United States Region 4
Environmental Protection 345 Courtland St. NE.
Agency Atlanta, GA. 30365
EPA 904/9-80-051
September 1980
Environmental Final
Impact Statement
Estech Genera I
Chemicals Corporation
Duette Mine
Manatee County, Florida
Library/Region IV
U. S. Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Georgia 30308
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
for
Proposed Issuance of a New Source National
Pollutant Discharge Elimination System Permit
to
Estech General Chemicals Corporation
Duette Mine n «
Manatee County, F1 or i da ^ IV
prepared by: - -r> r-'.
i' . V- V. ^
U.S. Environmental Protection Agency- . - ... *>7.
Region IV, Atlanta, Georgia 30365
cooperating agency:
U.S. Army Corps of Engineers
Jacksonville District
Jacksonville, Florida 32201
Estech General Chemicals Corporation has proposed an open
pit phosphate mine, beneficiation plant and rock dryer
on a 10,394 acre site in northeastern Manatee County,
Florida. Mining will involve 6,600 acres, most of which
will be reclaimed, and will produce 3 million tons per
year for 21 years. The EIS examines alternatives, impacts
and mitigatlve measures related to surface water, ground-
water, air, wetlands, and other natural and cultural
s y s t ems .
Comments will be received until October 12, 1980
Conrments or inquiries should be directed to
A. Jean Tolman, EIS Project Officer
U.S. Environmental Protection Agency
Reg i on IV
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 881-7458
approved by:
Rebecca W. Hanmer Date *
Regional Administrator
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Summary Sheet For Environmental
Impact Statement
Duette Phosphate Mine
Estech General Chemicals Company
( ) Draft
(X) Final
U. S. Environmental Protection Agency, Region IV
345 Courtland Street NE
Atlanta, Georgia 30365
1. Type of Action : Administrative (X) Legislative ( )
2. Description of Action
Estech General Chemica1s torpor ation is proposing to construct
and operate a phosphate mine beneficiation plant, and rock drying
facility in northeastern Manatee County, Florida. The EPA Region
IV Administrator has declared the proposed facilities to be a
new source as defined in Section 306 of the Federal Clean Water
Act.
In compliance with its responsibility under the National
Environmental Policy Act (NEPA) of 1969, EPA Region IV has
determined that the issuance of a new source National Pollutant
Discharge Elimination System (NPDES) permit to the proposed
mining and beneficiation facility would constitute a major
Federal action significantly affecting the quality of the human
environment. Therefore, this Environmental Impact Statement
was prepared in accordance with the requirements of NEPA and
EPA regulations at 40 CFR Part 6.
The proposed facility, the Duette Mine, encompasses 10,394 acres
of which approximately 6,600 acres are deemed mineable according
to present economic, environmental and technological limita-
tions. The mining operation is planned to nominally produce
3 million tons of phosphate ore annually for a period of 21
years. Estech presently operates the Watson and Silver City
Mines in southwestern Polk County, Florida. The Duette Mine
will serve as a replacement for these facilities as their
production expires.
Components of the proposed facilities include two draglines with
50 cubic yard buckets; hydraulic ore transportation via pipelines
to a central washer for ore disaggregation and pebble recovery;
a feed preparation and flotation plant for extraction of finer
phosphates; a drying facility to reduce moisture in the phosphate
rock from 13% to 2%; and shipment via rail.
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Operation of the proposed facilities requires a mining plan,
a water management system, and an integrated waste disposal
reclamation plan.
The mining plan proposed by Estech calls for the preservation
of the majority of the sensitive or unique natural vegetation.
The preservation areas include the sole cypress stand on the
site (18 acres), a 50 acre stand of sand pine scrub, and the
wooded floodplains of the major streams. The mining plan as
originally proposed by Estech and evaluated in the DEIS also
called for mining a three-quarter mile segment of the East Fork
of the Manatee River. In accordance with EPA's recormnendat ion
in the DEIS, Estech has revised its proposal to exclude mining
of that segment. To protect wetlands along streams, the mine
plan incorporates active mining along only one side of a wetland
a t a t ime .
The proposed disposal plan will utilize a sand-clay mix in the
approximate ratio of 2.5 to 1 (by weight). A single 480 acre
conventional clay settling area is proposed to receive all clay
wastes generated before the sand-clay mix procedure becomes
operational. It will remain active throughout the mine life
to receive clay wastes in excess of the sand-clay mix require-
ments and to serve as a supplemental water clarification and
storage area. Sand tailings in excess of the amounts required
in the sand-clay mix process will be deposited in mining cuts.
The proposed water management plan divides the needed supply
between surface and ground-water resources, minimizes mining
process consumption, and provides for recharge of the Floridan
Aquifer. The Consumptive Use Permit issued by the Southwest
Florida Water Management District allows groundwater withdrawal
at a rate of 13 mgd for the first 3 years. During this time,
a 200 acre surface water reservoir will be constructed to provide
storage for 3 mgd, thereby decreasing groundwater use to 10 mgd.
