Return to screen 1 and allow readings to stabilize for 2 min.
•	The DO percent saturation value should read 100.0.
•	Record values on calibration form.
•	Select o (not zero) instead of % to get DO in mg/L.
A.7.3 Depth
•	Select D from variable menu.
•	Select (F)eet or (M)eters.
•	Select (D)epth for depth transducer.
•	Select DEPTH from calibrate menu.
•	Enter 0.0 if sensor is in calibration bucket or enter correct value if sensor is at known depth.
•	Record values on calibration form.
A.7.4 Conductivity
[Note: Conductivity and salinity are measured with the same sensor; therefore by calibrating one, the other
is automatically calibrated. The unit is' equipped with the saltwater cell block and can only be used in
water with specific conductance greater than 10 pS/cm.]
•	Select Sp Cond from variables menu.
•	Select (M) milli or (U) micro units.
•	Select (S)alt water cell block.
•	Select (A)uto range.
•	Select (S)alinity for other display.
6 A-11

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Select (U)ncompensated Cond/Sal readings.
Pour conductivity calibration solution into clean calibration cup and install over sensors.
Select SpC/S from calibrate menu.
Select (Conductance and enter the correct value for the solution (be sure units are correct).
Record values on calibration form.
A.7.5 pH
Select pH from calibrate menu.
Pour pH 7.0 solution into clean calibration cup and install over sensors.
Enter correct pH value.
Pour pH 11 solution into clean calibration cup and install over sensors.
Enter correct pH value.
Record values on calibration form.
6A-12

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Asset t:
A.8 HYDROLAB CALffiRATION FORM
Hydrolab Serial #:	
TEMPERATURE
calibration thermometer:
hydrolab temperature:	
_(#Q
_(#C)
DO
salinity compensation: yes	 no	
local barometric pressure:	(mmHg)
% saturation:	(%)
DEPTH
actual depth of sensor:
hydrolab depth reading:
(ft or m)
(ft or m)
CONDUCTIVITY
range: auto	hi	med	low
uncompensated setting: yes	 no	
calibration solution concentration:	(jiSlcm)
hydrolab conductivity of cal. solution:	0*S/cm)
pH
hydrolab value for pH 7.0 solution:	
hydrolab value for pH	solution:
Comments:
Battery Voltage:
Date: 	
Maintenance and Calibration By:
6A-13

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A.9 CHECKLIST OF MATERIALS AND ^QWPMEVT
Physico-chemical Measurements
Primary equipment: Hydrolab H20 and Surveyor 3 datalogger 	0
Backup equipment: Hydrolab H20; or	0
YSI Model 33 S-C-T meter and probe 		0
YSI Model 57 Oxygen meter and probe 	0
Meter stick	,	0
Licor 193 underwater quantum sensor			0
and LI-1000 data logger	0
5 gallon bucket	0
Watch	0
Tide tables	0
GPS Pathfinder	0
Water Sampling
5 L Niskin Sampler 	0
125 mL clear HDPE bottle, d.i. water rinsed	Number Available:	
60 mL clear HDPE bottle, d.i. water rmsed 	Number Available:	
Filtration
60 mL syringe	0
25 mm filter holder 	 	0
Whatman GF/F 25 mm glass fiber filters	0
Filter forceps 	 	0
1.8 mL microcentrifuge tube	Number f /ailable:	
Saturated magnesium carbonate solution	0
Sediment Sampling
Smith-Mclntyre grab	0
Wash basin and spatula	0
Hand cores	0
Sample jars/centrifuge tubes	Number Available:	
Miscellaneous Supplies
Kimwipes	0
HC1 wash bottle	0
Labeling tape 	0
Labeling markers	0
Coolers	0
Station location maps 		0
Data sheets	0
Date: _
Initials:
6A-14

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A. 10 FIELD DATA SHEET
Site Name:	 Site Code:	 Station Code:	 Coordinates:	
Date:	 Time:	 Data Recorder (Initials):	
Water Depth (m):		Tidal Stage:	 Sea State:	
Air Temp:	 Wind Speed:	 Wind Direction:	
Qoud Cover: Clear-0 Partly Cloudy-1 Overcast- 2 Precipitation: none-0 drizzling-1 heavy-2
Sampling
Depth
(m)
Temp
CO
Dissolved Oj
(mg/L)
Conductivity
/imhos/cm
Salinity
(PPt)
Turbidity
(atu)
Remarks




























Site Name:
Date:
Site Code:
Time:
Water Depth (m):
Air Temp:	
Station Code:
Data Recorder (Initials):
Coordinates:
Tidal Stage:
Wind Speed:
Sea State:
Wind Direction:
Cloud Cover: Clear-0 Partly Cloudy-1 Overcast- 2 Precipitation: none-0 drizzling-1 heavy-2
Sampling
Depth
(m)
Temp
<ฐQ
Dissolved Oj
(mg/L)
Conductivity
pmhos/cm
Salinity
(ppt)
Turbidity
(ntu)
Remarks




























Site Name:
Date:
Site Code:
Station Code:
Coordinates:
Time:
Water Depth (m):
Air Temp:	
Wind Speed:
Data Recorder (Initials):
Tidal Stage:	
Sea State:
Cloud Cover. Gear-0 Partly Cloudy-1
	 Wind Direction:	
Overcast- 2 Precipitation:
none-0 drizzling-1 heavy-2
1 Sampling
1 Depth
1
Temp
CC)
Dissolved O2
(mg/L)
Conductivity
/imhos/cm
Salinity
(ppt)
Turbidity
(ntu)
Remarks




























6A-15

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A. 11 SITE AND STATION DESCRIPTION FORM
Date Established:	
Station Type: Water Quality Sediment Quality Seagrass Community	Coral Community
Latitude:	 Longitude:	
Coordinates Determined by: Reckoning Loran GPS
Description of Station Marker, if any:
Average depth at low water:	m
Description of bottom type and coven
Description of nearby navigational markers:
Description of current patterns:
Other comments (e.g., proximity to developed islands, proximity to natural features, relative visitation frequency,
proximity to major traffic areas):
By:	 Date:
6A-16

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A. 12 CHAIN-OF-CUSTODY FORM
DATE	TIME COLLECTION CONTAINER	SAMPLE TYPE/
SAMPLE I D.	sampled sampled METHOD TYPE ANP EVMPPR EEMA
-------
APPENDIX B
Laboratory Methods and Analytical Protocols

-------
LABORATORY METHODS AND ANALYTICAL PROTOCOLS
B.1 INTRODUCTION
Laboratory methods and analytical protocols for measuring water quality and sediment quality parameters are
described in this appendix. Where appropriate, alternate ซw>ual methods are described for mitomatnd wet chemistry
procedures to cover contingencies (e.g., when instruments fail or are unavailable).
Generalized descriptions of laboratory methods for water and sediment samples are presented in Section B.2.
Sample preservation and holding times are discussed in Section BJ. As appropriate, standard or published
methodologies an presented for water and sediment analyses. Because Environmental Protection Agency (EPA)
methods for the water quality parameters of interest were developed for freshwater and wastewater, the detection
limits of some of the EPA methods may be inappropriate for the unique nature of the Florida Keys. Therefore,
alternative methods, which are analytically similar to EPA methods but are optimized to improve detection limits,
are described for these water quality parameters in Section B.4 because they are not available in the open literature.
State-of-the-art methods are also described in Section B.4 for low levels of nutrients. These state-of-the-art methods
may not be used routinely, but they are appropriate for special monitoring efforts and research studies where very
low detection limits are required.
Because of differences between laboratories in terms of instrumentation and capabilities, exact precision and
accuracy values are not presented for protocols; rather, the data quality achievable with a particular setup is
presented. Laboratories using these methods should develop quality control (QQ procedures to validate and
document precision and accuracy standards.
B.2 LABORATORY METHODS
B.2.1 Water Samples
Upon arrival in the laboratory, water samples will be processed as follows:
(a)	Alkaline phosphatase activity (APA)
Duplicate 3 mL volumes of unaltered water samples will be placed in a disposable cuvette and spiked with
30 fil of methyl fluoresce in phosphate (MFP). The relative fluorescence will then be measured on a
fluorometer (e.g., Gilford Fluorometer IV or Turner Instruments Model 112) to determine a T0 value. After
2 h of incubation at ambient temperatures, the relative fluorescence will be determined for a T2 value. APA
determinations will be performed within 12 h of collection.
(b)	Nephdometer turbidity
Subsamples from the unfiltered samples will be removed for the measurement of nephelometer turbidity with
a nephelomenter/turbidimeter. Measurements will be read directly from the instrument and reported as
nephelometric turbidity units (NTU) as described by EPA protocol (Method 180.1). The instrument will be
calibrated with AMCO-AEPA-1 standards (AMCO Standards International).
(c)	Dissolved ammonia, nitrate, nitrite, and phosphate
Filtered water samples will be analyzed for dissolved nutrients by automated high sensitivity wet chemical
techniques according to the protocols specified by the manufacturer (Alpkem, Inc. or Technicon, Inc.).
Sensitivity, precision, accuracy, and reporting requirements are listed in Table B-l. Ammonia will be
analyzed by the indophenol method, nitrite by the diazo method, nitrate (as nitrite after cadmium reduction),
and phosphate by the ascorbic acid/molybdate method. Dissolved nutrient determinations will be performed
6B-1

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Table B-l. Performance criteria for analytical methods.
Parameter
Method/Range
Units
Limit of
Detection
Precision
(%)
Accuracy
(%)
Completeness Calibration
Dissolved
ammonium
Autoanalyzer
0.1-15 pM
/iM
0.1
0.2
97
95
(NH4)2S04
Dissolved
nitrate
Autoanalyzer
0.01-20 pM
/tM
0.01
0.5
99
95
kno3
Dissolved nitrite Autoanalyzer
0.01-1 jtM
fiM
0.01
0.5
99
95
kno2
Soluble reactive
phosphate
Autoanalyzer
0.02-2 /tM
fiM
0.02
1
97
95
kh2po4
Total N
Hi-temp. oxid.
MOO /iM
fiM
1
5
90
90
Urea
Total P
Ignition with
MgS04 0.1-10
/tM
fiM
0.1
5
85
90
kh2po4
Alkaline
phosphatase
activity
Enzyme assay
fiM/h
TBA
TBA
TBA
90
Methyl fluorescein
Nephelometer
turbidity
Nephelometer
ntu
NA
NA
NA
90
AMCO-AEPA-1
Chlorophyll a
Fluorometry
0.1-10/tg/L
Hg/L
NA
10
95
95
Anacystis chl a
standards
NA: Not applicable
TBA: To be announced
6B-2

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within 24 h of sample collection. Alternatively, sample may be analyzed by manual wet chemistry methods
as described below.
(d)	Total nitrogen (TN) and total dissolved nitrogen (TDN)
Unfiltered and filtered aliquots will be analyzed for TN and TDN content, respectively. A 1.5 mL sample
will be placed in a sample vial and sealed with a Teflon/silicon lined crimp cap and stored at 2 ฐC until
analyzed. Analysis will be performed by oxidation of the sample at high temperature to nitric oxide (NO)
and reaction with ozone to form nitrogen dioxide (NO^). Alternatively, samples may be analyzed by the
persulfate digestion method described below. These analyses will be performed within 30 days of sample
collection.
(e)	Total phosphorus (TP) and total dissolved phosphorus (TDP)
Unfiltered and filtered aliquots will be analyzed for TP and TDP, respectively. A 5 mL sample will be
completely mixed with 100 pi of MgS04 in a scintillation vial and evaporated to dryness at 80 "C in an oven.
The evaporated sample will then be ashed at 550 "C for 3.5 h, hydrolyzed with 5 mL of HC1, and incubated
overnight at 80 ฐC. The orthophosphate content of the hydrolyzed sample will then be determined in an
autoanalyzer. These analyses will be performed within 30 days of sample collection.
(f)	Non-purgeable organic carbon (NPOC)/inorganic carbon
Unfiltered aliquots will be analyzed for NPOC/inorganic carbon by high-temperature combustion and analysis
of C02 by infra-red gas analysis (e.g., Shimadzu TOC-5000). Samples will be acidified and purged for 8
min with nitrogen prior to analysis for NPOC content, while unacidified and unpurged samples will be
analyzed for inorganic carbon content. This analysis will be performed within 7 days of sample collection.
(g)	Chlorophyll a
The used GF/F glass fiber filters will be stored frozen at -15 ฐC until analyzed within seven days of sample
collection. Each filter will be thawed out and steeped overnight in 1.5 mL of acetone solution at 4 ฐC. The
fluorescence in a 750 fiL aliquot of the extract, diluted with 2.25 mL of acetone will be determined in a
cuvette using a fluorometer equipped with the appropriate filters.
Performance criteria for the required analytical methods are listed in Table B-l.
B.2.2 Sediment Samples
Sediment samples will be stored at about 4ฐC until analyzed for basic sediment parameters or extracted for heavy
metals and orgamcs such as pesticides (known mosquito control agents and right-of-way control herbicides), heavy
metals, tributyltin, polychlorinated biphenyls (PCBs), and coprostanol. Basic sediment parameters such as organic
matter content, grain-size distribution, and mineralogy will be measured.
B.2.2.1 BASIC SEDIMENT PARAMETERS
Subsamples will be taken to determine grain-size distribution using the Buoyoucos hydrometer method. Prior to
analysis, samples will be oxidized to remove organic matter by slowly adding 3 % hydrogen peroxide until no visible
reaction occurs. A subsample of the cleaned sediment will be set aside for analysis of mineralogy by x-ray
diffraction (Royse 1970). Enough sediment for each sample will be cleaned and dried to collect 50 g of dry
sediment. Each sample will be placed in a 1000-mL volumetric cylinder and filled to the mark with a 5 % sodium
hexametaphosphate (Calgon*) solution. The mixture will be stirred thoroughly with a plexiglass plunger and the
hydrometer and thermometer placed within the cylinder. The hydrometer and thermometer will be read at 1, 5,
15, 60, and 210 min after stirring. The readings will be used to determine sand, silt, and clay fractions according
to the Bouyoucos formula (Royse 1970). Organic matter content will be measured by determining the ash-free
6B-3