Prior to withdrawal, a recharge system will be constructed to
transmit water from the surficial aquifer into the deep system.
The proposed reclamation plan will be accomplished by the
physical restructuring and refilling of disturbed sites followed
by revegetation. The proposed methodology is designed to return
the site to land forms compatible with its rural, agricultural
setting. The reclaimed site will consist of improved pasture,
marsh and wetland environments, five lakes, and a 100 acre
"wilderness" area allowed to revegetate naturally. The proposed
plan aims to provide long range water quality and biological
diversity as well as aesthetic values in land form diversity,
wildlife protection, recreational uses, and water resources.
3. Alternatives Considered
A. Beneficiation plant sites were evaluated to minimize loss
of phosphate resource, water pumping, ore and waste transpor-
tation, road and utility construction, and destruction of
environmentally sensitive areas. Six sites were considered.
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B. Production rate alternatives were evaluated considering both
environmental and economic parameters. Environmental aspects
considered included rate of habitat a 1teration/destruction, rate
of groundwater withdrawal, and level of air emissions. Economic
considerations included production costs, overall rock demand
and growth, and Estech's present production and marketing.
Alternatives were selected to evaluate the effects of various
production rates rather than to designate an optimum production
rate.
C. Resource recovery alternatives were evaluated with
consideration given to impacts on environmental resources and
recovery of mineral resources. The primary consideration was
phosphate ore underlying forested swamps or marsh areas.
D. Mining methods were evaluated to assess ore recovery rates,
energy use, water use and conservation, environmental resources,
and safety. Alternatives examined were electric draglines,
dredges, bucket wheel excavators, and technique combinations.
E. Ore transportation alternatives were evaluated considering
the factors of technical and operational feasibility, cost,
energy use, water conservation, and impact to the environment.
Conventional slurry pumping, conveyors, and trucks were
transportation methods considered.
F. Beneficiation process alternatives were evaluated for energy
and water use efficiencies within proven state-of-the-art
technology. Alternative processes considered were conventional
beneficiation, total acidulation, and blast furnace.
G. Process water sources were evaluated to conserve the regional
resource while providing a sufficient quality and quantity of
water. Supply alternatives considered were use of surface water
and groundwater, total requirement from the Floridan Aquifer,
use of surface water in rainfall catchment, and use of water
from the surficial aquifer.
H. Waste disposal and reclamation plans were evaluated for
methods to dispose of sand and clay wastes in a manner that
economically restores disturbed land to a productive state.
Physical restoration and revegetation were considered in light
of existing and planned environmental systems.
I. Surface water discharge alternatives were evaluated from
two respects: volume of water discharges and point of discharge.
Volume alternatives considered containment of long term
accumulation, containment of short-term accumulation, containment
to offset evaporation losses only, and no containment. Eight
points of discharge were evaluated. Each alternative was
discussed in terms of environmental impacts, water use and
economi cs.
3. Rock drying alternatives were evaluated to select an
alternative which provided dry rock for shipping and met air
quality standards. Alternatives assessed were construction of
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a dryer at the mine site, use of an existing dryer, construction
of a dryer at a remote location, and shipment of wet rock.
K. Transportation and energy source alternatives were evaluated.
Transportation alternatives included railroad with truck as
emergency mode, trucks only, pipeline to port, and conveyor.
Energy source alternatives assessed were cormnercia 11y available
electric power and various methods of on-site generation.
L. A no-action alternative was evaluated considering
environmental and socioeconomic impacts of not constructing the
mine, beneficiation plant, or rock drying facility.
if.. Surrmary of Major Environmental Effects
Each of the selected alternatives was integrated into the appro-
priate land or water management strategy: the mining plan, waste
disposal/reclamation plan, and water management plan, collective-
ly the proposed activity. Environmental impacts of the proposed
activity were then assessed. The major emphasis of the impact
assessment was to identify means of minimizing the degree and
extent of negative impacts caused by the mining operation at
any one time and to minimize the permanent alteration and/or
destruction of natural systems and environmental resources.
The direct effect of mining will be the physical destruction
of much of the present natural vegetation and the alteration
of the site's soils and topography. The proposed reclamation
plan is intended to mitigate the long-term negative impacts of
the mining operation. Major impacts to three major systems are:
Land - Overall, 85% of the native upland vegetation will be lost.
Reclamation is designed to replace most natural land com-
munities with improved pasture, thereby largely precluding
the re-establishment of original vegetation. A 50 acre
stand of sand pine scrub is marked for preservation.
Land-Water Interface - Due to the uncertainties of wetland
restoration, only Category 2 and 3 wetlands will be mined.
Of these, approximately 421 acres of freshwater swamps and
364 acres of freshwater marshes will be destroyed. Pro-
posed reclamation will attempt to restore these acreages
and contribute additional acres of land-water interface
for a net gain, if successful, of approximately 15%.