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dry weight of SO g aliquots that are oven-dried at 100ฐC < n a tared aluminum cup to constant weight. The pellet
will be ignited at 500ฐC for 6 h in a muffle furnace (Baker and Wolff 1987).
B.2.2.2 HEAVY METALS AND TRIBUTYLTIN
Sediment subsamplea will be analyzed for selected heavy metals and tributyltin. Heavy metals will include the
following:
•	Copper
•	Lead
•	Zinc
•	Pซf4i^iinn
•	Chromium
•	Arsenic
•	Mercury
•	Aluminum
After acid digestion, samples will be analyzed for the trace metals (with the exception of mercury and aluminum)
by graphite furnace atomic absorption spectrophotometry. Aluminum will be analyzed by flame atomic absorption
spectrophotometry. Mercury will be analyzed in the extracts by cold-vapor atomic absorption (Battelle 1989).
Samples will be oven dried at 100ฐC and 250 mg aliquots will be placed into 100 mL Teflon flasks and 10 mL of
HN03 and 5 mL of HF added. Additional HNO3 or HF may be added to complete digestion. After a 2-hour
digestion at room temperature, 3 mL of HC104 will be added and the sample dried on a hot plate set at about
120ฐC. The residue will be dissolved in 1.0 mL of concentrated HN03 and diluted to 10.0 mL with deionized
water (Windom et al. 1989). Accuracy and precision of the analytical methods will be checked by analysis of NBS
Estuarine Sediment Reference Standards and by intercalibration with other laboratories. Specific procedures will
be described by participating laboratories in a QA/QC plan. Recommended performance criteria are presented in
Table B-2. Heavy metal concentrations will be expressed as fig metal g~' dry sediment.
Sediment subsamples also will be collected for analysis of bis(tri-n-butyltin)oxide (TBT). TBT samples will be
air-dried, ground to a fine powder with a mortar and pestle, extracted with methylene chloride, toluene, HBr and
tropoloae and derivitized. The extracts will be analyzed as total solvent extractable organotin by GC/FPD.
Concentrations will be expressed as ng g"1 (Uhler et al. 1991).
B.2.2J EXTRACTABLE ORGANIC COMPOUNDS
Sediment samples will be stored at about 4ฐC until extracted and analyzed as described below. A general
description of the analytical procedures are provided below. Specific field and analytical protocols are described
in these documents. Recommended performance criteria are specified in Table B-2. Samples will be thawed if
necessary and sample splits removed using solvent-cleaned equipment. Surplus samples will be stored under
refrigeration for reanalysis if necessary. After 30 days, surplus or archival samples will be stored below -20ฐC.
Petroleum Hydrocarbons
A first aliquot will be removed and placed in solvent cleaned flasks, extracted with methylene chloride, cleaned up
using silica gel, and analyzed by GC-FID for total petroleum hydrocarbons. Results will be reported as
concentrations in pig/g (National Research Council 198S). The results of analysis for total petroleum hydrocarbons
will be used to determine areas of significant contamination. Where high values are found, the fractions of the
samples extracted by HPLC as described below can be analyzed for more detailed measurements of aliphatic and
aromatic hydrocarbons by GC-MS.
6B-4

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Table B-2. Recommended performance criteria for analysis of heavy metal and extractable organics in sediments and tissues.

METHOD LIMITS OF
DETECTION

PARAMETER
UNITS
METHGO
SEDIMENT
TISSUE
PRECISION
(X)
ACCURACY
(X)
COMPLETENESS
(X)
CALIBRATION/STAIOARO
Al
A9/9 dry ut
FAA/GFAA
400
5.0
1
95
95
1000 ppn Al Fisher SA-442
As
jig/g dry wt
GFAA
1.0
1.0
5
95
95
1000 ppm As Fisher SA-449
Cd
lig/g dry wt
GFAA
0.01
1.0
5
95
95
1000 ppm Cd Fisher SC-118
Cr
U9/0 dry Mt
GFAA
1.0
0.1
5
95
95
1000 ppm Cr Fisher SC-192
Cu
M9/g dry wt
GFAA
1.0
0.5
5
95
95
1000 ppa Cu Fisher SC-194
Hg
fig/g dry wt
CVAA
0.01
0.05
5
95
95
1000 ppm Hg Fisher SA-114
Pb
Mg/9 dry wt
GFAA
1.0
0.1
5
95
95
1000 ppm Pb Fisher SC-21
Zn
pg/g dry wt
FAA
s.o
5.0
5
95
95
1000 ppm Zn Fisher SC-13
tributyltin
ng/g dry wt
GC-FPD
10.0
10
10
85
95
TBI Series (Alfa, Inc.)
Cythion, Permethrln
ng/g dry wt
GC-ECD
0.5
0.5
10
as
95
HIST Pesticides Standard Sol.
PCB congeners
ng/g dry wt
GC-ECD
2.0
1.0
10
85
95
NIST PCB Congeners Standard Sol.
DDT metabolites
ng/g dry wt
GC-ECD
0.5
S.O
10
8S
95
NIST Pesticides Standard Sol.
Atrazine,
Triclopyr, 2,4-0
ng/g dry wt
GC-ECD
0.5

10
85
95
NIST Pesticides Standard Sol.
Fenthion, Naled,
Temephos
ng/g dry wt
GC-NPO
0.5

10
85
95
NIST Pesticide* Standard Sol.
Methoprene
ng/g dry wt
GC-FID
0.5

10
85
95
NIST Pesticides Standard Sol.
Hexazinone,
Sul f ooieturon
Glyphosate
ng/g dry wt
GC-Hall
0.5