Water - The direct impact of mining will be the destruction of
417 acres of ephemeral feeder streams and their flood-
plains. The remaining aquatic areas will suffer stress
resulting from changes in temperature, sunlight, erosion,
water table drawdown, and addition of various chemicals.
The wooded floodplains of the major streams are excluded
f ran mining.
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Mining will create several lakes on the site, which is
a significant expansion of the aquatic environment.
The proposed activity will signjficant1y alter the site's
original topography through strip mining and waste clay disposal
activities. The long-term, net effects on topography are
directly reflected in the proposed reclamation, which largely
returns the site to pre-mining elevation and relief. On-going
reclamation will limit the number of acres disturbed at any given
time to about 700-800 acres.
Proposed mining will disturb the existing soils on approximately
75% of the site. Existing soil profiles will be destroyed and
in general the surface horizon will be buried. Waste disposal
and physical reclamation will result in three new types of
surface soils: clay, sand-clay, and overburden. Each of the
new reclaimed soil types has distinct agricultural and
engineering properties that relate to post-rec lamation land use
potent ial .
The average annual groundwater withdrawals will be limited to
13 mgd less recharge of 3"mgd for a total net consumption of
10 mgd. During the fourth year of mining, approximately 2.88
mgd of water will be diverted from the East Fork of the Manatee
River to a surface water storage reservoir.
The primary effect of withdrawals from the deep groundwater
system is the lowering of the potentiometric surface within the
area of influence of the wells. This effect will be extremely
small in comparison to the large seasonal fluctuation. Potential
impacts to water quality in the deep aquifer system may be caused
by the dewatering/recharge projects which directly transmit water
from the shallow system to the deep aquifer system. Monitoring
of the quality of water being discharged is required by the
Southwest Florida Water Management District.
The primary effect of the mining on the shallow groundwater
system will be the lowering of the water level within the system
by the dewatering and/or recharge wells.
The proposed reclamation project may cause changes in water
quality in the surficial aquifer as well as changes in on-site
flow patterns within the surficial aquifer.
During active mining, stream flow into Lake Manatee will decrease
by approximately 9%. After reclamation the average flows of
the East and North Forks of the Manatee River will be reduced"
approximately 0.7 mgd and 0.6 mgd respectively. This decrease
will be the result of increased impoundments in lakes and marshes
and the sand/clay mix land fills. The major drainage courses
on the mine site will be left undisturbed.
Discharges to streams leaving the proposed mine site from the
plant water system may be necessary due to temporal variation
in rainfall. It is anticipated that approximately 1.9 mgd will
be discharged into the East Fork of the Manatee River during
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August and September of an average rainfall year; effluent will
be discharged at a rate of 1.8 mgd into the North Fork during
August, September, and October.
The proposed mining may be expected to contribute both primary
and secondary air quality effects. Primary effects will be
contributed by the operation of two phosphate rock dryers,
storage, materials handling, and shipping facilities, as well
as fugitive dust from land clearing and reclamation activities.
Secondary effects will be contributed by population, commercial,
and industrial development induced by the proposed project.
Primary emissions from the rock dryers and associated facilities
are very fine clay and phosphate rock particulates and by-
products of the combustion of fuel oil, e.g., sulfur dioxide
and ash. The proposed sources will not violate air quality
standards nor significantly degrade air quality. SC^and
particulate matter emissions will satisfy New Source Performance
Standards and BACT.
There are no significant noises associated with mine-related
activities that could be considered intrusive or detrimental
to sensitive receptors because of spectral content or
intermi t tency.
A potential direct impact of mining and beneficiation is that
of occupational radiation exposure. The primary exposure areas
are the rock pile transfer tunnels. The Duette operation, having
both a plant design including properly ventilated tunnels and
a lower product radioactivity level than the general mining
region, should not exhibit adverse occupational exposure. The
proposed fugitive dust control on dryer emissions should also
limit off-site transport of airborne radioactivity to the point
where annual dose cannot be measured within the statistical
variation of natural background.
Upon completion of mining, reclaimed lands will have different
radiological characteristics than the land before mining.
Considering future agricultural uses of the site, the most
important pathway is the direct uptake of radium-226 by row crops
grown on the reclaimed clay settling area. Although the radium
content is highest here, the land will be agriculturally suited
for row crops. Study results suggest that the excess
availability of the major cations produce a discrimination
against uptake of Ra++ in the clay soils containing higher than
normal radium-226. Regarding future residential development
of the site, predicted indoor radon progeny levels indicate only
the reclaimed settling area may produce levels requiring remedial
action. The predicted clay land form indoor radon progeny level
is 0.015 WL (working level). If the clay settling areas are
excluded for structural reasons or topsoil replacement occurs,
no reclaimed lands are predicted to produce homes with radon
progeny levels near the 0.02 WL remedial action level.
Surface water radium-226 concentrations in off-site environs
may be elevated from natural levels of 0.8 pCi/1 to 2 pCi/1.