10
85
95
NIST Pesticides Standard Sol.
Paraquat
ng/g dry wt
HPLC
0.5

10
85
95
NIST Pesticides Standard Sol.
Coprostanol
M9/9 dry wt
GC-FID/HS
0.1

10
85
95
coprostanol; 5a-androstan-170-o1
FAA: Flame Atomic Absorption Spectrophotometry	GFAA: Graphite Furnace Atomic Absorption Spectrophotometry
CVAA: Cold Vapor Atonic Absorption Spectrophotometry	GC-ECD: Gas Chromatography-Electron Capture Detector
GC-FID: Gas Chromatography-Flame Ionization Detector	GC-NPO: Gas Chromatography-Nitrogen/PhosphorUs Oetector
GC-Hall: Gas Chromatography-Electrolyitc Conductivity Detector	GC-FPD: Gas Chromatography Flame Photometer Detector
GC/HS: Gas Chromatography Mass Spectrometry	HPLC: High Performance Liquid Chromatography

-------
Pesticides and PCBs
Hie methods for extractable organic compounds such as pesticides, PCBs, and coprostanol will observe the guidance
provided in the Phase 4 Work/Quality Assurance Project Plan for the National Status and Trends Program (Battelle
1989) and Standard Analytical Procedures of the NOAa National Analytical Facility 1985-1988, New HPLC
Geanup and Revised Extraction Procedures for Organic Contaminants (Krahn ex al. 1988) which describes the
extraction procedure summarized below.
A second aliquot (10 g) of wet sediment will be placed in a solvent-cleaned and tared bottle, and dewatered by
centrifugation and decanting. A similar weight of wet sediment will be processed for dry-weight determination.
Pesticide-grade methylene chloride, appropriate internal standards, and sodium sulfate will be added to each sample
bottle. The bottle will then be capped securely, shaken to loosen the contents and rolled overnight. After
extraction, the sample will be centrifuged and then decanted into a flask. Then, 100 mL of methylene chloride will
be added to the sediment and the bottle will be rolled for another 6 h. The sample will be centrifuged and decanted,
and then extracted further with another 100 mL of methylene chloride and rolled overnight. All three extracts will
be combined. The combined extract will be concentrated by boiling in a 60ฐC water bath to a volume of 10-15 mL.
The extract is further reduced to about 1 mL volume in a concentrator tube. Then, 3 mL of pesticide-grade hexane
will be added and the extract reduced to 2 mL. Field blanks, spiked blanks, reagent blanks, and analyte-calibration
solutions will be prepared as appropriate.
Prior to the HPLC procedure, pre-cleanup will be performed by concentrating the extract on a steam table and then
filtering by gravity through a glass wool column. The extract will be placed in a centrifuge tube and concentrated
to 1.0 mL using a tube heater. HPLC internal standards will be added to the concentrate and aliquots are
transferred to labelled GC vials for storage until analyzed. A portion of each extract will be chromatographed with
methylene chloride on a calibrated 100-angstrom size exclusion HPLC column. The chromatographed fraction will
be collected in a concentrator tube and reduced to a 1.0 mL volume using a tube heater. The procedure will be
repeated after adding 2 mL of hexane. GC internal standards (hexamethylbenzene and tetrachloro-m-xylene) will
be added and the fraction transferred to a GC vial.
The fraction will be analyzed by GC-ECD for the organophosphorus insecticide Cythion, for the pyrethroid
insecticide Pennethrin, for Total PCBs, Total DDTs, and for ROW control herbicides such as Atrazine, 2,4-D, and
Triclopyr. Fenthion, Naled, and Temephos in the extracts will be analyzed by GC-FPD or NPD. Extracts will
be analyzed by GC-FID for Methoprene, an insect growth inhibitor and by GC-Hall for Hexazinone, Sulfometuron-
methyl, and Glyphosate. Concentrations of pesticides will be expressed as nanograms per gram dry weight of
sediment (ng g'1). Any pesticides identified in samples will be confirmed by gas chromatography/mass spectrometry
(GC/MS) analysis.
Coprostanol
The fraction also will be analyzed for coprostanol by capillary gas chromatography with flame ionization
detection (FID). An aliquot will also be reacted with acetic anhydride to convert the alcohols to acetate to confirm
the analysis. The concentration of coprostanol will be expressed as microgram of coprostanol per gram dry weight
of sediment 0*g g*1).
B.2.3 Biological Body Burdens
All specimens will be stored frozen at about -26ฐC until processed. Plant samples will be cleaned with freshwater
to remove sediments and epiphytes. All samples will be freeze-dried and homogenized. Each sample will be split
for analysis of pesticides, PCBs, heavy metals, and for archival purposes.
6B-6

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Samples will be processed for organic matter content as described above for sediments. Guidance for sampling and
analytical methodology will al *> be taken from the Phase 4 Work/Quality Assurance Project Plan for the National
Status and Trends Program (Battelle 1989) and new HPLC procedures of the National Analytical Facility (Krahn
et al. 1988). Copper, lead, cadmium, chromium, arsenic, and zinc will be analyzed in samples digested with nitric
acid. These digests will be analyzed by GFAA whereas CVAA will be employed for mercury analysis. Pesticides,
PCBs, and butyltins will be analyzed in methyl chloride/hexane extracts of subsamples with a modification of the
methods described above for sediment. Tissue samples will be analyzed by GC-ECD for toxic organics that have
known bioconcentration potential. These include the organophosphoms insecticide Fenthion, PCBs, DDT
metabolites, and the herbicide 2,4-D.
References
Baker, J.M. and W.J. Wolff (eds.). 1987. Biological Surveys of Estuaries and Coasts. Cambridge University
Press, Cambridge, MA. 449 pp.
Battelle Ocean Sciences. 1989. Phase 4 work/quality assurance project plan for National Status and Trends Mussel
Watch Program. Battelle Ocean Sciences, Duxbury, MA.
EPA. 1983. Test methods for evaluating solid wastes, third edition. SW-846. Environmental Protection Agency,
Washington, DC.
EPA. 1991. Assessment and control of bioconcentratable contaminants in surface waters, draft. Environmental
Protection Agency, Office of Research and Development, Washington, DC.
Krahn, M.M., C.A. Wingren, R.W. Pearce, L.K. Moore, R.G. Bogar, W.D. Macieod, Jr., S. Chan, and D.W.
Brown. 1988. Standard analytical procedures of the NOAA National Analytical Facility, 1988: New HPLC
cleanup and revised extraction procedures for organic contaminants. NOAA Technical Memorandum NMFS
F/NWC-153.
National Research Council. 198S. Oil in the Sea. National Academy Press. Washington D.C. 601 pp.
Royse, C.F., Jr. 1970. An introduction to sediment analysis. Arizona State University. 180 pp.
Skougstad, M.W., M.J. Fishman, L.C. Friedman, D.E. Erdmann, and S.S. Duncan (Eds.). 1979. Methods for
determination of inorganic substances in water and fluvial sediments: Techniques of water-resources investigation
of the U.S. Geological Survey. Book 5, Chapter Al. 626 pp.
Uhler, A.D., G.S. Durell, and A.M. Spellacy. 1991. Extraction procedure for the measurement of Butyltin
Compounds in biological tissues using Toluene, HBr, and Tropolone. Bull. Envir. Contain. Toxicol. 47:217-
221.
Windom, H.L., S.J. Schropp, F.D. Calder, J.D. Ryan, R.G. Smith, L.C: Bumey, F.G. Lewis, and C.H.
Rawlinson. 1989. "Natural trace metal concentrations in estuarine and coastal marine sediments of the
southeastern United States." Environ. Sci. and Tech. 23:314-320.
6B-7

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B.3 SAMPLE PRESERVATION AND HOLDING TIMES
The objective of sampling in a monitoring program is generally to determine the value of a chosen parameter in the
natural environment at a particular point in space and time. In order to accomplish this, the analytical (physical,
chemical, or electrometric) method must be applied before any changes occur in the sample that is taken. While
some parameters can be reliably measured in situ or in the field, a number of parameters can only be determined
by analyzing samples in the laboratory, thereby requiring standardized methods for sampling and preservation to
maintain accuracy and repeatability. In practice, a bias or lack of accuracy in the analytical result is almost always
introduced that reflects the influence of sample collection, bottle effects, analytical error, operator error, etc. The
reported values also have associated with them a level of precision that is affected by these errors.
A number of different factors can affect the concentration of an analyte within a sample that has been removed from
its natural environment. Some constituents may be readily taken up by living organisms present in the sample,
adsorbed or absorbed by compounds naturally present in the sample or by the surfaces of the sample container, or
undergo chemical reactions or changes in valence states. Treatment or processing of the sample can also induce
changes such as cytolysis (breakdown of cells), releasing soluble and chemically active components.
No method of preservation is complete. Most recommended preservation methods attempt to do the following:
•	Minimize biological activity
•	Prevent exposure of the analyte to factors that cause the breakdown or a change in the analyte
•	Avoid volatilization
•	Minimize absorption and adsorption
There are a number of different methods for sample preservation according to the type of sample and the analyte
of interest. These methods generally involve
•	pH control
•	Addition of preservatives
•	Refrigeration
•	Freezing
One objective of an analytical chemist is to develop a sampling and analytical protocol that will determine the
concentration of an analyte in a sample that closely matches that which occurs in the natural environment. To
achieve this, good sampling and analytical protocols minimi?*; the time between removal of the sample from the
natural environment and the actual analysis for a particular parameter. Reduction of biological activity can be
accomplished by filtration and cooling to freezing temperatures. Cooling also reduces the rate of chemical reactions.
Good protocols also involvie collecting a sufficient quantity of sample such that any changes in the concentration of
an analyte that occur are minimiwH or are small relative to the total quantity of the analyte within the sample. It
is also important to choose the right type and size of sample container for holding the sample so that binding with
the container walls is minimized; proper container size also reduces the surface ata of sites for chemical reactions
and microbial growth that are common sources of biologically mediated changes in analyte concentrations. For
some parameters, proper pH control is critical to minimi™ volatilization, precipitation in high ionic strength
solutions, degradation, and changes in valences of the analyte.
Finally, the chosen method of preservation should not adversely affect the subsequent analytical method to be
performed on the sample. Some preservation methods (e.g., addition of acid for ammonia samples) would affect
the indophenol method, which occurs under basic conditions. As another example, mercuric chloride can precipitate
in autoanalyzer columns.
The recommended sample containers, preservation, and maximum holding times for parameters to be measured are
listed in Table B-3.
6B-8

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Table B-3. Florida Keys Natioi^l Marine Sanctuary
Water Quality Monitoring Program —
sample containers, preservation, and maximum holding times
ANALYSIS
SAMPLE CONTAINER
MAXIMUM HOLDING TIME

AND PRESERVATION
This Program
EPA/FDER
REQUIREMENTS
Temperature
NA
Field
Analyze
immediately
8 Salinity
NA
Field
28 d for specific
conditions
I Dissolved oxygen, membrane
NA
Field
Analyze
immediately
PH
NA
Field
Analyze
immediately
| Light attenuation coefficient
NA
Field
None
Nephelometer turbidity
HDPE or glass
12 h
48 h
Dissolved ammonia (NH4+)
HDPE or glass, filter
immediately and cool to 4ฐC
48 h
28 d at < pH 2
Dissolved nitrite/nitrate
(N02-. NO3-)
HDPE or glass, filter
immediately and cool to 4SC
48 h
48 h
28 d at < pH 2
Dissolved phosphate (P04~3)
HDPE or glass, filter
immediately and cool to 4ฐC
48 h
48 h
Total dissolved nitrogen
HDPE or glass, filter
immediately and cool to 4aC
28 d
28 d
Total dissolved phosphorus
HDPE or glass, filter
immediately and cool to 4ฐC
28 d
28 d
Total phosphorus
HDPE or glass, and cool to
4ฐC
28 d
28 d
1 Total nitrogen
HDPE or glass, and cool to
4ฐC
28 d
28 d
Non-purgeable organic
carbon/inorganic carbon
HDPE or glass, Cool to 4ฎC
and refrigerate at 2ฐC
7 d
None
Chlorophyll a
HDPE or glass, filter
immediately, freeze at -15ฐC
48 h
None
Alkaline phosphatase activity
HDPE or glass. Hold at
ambient temp, in the dark
12 h
None
I Basic sediment parameters
Acid-washed glass or HDPE,
cool to 4ฐC, store at 0ฐC
until analyzed
Analyze
within 28 d
Not specified
6B-9

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Table B-3. Florida Keys National Marine Sanctuary
Water Quality Monitoring Program —
sample containers, preservation, and	holding times (continued)
[ ANALYSIS
SAMPLE CONTAINER
MAXIMUM HOLDING TIME