The drinking water standard for radium-226 is 5 pCi/1. The
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groundwater radium-226 concentrations at the site are between
0.8 and 6 pCi/1 and are less than those observed in some non-
mining regions. Radium-226 levels in groundwater appear to be
associated with local subsurface conditions which are below the
zone of surface mining influence.
The socioeconomic impact of the proposed mining will exhibit
a generally beneficial effect. Operation of the mine will
directly require 324 workers, many of which will be relocated
employees of the applicant. Some workers will be obtained from
the Manatee County labor force. The direct economic effects
of the mine are favorable, producing approximate annual yields
of $382,400 in sales tax, $1.92 million in severance tax and
$1,982 million in Ad Valorem tax. Regional economy effects
derived through standard multipliers indicate an annual indirect
impact of $35.4 million and an annual induced impact of $118.4
million. Estimated employment associated with the activity is
similarly projected to be 235 through indirect impact and 1425
through induced impact. The mine will exert no directly
discernable effects on cqrrmunity services and facilities as the
operation will be self-sufficient in terms of minor medical
treatment, water supply, fire and police protection, solid waste
disposal and internal transportation facilities. The mine will
not measureably increase demand on regional facilities for
education, major medical treatment, recreation and
t ranspor tat ion.
Long-term land use patterns should not be adversely impacted
by the mining activity. The site is proposed for agricultural
uses in the Manatee County Comprehensive Plan. The planned mine
reclamation program is designed to return the site to land forms
amenable to a variety of agricultural uses. On the short-term,
the proposed mine site is located between two approved phosphate
mines and therefore should not disrupt near-future land use
trends in the area.
The no-action alternative of not constructing the mine,
beneficiation plant, or rock drying facility would exert little
effect, positive or negative, on regional or local projections
for population growth, economic growth, or demands for community
services and facilities. Economic benefits of the proposed mine,
both from taxes and from the projected annual expenditures by
Estech for products and services, would not be realized.
The no-action alternative would mean that 61.5 million tons of
phosphate rock resource would be unavailable at least in the"
short term. The unavai1abiIity of the resource means that
potential for improvement to the Nation's balance of payments
would be lost for the time being. However, value of the reserve
may increase as the world's reserves become scarce. Moreover,
as the year 2000 approaches, domestic reserves may take on
strategic importance for the United States.
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5. Identified Issues and Concerns
The Draft Environmental Impact Statement (DEIS) was made
available to the Council on Environmental Quality (CEQ) and the
public during October 1979. A public hearing on the DEIS was
held in Bradenton, Florida, on November 28, 1979. Written and
verbal comments on the DEIS were received from the following:
U.S. Department of
Ser v i ce
U.S. Department of
U.S. Department of
U.S. Department of
U.S. Department of
U.S. Department of
Administ rat ion
U.S. Department of
Federal Agencies
Health, Education and Welfare, Public Health
the Inter ior
the Army, Corps of Engineers
Agriculture, Forest Service
Agriculture, Soil Conservation Service
Commerce, National Oceanic and Atmospheric
Commerce, Secretary for Science and Technology
Local Government
Sarasota County
Tampa Bay Regional Planning Countil
Interested Groups
Manasota-88
Florida Audubon Society
Save Our Bays Association
Royster Company
Izaak Walton League
Individuals
Dr. Edward A. Mar tell
Dr . Mar y L. Je 1 ks
Mr s. Hi Ida Quy
Dr. Mary B. Greer
Mr. J. Scott Brown
Mr. Robert A. Lyman
Mrs. Gloria C. Rains
Comments from the Department of the Interior and the Army Corps
of Engineers identified two issues which were unresolved in the
DEIS, i.e., fu 11 comp 1iance with Section 7 of the Endangered
Species Act and with Section 106 of the Historic Preservation
Act. Since the time of the DEIS publication, EPA has completed
the consultation procedures required under each act, and evidence
of full compliance is provided in the "Responses to Written
Comments" section of the FEIS.
Concerns raised by other Federal agencies were, for the most
part, the same as those reflected By state and local government,
interest groups and concerned individuals. One such area of
concern at all levels in Florida is the problem of increased
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potential radiation exposure due to activities of the phosphate
industry. The radiation issue as it pertains to phosphate mininp
is comprised of at least three parts: concern for the occupa-
tional safety of phosphate workers, for potential groundwater
contamination, and for increased radiation from reclaimed lands,
both from radon gas in the case of residential development and
from radionuclide introduction into the food chain via agri-
culture. Although the radiation issue as it relates to the
phosphate industry will likely continue to be the subject of
study and research and a matter of public concern in Florida
for some time, specific radiation questions focused on the Estech
site and project have been answered fully in the FEIS "Responses
to Written Comments".