AND PRESERVATION
This Program
EPA/FDER
REQUIREMENTS
Sediment heavy metals except
Hg
Nitric acid and solvent
washed glass, Teflon-lined
cap, cool to 4ฐC, store at
0ฐC until analyzed
Analyze
within 28 d
Analyze within
6 mos (soils)
Sediment Hg
Nitric acid and solvent
washed glass. Teflon-lined
cap, cool to 4ฐC, store at
0ฐC until analyzed
Analyze
within 28 d
Analyze within 28 d
Sediment tributyltin
Nitric acid and solvent
washed glass. Teflon-lined
cap, cool to 4#C, store at
0ฐC until analyzed
Extract within
7 d, analyze
within 28 d
Extract within 14 d,
analyze within 40 d
Sediment pesticides
Solvent washed glass,
Teflon-lined cap, cool to
4ฎC, store at 0ฐC until
analyzed
Extract within
7 d, analyze
within 28 d
Extract within 14 d,
analyze within 40 d
Sediment PCBs
Solvent washed glass.
Teflon-lined cap, cool to
4ฐC, store at 0ฐC until
analyzed
Extract within
7 d, analyze
within 28 d
Extract within 14 d,
analyze within 40 d
Sediment petroleum
hydrocarbons
Solvent washed glass,
Teflon-lined cap, cool to
4ฐC, store at 0ฐC until
analyzed
Extract within
7 d, analyze
within 28 d
Extract within 14 d,
analyze within 40 d
Sediment coprostanol
Solvent washed glass,
Teflon-lined cap, cool to
4ฐC, store at 0ฐC until
analyzed
Extract within .
7 d, analyze
within 28 d
Extract within 14 d,
analyze within 40 d
I Tissue heavy metals and
| tributyltin
Polyethylene bags, cool to
4ฐC, store at 0ฐC until
analyzed.
Extract within
7 d, analyze
within 28 d
Not specified
1 Tissue pesticides, PCBs
Polyethylene bags, cool to
4ฐC, store at 0SC until
analyzed
Extract within
7 d, analyze
within 28 d
Not specified
6B-10

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B.4 ANALYTICAL METHODS
Analytical methods are provided below for the parameters included in the water quality monitoring program. Where
appropriate, alternate manual methods are provided for aiitnmanปH wet chemistry procedures to cover contingencies.
"ITie methods follow the format of EPA (1984).
•	Ammonium NH4* (colorimetric,	small volume, low to high range).
•	Ammonium NH4* (spectrophotometry, manual, small volume, low to mid range).
•	Ammonium NH4* (fluorometric, automated, small volume, ultralow range).
•	Nitrite NOj- (colorimetric, automated, small volume, low to mid range).
•	Nitrate NO3- (cadmium reduction, colorimetric, automated, small volume, low to medium range).
•	Nitrite N02" (spectrophotometry, manual, small volume, low to medium range).
•	Nitrate NO3- (cadmium reduction, colorimetric, automated, small volume, low to medium range).
•	Total nitrogen and total dissolved nitrogen (high temperature combustion, gas chromatography).
•	Total nitrogen and total dissolved nitrogen (persulfate digestion, spectrophotometry, manual, large volume).
•	Soluble reactive phosphorus/orthophosphate P04~3 (colorimetric, automated, small volume, low to mid
range).
•	Soluble reactive phosphorus (spectrophotometry, manual, medium volume, low range).
•	Soluble reactive phosphate and total dissolved phosphate (co-precipitation/spectrophotometry/colorimetry,
manual/automated, high volume, ultralow range).
•	Total phosphorus and total dissolved phosphorus (high temperature digestion, manual, small volume, low
range).
•	Non-purgeable organic carbon and inorganic carbon (high temperature combustion with infra-red detection,
automated, small volume, low to high range).
•	Chlorophyll a and phaeophytin concentrations (fluorometric, manual).
•	Alkaline phosphatase activity (fluorometric, manual).
6B-11

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ammonium nh4+
(Colorimetric, automated, small volume, low to high range)
. Scope and Application
1.1 This method is applicable for the determination of ammonium in terrestrial groundwater, submarine
groundwater, marine, and estuarine water containing ammonium in the 0.1-30.00 pM range. Higher
concentrations may be analyzed after dilution. The method is recommended for large numbers of samples
when logistical considerations require small volumes of samples.
. Summary of Method
2.1 Alkaline phenol and hypochlorite react to form indophenol blue. The blue color formed is intensified with
sodium nitroprusside. The color is proportional to the concentration of ammonium in the sample.
Sample Handling and Preservation
3.1	Water samples are filtered through Whatman GF/F glass fiber filter immediately after collection. Filtered
samples are refrigerated at 4 ฐC until analyzed within 48 h.
3.2	Submarine or terrestrial groundwater containing a significant amount of sulfides are acidified with IN HC1
and purged prior to analysis.
3.3	HDPE or glass containers may be used after acid-washing with ammonia-free dilute HC1 solution.
4.	Interferences
4.1	Calcium and magnesium can precipitate during analysis. A sodium potassium tartrate solution is used to
prevent precipitate formation.
4.2	High concentrations (millimolar) of sulfide or the low redox potential associated with the sample can cause
interference in the indophenol method during color development.
4.3	Metal-sulfide salts can also precipitate in the flow cells of an autoanalyzer and degrade them.
4.4	Sample color or turbidity that absorbs in the photometric range may also interfere.
4.5	At low ranges, sample contamination from atmospheric sources is common. Ammonia analysis should
be conducted in a very clean environment. Strong ammonia solutions should not be used in the laboratory
during the analysis.
4.6	At low ranges, scrupulously clean labware is required. If the acid-wash can be kept free from ammonia,
labware should be acid-washed and thoroughly rinsed with copious deionized water immediately before use.
Unless labware is rinsed free of acid, the residual acid may act as a scavenger of ammonia from the
atmosphere.
5.	Apparatus and Materials
5.1 The Technicon Autoanalyzer Unit or Alpkem Rapid Flow Analyzer (RFA) Unit consist of a
•	Sampler
•	Manifold or analytical cartridge
•	Proportioning pump
•	Temperature control
•	Colorimeter
•	Recorder or integrator
6.	Reagents
6.1	Ammonia-free Deionized Water: Only fresh deionized water should be used in this analysis. Deionized
water that has been stored is subject to contamination from the air. Distilled water may be used after
passing it through a deionizing column With strong acidic cation and strongly basic anion resins. [NOTE:
All solutions must be made up with ammonia-free deionized water.]
6.2	Synthetic Seawater or Gulfstream Water: Standard solutions and cuvette blanks should be made up with
ammonia-free solutions of the same ionic strength as the samples. The recommended matrix is Sargasso
Sea or Gulfstream axis water that has been filtered through pre-combusted glass fiber filters. If this is not
available, synthetic seawater may be made up with low-nitrogen analytical grade chemicals as follows:
6B-12

-------
•	NaCl - 31 g/L
•	MgS04- 7HjO — 10 g/L
•	NaHCOj - 0.05 g/L
6.3	Formulations of the following reagents according to the instrument manufacturer's specifications:
•	Hypochlorite solution
•	Sodium hydroxide solution
•	Sodium citrate solution
•	Phenol/nitropmsside solution
6.4	Ammonia Standard Stock Solution: Dissolve 100 mg ammonium sulfate (NH^jSC^ in deionized water and
make up to 1 L. Preserve with 1 mL chloroform. Store in glass at 4 #C. This solution is stable for
several months if well stoppered.
1 mL of the stock solution contains 1.5 fig atoms NH4*.
Prepare dilutions for high range standards with Gulfstream water as follows:
mL of stock
dilute to
uM concentration
2.0
100 mL
30.00
1.0
100 mL
15.00
0.5
100 mL
7.50
0.2
100 mL
3.00
Prepare dilutions for low range standards with Gulfstream water as follows:
mL of stock
dilute to
uM concentration
0.10
100 mL
1.50
0.05
100 mL
0.75
0.02
100 mL
0.30
0.01
100 mL
0.15
Procedure
7.1	Allow electronics to warm up and stabilize.
7.2	Set up the manifolds or cartridges according to the manufacturer's instructions for the appropriate range.
7.3	Run the proportioning pump at the recommended speed while feeding deionized water through the sample
line and obtain a stable baseline with reagents.
7.4	Place the appropriate ammonium standards in the sampler in order of decreasing concentration and
complete loading of the sample tray with unknown samples.
7.5	Switch sample line to sampler and start analysis.
Calculation
8.1 Prepare appropriate standard curves derived from passing NH4* standards through the autoanalyzer
manifold. Compute sample concentrations by comparing sample peak heights against standard curve. While
sample concentrations may be automatically computed, a record of absorbancies of the blanks and standards
should be kept.
Precision and Accuracy
9.1 At the 1 /xM range with a 10-cm path length, the precision should be better than ฑ 0.05 /iM.
6B-13

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References
EPA. 1984. Methods for chemical analysis of water and wastes. EPA-600/4-79-020. Environmental Protection
Agency, Office of Research and Development, Environmental Monitoring and Support Laboratory, Cincinnati,
OH.
Koroleff, F. 1983. Determination of ammonia. In K. Grassoff, M. Erhardt, and K. Kremeling, Methods of
seawater analysis. Verlag Chemie, Weinheim, Germany.
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AMMONIUM NH4+
(Spectrophotometric, manual, small volume, low to mid-range)
1.	Scope and Application
1.1 This method is applicable for the determination of ammonium in terrestrial groundwater, submarine
groundwater, marine, and estuarine water containing ammonium in the 0.1-30.00 /iM range. Higher
concentrations may be analyzed after dilution. The method is recommended as an alternative to automated
procedures when at least 10 mL of sample is available. The method is modified from the procedures
described by Koroleff (1983).
2.	Summary of Method
2.1 This method is based on the formation of the blue color of indophenol by phenol and hypochlorite in the
presence of ammonia.
3.	Sample Handling and Preservation
3.1	Water samples are filtered through Whatman GF/F glass fiber filter immediately after collection. Filtered
samples are refrigerated at 4 ฐC until analyzed within 48 h.
3.2	Submarine or terrestrial groundwater containing a significant amount of sulfides are acidified with IN HCI
and purged prior to analysis.
3.3	HDPE or glass containers may be used after acid-washing with ammonia-free dilute HCI solution.
4.	Interferences
4.1	Calcium and magnesium can precipitate during analysis. A sodium potassium tartrate solution is used to
prevent precipitate formation.
4.2	High concentrations (millimolar) of sulfide or the low redox potential associated with the sample can cause
interference in the indophenol method during color development.
4.3	Sample color or turbidity that absorbs in the photometric range may also interfere.
4.4	At low ranges, sample contamination from atmospheric sources is common. Ammonia analysis should be
conducted in a very clean environment. Strong ammonia solutions should not be used in the laboratory
during the analysis.
4.5	At low ranges, scrupulously clean labware is required. If the acid-wash can be kept free of ammonia,
labware should be acid-washed and thoroughly rinsed with copious deionized water immediately before use.
Unless labware is rinsed free of acid, the residual acid may act as a scavenger of ammonia from the
atmosphere.
5.	Apparatus and Materials
5.1	10 mL automatic pipettes
5.2	0.3 mL automatic pipettes
5.3	100 mL volumetric flasks
5.4	Spectrophotometer
5.5	Cuvettes
6.	Reagents
6.1	0.5 N Sodium Hydroxide: Dissolve 20 g NaOH in deionized water and dilute to 1 L.
6.2	REAGENT A. Trisodium Citrate Reagent: Dissolve 30 g trisodium citrate dihydrate (C^HjNajC^ • 2HjO)
in ca. 60 mL deionized water. Add 2.5 mL of 0.5 N NaOH. Store in refrigerator in glass with plastic
or glass stopper.
6.3	REAGENT B. Phenol Reagent: Dissolve 9.5 g C6H5OH (phenol) or 10.8 mL of 8896 phenol stock
solution and 100 mg of disodium nitroprusside dihydrate (Na2Fe(CN)jNO * 2HiO) in deionized water and
dilute to 250 mL. Store in refrigerator in amber glassware; it will be stable for months.
6.4	REAGENT C. Hypochlorite Reagent: Dissolve 0.05 g of Trione (dichloroisocyanuric acid) in 20 mL of
0.5 NaOH. [NOTE: Prepare a fresh solution each day.]
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6.5 Ammonia Standard Stock Solution: Dissolve 100 mg amnonium sulfate, (NH^SO^ in deionized water
and dilute to 1 L. Preserve with 1 mL chloroform. Store in glass at 4 ฐC. This solution is stable for
several months if well stoppered.
1 mL of the stock solution contains 1.5 fig atnme N-NH^+.
Prepare dilutions with deionized water as follows:
ml ctficlc
dilute to
uM concentration
1.00
0.50
0.20
0.10
0.05
100
100
100
100
100
15.0
7.5
3.0
1.5
0.75
7. Procedure
7.1	Rinse test tubes and caps once with 15% HC1 and four times with deionized water immediately before
starting the procedure. Shake out excess drops of water and keep tubes inverted and capped until used.
7.2	To avoid contamination of samples and reagents, all containers should be tightly capped until needed for
use.
7.3	Pipette 10 mL of sample into a test tube. To each test tube:
a)	Add 0.3 mL of Reagent A and shake/vortex.
b)	Immediately add 0.3 mL of Reagent B and shake/vortex.
c)	Immediately add 0.3 mL of Reagent C and shake/vortex.
7.4	Cap the tubes tightly with para film. Let the reaction proceed in the dark for at least 6 h, preferably
overnight.
7.5	Prepare blanks and standards by adding reagents as above to 10 mL volumes of seawater water blanks and
standards. Allow color development to proceed for at least 6 h.
7.6	When samples and standards are ready for the reading of absorbance, prepare reagent blanks using 10 mL
of seawater. Add reagents as above. Measure absorbance immediately.
7.7	Set the spectrophotometer to 630 nm wavelength and adjust to read zero with Gulfstream water or synthetic
seawater in a 1 cm pathlength cuvette. Longer pathlengths will increase sensitivity proportionately.
8.	Calculation
8.1 Compute sample concentrations by comparing sample peak heights against standard curve. While sample
concentrations may be automatically computed, a record should be kept of the absorbances of the blanks
and standards.
9.	Precision and Accuracy
9.1 At the 1 level, precision should be better than 0.1 #tM with a 1-cm path length.
Koroleff, F. 1983. Determination of ammonia. In K. Grassoff, M. Erhardt, and K. Kremeling. Methods of
seawater analysis. Verlag Chemie, Weinheim, Germany.
References
6B-16