Several conrmenters, at all levels, expressed concern over the
uncertainty of successful restoration of wetlands and upland
habitat. The categorization of wetlands reconrmended in the
Central Florida Phosphate Industry Areawide EIS was developed
in recognition of, and in order to deal with, this question of
success of restoration. By this method, the Estech site's most
strategica11y located, functional and otherwise important
wetlands were designated as Category 1, to be protected and not
mined. This includes the 3/k mile segment of the East Fork
Manatee River originally proposed for mining by Estech. Only
Category 2 wetlands, which are considered less functional and
vital to the system, may be exposed to the risks that are
associated with restoration. It is expected that restoration
methodology may improve through knowledge gained from the
Category 2 wetlands restoration efforts.
In a similar manner, the 50-acre stand of sand pine scrub is
marked for preservation. In any site specific case, including
Estech, the precise areas to be preserved and the location of
the boundary between Category 1 and Category 2 wetlands
designations are a matter of professional judgement and therefore
subject to possible disagreement and controversy. Relative
quality of wetlands on local and regional scale were weighed
in reach g our determination.
The proposed rock drying facility proved to be a very contro-
versial part of Estech's proposed project and EPA's proposed
agency action. The seed of this controversy is the recommen-
dation in the Central Florida Phosphate Industry Areawide EIS
(Areawide EIS) to eliminate rock drying at beneficiation plants
and dry only that rock which must be dried for particular
chemical processes. However, as was explained in the DEIS, the
Clean Air Act Amendments of 1977 with the resulting BACT and
PSD regulations mitigated the study assumptions of the Areawide
EIS. The objective of the Areawide EIS to protect air quality
can now be attained by an enforceable and pervasive system of
air quality controls that exert influence over all major
industrial source contributions. Although EPA views the Estech
rock dryer issue as resolved, a large segment of the interested
public still perceives it as a contradiction to the Areawide
EIS and it remains controversial for that reason.
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A similar controversy arose with respect to the "roposed 480-acre
initial aboveground slime pond. The Areawide EIS recommended
elimination of such clay disposal areas. It encouraged the use
of the most current technology, still being developed, to achieve
this objective and recognized the necessity for an initial
aboveground slime pond. The Estech proposal and EPA's proposed
action entirely conform to the Areawide EIS reconmendation.
It was the public perception of nonconformance to the first,
incomplete part of the recommendation, to "eliminate aboveground
slime ponds," which engendered the controversy. The issue was
acute in Estech's case due to the location of the Lake Manatee
drinking water reservoir downstream of the proposed slime pond.
The County of Sarasota and a few members of the public questioned
the objectivity of the third party consultant for the EIS. No
information has been presented which alters EPA's confidence
in the consultant's objectivity.
6. Unresolved Issues
Two unresolved issues remain. Sarasota County and a few
interested citizens objected to any EPA action being taken on
the Estech EIS or the NPDES permit application before the local
approval issue has been decided. Specifically, Manatee County's
denial of the required Development Order and land zoning change
for Estech has been appealed by Estech to Florida's Governor
and Cabinet sitting as the Land and Water Adjudicatory Board.
As part of that process, a state administrative hearing was held
in Bradenton, Florida during March and May of this year.
Supplemental information generated both as a direct and an
indirect result of the hearing is presented and analyzed in the
"Supplemental Analyses" section of the Final EIS. At this
writing, the Estech appeal has not yet come before the Land and
Water Adjudicatory Board. Before EPA issues the NPDES permit,
a permit hearing will be held and state certification under
Section 401 must be obtained. EPA will assure that the action
it takes on the NPDES permit does not undermine the integrity
of local land use decision process.
Lastly, the question of long term availability of domestic
phosphate resources and their projected depletion by the end
of the century was raised by the public in the context of the
Estech EIS. A recent report by the U.S. General Accounting
Office, entitled "Phosphates--A Case Study of a Valuable
Depleting Mineral in Aimer ica", calls for the development of a
national phosphate policy. It is unknown when, or even if, a
national policy on phosphates will be forthcoming, but EPA would
welcome such policy guidance in reconciling economic, social
and environmental values.
7. Agency Decision
The Areawide EIS establishes a basis for initiating a site
specific EIS for a new source mining operation. The site
specific DEIS examined the mining and reclamation plan by Estech
and assessed the impacts of the proposed activities.
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The Hstech proposal deviated from the Areawide EIS recommen-
dations in two significant areas: 1) construction of a rock
drying facility and 2) mining of a segment of the East Fork
Manatee River, a Category 1 wetland.
EPA's position on the rock drying facility was discussed in
earlier paragraphs. In short, a detailed ex am ination of the
short- and long-term, areawide and cumulative effects of the
proposed drying facility has shown that air quality standards
will not be violated, air quality will not be significantly
degraded and sulfur dioxide and particulate matter emissions
will satisfy NSPS and BACT. Therefore, EPA intends to approve
the rock drying facility and issue the required permits pursuant
to provisions of the Clean Air Act.
The segment of the East Fork Manatee River originally proposed
for mining has been determined to be a Category 1 wetland. Such
wetlands provide important ecological functions such as erosion
control, and perform as a living filter by removing sediments
and other pollutants from; flood waters. In addition, these
wetlands are very productive and export a portion of this
biological productivity to downstream areas. The efficient
functioning of such a complex community is dependent upon t e
presence of all of its member populations. Restoration o a
major, complex floodplain would be slow, if possible at all.
Thus EPA recommended in the DEIS that the functioning sys em
be left intact, which would assure preservation of the biological
integrity of the floodplain of the East Fork of the Manatee
River. Based on the above considerations, EPA believes that
mining should not proceed in the East Fork Manatee River. n
response to this r ecorrmendat i on, Estech has altered t e prop e
mining plan to exclude mining of the East Fork Manatee lver.
As a result of the Florida administrative hearing process
mentioned previously, supplemental information was genera e
for the Estech proposed project. First, a number of additional
soil core samples were taken at various locations on e si e
and submitted for radiological analyses. The data and an
interpretive report on the data are included in the
additional information served to confirm the radiological
interpretations and conclusions stated in the DEIS.
Analyses of these same core samples also revealed a higher clay
to sand ratio than had been predicted for the DEIS. e
projected increase in the amount of waste clay to be g
by mining necessitated an increase in the height of t e emporary
dikes surrounding the sand-clay mix area. The proposed san -c ay
dike height change was carefully evaluated to determine its
impact, and the statements and conclusions in the DEI5 were re-
examined in light of the proposed change. This information l
presented in detail in the Supplemental Analyses of the FEIS.
It is concluded that the impacts identified in the DEIS would
not differ significantly as a result of the proposed change.
Therefore, EPA intends to issue an NPDES permit pursuant to the
Clean Water Act of 1977. The permit will include as conditions
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all those reconrmendat i ons contained in the Areawide EIS which
pertain to mining except the recommendation concerning rock
dryers as noted above. The exclusion of the East Fork Manatee
River from mining will be assured by inclusion as a permit
condition. In addition, the permit will include conditions for
protection of endangered species and for protection of an
archaeological site. These conditions were generated as a result
of the Endangered Species Consultation and Archaeological
Consultation. Lastly, the permit will include a condition that
the 480-acre initial aboveground slime pond be inactivated and
reclaimed a minimum of one year before cessation of mining
activities at the proposed mine site.
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FINAL ENVIRONMENTAL IMPACT STATEMENT
TABLE OF CONTENTS
Page
SUMVIARY SHEET FOR ENVIRONMENTAL IMPACT STATEMENT
LIST OF TABLES iii
LIST OF FIGURES iv
1.0 PREFACE 1
2.0 SUMMARY OF DRAFT ENVIRONMENTAL IMPACT STATEMENT 3
2.1 Introduct ion 3
2.2 Alternatives Evaluation 4
2.3 Description of the Proposed Activity 22
2.4 Description of Baseline, Impacts, and Mitigating
Measures of the Natural Environment 26
2.5 Description of Baseline, Impacts, and Mitigating
Measures of the Manmade Environment 44
2.6 Comparison of Proposed Activity with Areawide
EIS Recommendations 47
3.0 ERRATA 55
3.1 Draft Environmental Impact Statement 55
3.2 Archaeological and Historical Properties Resource
Document 59
3.3 Meteorological Conditions Resource Document 59
3.4 Soils Resource Document 61
3.5 Reclamation Methodology Resource Document 62
3.6 Radiological Environment Resource Document 62
3.7 Surface Water Quality Resource Document 63
3.8 Description of the Proposed Activity Resource
Document 67
3.9 Air Quality Resource Document 67
3.10 Alternatives Evaluation Resource Document 68
4.0 SUPPLEMENTAL ANALYSES 69
4.1 Additional Radiological Data 69
4.2 Elevation of Sand-Clay Mix Disposal Height ....... 75
5.0 PUBLIC PARTICIPATION 86
^•1 Written Comments and Responses to Written
Corrments 87
^•2 Hearing Transcript and Responses to Transcript
Comme nts 263
6.0 LIST OF PREPARERS 371
i
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FINAL ENVIRONMENTAL IMPACT STATEMENT
table OF CONTENTS
Page
7.0 FINAL EIS COORDINATION LIST 373
8.0 APPENDICES 375
8.1 Draft NPDES Permit A-1
8.2 PSD Permit Application - Preliminary Determination A-2
8.3 Supplemental Radiological Data A-3
ii
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FINAL ENVIRONMENTAL IMPACT STATEMENT
LIST OF TABLES
Page
Figure 2.1-1 Location of Duette Mine 3
Figure 2.2-1 Alternative Plant Site Locations 5
Figure 2.3-1 Master Development Plan with Dragline
Sequence 23
Figure 2.4-1 Projected Short Term {2k Hour) Effects of All
Stationary Source Particulate Emissions 29
Figure 2.k-2 Subsurface Geology and Groundwater Systems .. 33
iii
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FINAL ENVIRONMENTAL IMPACT STATEMENT
LIST OF FIGURES
Page
Table 2.2-A Resource Recovery Alternatives and Regulatory
Constraints 8
Table 2.2-B Comparison of Mining Method Alternatives 9
Table 2.2-C Comparison of Ore Transportation Alternatives 10
Table 2.2-D Comparison of Alternatives for Water Supply .. ]l
Table 2.4-A Project Emissions 27
Table 2.4-B Drainage Basin Areas 36
Table 2.4-C Acreages Before Mining and After Reclamation . 42
Table ^.l-A Critical Values of t 73
Table 4.1-B Statistical Calculations and Results 74
iv
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1 .0 PREFACE
In October of 1979, the Environmental Protection Agency published
and distributed a Draft Environmental Impact Statement (DEIS) on
the proposed Estech Duette Mine. The DEIS was written pursuant
to the National Environmental Policy Act (NEPA). While the DEIS
was a complete document, much of the detailed technical information
and supporting data were presented in thirteen volumes of resource
documents. The DEIS was distributed to the appropriate Federal,
State and local agencies and to interested individuals. The
resource documents were available for review at a number of
locations and were distributed on a limited basis.