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AMMONIUM NH4+
(Fluorometric, automated, small volume, ultraiow range)
1.	Scope and Application
1.1 This method is recommended for use in natural (fresh or seawater) waters containing nanomolar ranges
of ammonium (NH4'h). The method is an improvement over the method of Aoki et al. (1983) and
Willason and Johnson (1986). Up to 30 samples in the nanomolar range may be analyzed with this
method.
2.	Summary of Method
2.1 Ammonium in nanomolar concentrations are analyzed by diffusion of ammonia gas (NH3) through a Teflon
membrane into a o-phthaldialdehyde solution where a fluorescent complex is formed. Ammonium in
solution is converted to ammonia gas under basic conditions. The concentration of fluorescent material
is measured in a fluorometer. The carrier solution is acidified to < pH 3 which maintains any
contaminating ammonia in the carrier in solution. The NaOH-citrate solution is stripped of ammonia
contaminants by passing the solution through a micro porous Teflon column immersed in 1096 sulfuric acid.
3.	Sample Handling and Preservation
3.1 Water samples are filtered through Whatman GF/F glass fiber filter immediately after collection. Filtered
samples are refrigerated at 4 ฐC until analyzed within 48 h. Do not preserve samples with mercuric
chloride or by addition of H2SO4.
4.	Interferences
4.1	Dissolved free amino acids (DFAA) were reported not to cause significant interferences. The low
concentrations of volatile amines in the natural environment will cause only minimal interferences.
4.2	At these very low ranges, sample contamination from atmospheric sources is common. Ammonia analysis
should be conducted in a very clean environment. Strong ammonia solutions should not be used in the
laboratory during the analysis.
4.3	Scrupulously clean labware is required. If the acid-wash can be kept free of ammonia, labware should be
acid-washed and thoroughly rinsed with copious deionized water immediately before use. Unless labware
is rinsed free of acid, the residual acid may act as a scavenger of ammonia from the atmosphere.
5.	Apparatus and Materials
S. 1 The apparatus consists of the following components:
Autoanalysis tubing:
Tube ratings Effective flow at 25 % of pump rate
Carrier solution: 0.60 mL min~' l.OOmLmin'1
NaOH-citrate: 0.05 min-' 0.09 ml. min — 1
OPA solution 0.32 mL min"1 0.61 mL min~!
Samples:	1.20 mL min-' 2.03 ml. min~'
Ammonia stripping block (I m 2.0 mm i.d., 2.0 fim poresize, W.L. Gore Co.)
Proportioning pump (Ismatec 16-channel, Coleman Instrument Co.)
Injection loop (1.0 mL)
Injection valve (Teflon rotary, Rheodyne Inc.)
Diffusion cell (30.1 cm Technicon AAII block difluser, A-87-03 Technicon)
Teflon diffusion membrane (nonlaminated hydrophobic Goretex, 0.45 pm poresize,
W.L. Gore Co.)
PTFE mixing coil (25 cm)
Constant temperature cabinet (35 ฑ 0.2 ฐC)
Fluorescence Detector (Hitachi F-1050, excitation 335 am; emission 470 nm;
time constant, 3 sees; sensitivity, 100, Hitachi, Ltd.)
Computer control system (E-Lab Lab integration package, OMS Tech)
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6. Reagents
6.1	0.25 M Borate Buffer Dissolve 15.46 g of reagent giade H3BO4 in 1000 mL of deionized water adjusted
to pH 9.50 with 10N NaOH.
6.2	OPA Reagent: Dissolve 100 mg of o-phthaldialdehyde (Sigma Chem. Co) in 2 mL of methanol and 500 /il
of 2-mercaptoethanol (Sigma) and add to 1000 mL of 0.25 M borate buffer in a clean amber glass bottle.
Deoxygenate the solution for 20 min by bubbling 200 mL Oj-free Nj per minute. Allow to stand for 24
h prior to use to let background fluorescence decay. Store capped at room temperature. Use reagents
within 72 h after preparation.
6.3	NaOH-sodium citrate: Dissolve 200 g of reagent grade sodium citrate and 18.0 g NaOH in 950 mL of
deionized water. Store in tightly capped HDPE or glass bottle with silicone stopper with the headspace
purged with N2.
6/4 Carrier Solution: Add 8 mL concentrated H2S04 to 4,000 mL of deionized water. Store in tightly capped
HDPE or glass bottle with silicone stopper with the headspace purged with N2.
6.5	10% H2S04: Store in tightly capped HDPE or glass bottle with silicone stopper with the headspace purged
with N2.
6.6	Ammonium Standard Stock Solution: Dissolve 100 mg ammonium sulfite, (NH^SO^ in deionized water
and dilute to 1 L. Preserve with 1 mL chloroform. Store in glass at 4 ฐC. This solution is stable for
several months if well stoppered.
1 mL of the stock solution contains 1.5 fig atoms N-NH^.
6.7	Ammonium Standard Working Solution: Dilute 1 mL of the ammonium standard to 1000 mL.
1 mL of the working solution contains 1.5 ng atoms N-NH^.
Prepare selected dilutions with filtered Gulfstream water as follows:
mL of stock
dilute to
nM concentration
100.0
use as is
150.0
50.0
100 mL
75.0
20.0
100 mL
30.0
10.0
100 mL
15.0
5.0
100 mL
7.5
2.0
100 mL
3.0
1.0
100 mL
1.5
Procedure


7.1	Allow the electronics and temperature cabinet to warm up to stable temperature.
7.2	Run the proportioning pump at 25% of full speed and obtain a stable baseline by running deionized water
and all reagents through the sample line.
7.3	Place the appropriate ammonium standards in the sampler in order of decreasing concentration and
complete loading of the sample tray with unknown samples.
7.4	Switch sample line to sampler and start analysis.
8.	Calculation
8.1 Prepare appropriate standard curves derived from passing NH4+ standards through the autoanaiyzer
manifold. Compute sample concentrations by comparing sample peak heights against standard curve.
9.	Precision and Accuracy
9.1 Jones (1991) reported a limit of detection of 1.1 nM using Sargasso Sea seawater and 1.2 nM using
deionized water. He reported a standard deviation of 0.25 nM for an analysis of 5 replicate Gulfstream
samples with a mean concentration of 18.1 nM.
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References
Aoki, T., S. Uemun, and M. Munemari. 1983. "Continuous fl