This Final Environmental Impact Statement (FE1S) has been prepared
to conform with the Council on Environmental Quality (CEQ) regula-
tions (40 CFR Part 6) for implementing NEPA. The essence of the
NEPA decision process is contained in the Summary Sheet for the
FEIS; it describes the existing problem requiring a decision,
sunrmarizes alternatives and their associated impacts, identifies
major concerns and issues including areas of controversy and
presents conclusions.
In an effort to avoid excessive paperwork and costly reproduction,
the DEIS text has not been reprinted in the FEIS. Instead, Chapter
2, Sunmary of the DEIS, presents the DEIS material in condensed
form, with greatest space afforded to the alternatives section.
While the Surmiary of the DEIS is intended to be comprehensive,
the supporting information furnished in the DEIS and its thirteen
resource documents should be reviewed and is incorporated herein
by reference. Chapter 3, Errata, is comprised of the corrections
to substantive errors and omissions in the DEIS and resource
documents as well as all recognized typographical and minor errors.
Chapter 4, Supplemental Analyses, presents two significant
additional areas of information developed subsequent to the DEIS.
Additional radiological data were collected to provide an expanded
data base for the proposed project site. The Supplemental Analyses
chapter presents an evaluation of these data and their effect on
1
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the findings and conclusions in the DEIS. Secondly, a revision
in the original proposed waste disposal plan, namely the height
of the sand-clay mix disposal areas, is described and evaluated.
Chapter 5 contains a description of the public participation
program conducted for the EIS. Included in this chapter are copies
of written corrmun i cat ions submitted to EPA in response to the DEIS,
followed by EPA's responses to each individual comment. These
are followed by a transcript of the public hearing on the DEIS
and a point by point response to the hearing comments.
The final chapters of the FEIS identify the individuals involved
in its preparation and the agencies and groups to whom the FEIS
will b? sent for review and comment. Appendices to the FEIS
contain the draft NPDES permit, EPA's Preliminary Determination
on the PSD permit application and the additional radiological data
mentioned previously.
In accordance with CEQ regulations, there will be a thirty day
review and comment period following publication of this FEIS and
its filing with the CEQ.
2
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2.0 SUMMARY OF DRAFT ENVIRONMENTAL
IMPACT STATEMENT
2.1 INTRODUCTION
Estech General Chemicals Corporation proposes a phosphate mining
and beneficiation facility at the Duette Mine in Northeastern
Manatee County, Florida (Figure 2.1-1). The operation encom-
passes 10,394 acres, of which 6,600 acres are deemed minable.
The operation is planned to produce three million tons of ore
annually for 21 years. Construction of the facility is scheduled
for 1980 with mining beginning two years later.
The water management plan divides the needed supply between
surface water and groundwater resources, minimizes process con-
sumption, and provides for recharge of the Floridan Aquifer.
Discharges of water will be minimized and monitored for
compliance with regulatory requirements.
The reclamation plan is primarily intended to return the site
to agricultural uses. The plan proposes preservation of certain
important wetland and upland plant conmunities and reclamation
to wetlands. Wetland preservation and reclamation areas were
incorporated to provide long-range water quality and biological
Figure 2.1-1 Location of Duette Mine
3
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diversity as well as land form diversity, wildlife protection,
recreational uses and water resources.
In April 1978, the Application for Development Appproval was
filed with Tampa Bay Regional Planning Council (the State
designated regional planning agency) and Manatee County Planning
and Development Department (the designated local agency having
jurisdiction) to secure proper zoning. In addition, a Master
Mining Plan, as required by Section III Manatee County Mining
Ordinance, was submitted to the local agency.
In May 1978, the Duette Mine was determined by EPA to be a new
source as defined in Sec. 306 of the Federal Water Pollution
Control Act Amendments of 1972. Pursuant to this determination,
the procedures specified in the National Environmental Policy
Act were initiated which include the preparation of an environ-
mental impact statement as an integral part of the National
Pollutant Discharge Elimination System (NPDES) permit
appli cat i on.
In September 1978, a Consumptive Use Permit (CUP) was issued
by the Southwest Florida Water Management District (SWFVWID)
pursuant to the requirements of Ch. 373, FS. and Ch. 16J-2, FAC.
This state permit explicitly regulates the consumptive use of
surface water and groundwater.
2.2 ALTERNATIVES EVALUATION
Alternative evaluation included assessment of plant site
locations, production rate, resource recovery, processes for
mining and beneficiation, water supply, waste disposal and
reclamation techniques, discharge into surface water, rock
drying, product transportation to port, power sources and
no-act ion.
Plant Site Alternatives
Beneficiation plant sites were evaluated to minimize loss of
phosphate resource, water pumping, ore and waste transportation,
4
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road and utility construction and destruction of environmentally
sensitive areas. Six sites were considered and are shown in
Figure 2.2-1. Site 6 is the applicant's proposed plant site
locat ion.
Figure 2.2-1 Alternative Plant Site Locations
Resource losses associated with alternative sites are: Site
1 - 511,500 tons; Site 2-0 tons; Site 3 - 2,325 million tons;
Site k - 1.6 million tons;( Site 5 - 1.6 million tons; Site 6 -
0 tons. The lowest net energy costs result from locating the
plant site at the center of the ore body (Site 4). Offsetting
the energy savings in sites 4 and 5 is the resource loss. Sites
and 5 have essentially the same environmental ramifications
as the proposed location (Site 6). Site 3 exhibits the greatest
potential for disburbance of wooded floodplains preserved as
5
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a wildlife corridor and for damaging aquatic habitat due to minor
spills and surface water withdrawal. This site also necessitates
destruction of the environmentally sensitive, 18 acre cypress
dome. It may also result in unacceptable noise levels at
sensitive receptor sites. Site 2 exhibits some potential for
wooded floodplain disturbance but does not otherwise differ
significantly from the Estech proposal. The primary constraint
on Site 1 is the potential for unacceptable air pollutant levels
at the property boundary.
From the energy and cost point of view, the two most feasible
alternatives are the Estech proposal (Site 6), which would
minimize ore transportation costs and the western boundary
location (Site 2), which would have smaller material
transportation and development costs than Site 6. Site 2 does,
however, exhibit a somewhat greater potential for damage to
environmentally sensitive areas (floodplains) than Site 6.
Production Rate Alternatives
Production rate alternatives were evaluated considering both
environmental and economic parameters. The alternatives selected
to illustrate various production rate effects rather than to
definitely designate the optimun are production rates of I) 1.5
million tons per year, 2) 3.0 million tons per year (applicant's
proposed production rate) and 3) k.5 million tons per year.
Consideration of environmental aspects indicate all alternatives
would have essentially the same long-term effects on vegetation
and wildlife. Positive aspects of alternative one are that lower
groundwater withdrawal rates would cause the least stress on
regional water resources and annual particulate emissions would
be lowest. Annual SO2 emissions would be largely the same for
alternative one and two but the long-term contributions of one
would be twice that of alternative two. Alternative three has
a considerable potential to exceed groundwater withdrawal
limitations and exhibits the highest air pollutant contributions.
6
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Alternative one is a 10.7% reduction from present production.
Alternative two replaces mined out production and provides for
demand growth of the phosphate industry. Alternative three is
excessive in that it is decidedly more than necessary to replace
existing capacity and is in excess of historical growth rates.
In terms of both environmental considerations and production
capability, it appears that Estech's proposed production rate
has been reasonably selected.
Resource Recovery Alternatives
Resource recovery alternatives were evaluated with consideration
given to impacts on environmental resources and recovery of
mineral resources. The primary consideration was phosphate ore
underlying forested swamps or marsh areas.
Three cases of resource recovery are considered. Case 1, the
proposed action, represents the mining and reclamation plan
(originally proposed) by Estech. Resource recovery of this plan
would be about 61.5 million product tons of phosphate rock
recovered over a 20-21 year mining period. In achievement of
the proposed recovery, Estech has excluded the lower quality
"unmineable" ore and ore of varying quality underlying much of
the forested swamp comnunity found along major water courses
and the cypress dome. Case 1 includes mining approximately 360
of the 600 acres of freshwater marsh, 55 acres of the East Fork
Manatee River and most of the small feeder streams. (Note,
the FEIS, Estech has revised its proposed action to exclude
mining in the East Fork of the Manatee River.)
Case 2 excludes the mining of all freshwater swamp but includes
mining of marshes as in Case 1. Resource recovery would be about
57.65 million product tons of phosphate recovered over a 19-20
year mining period.
Case 3 includes recovery of all phosphate rock resources regard-
less of vegetative cover or current land use. Resource recovery
would be about 65.9 million product tons of phosphate recovered
7
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over a 21 1/2 - 22 1/2 year mining period. The case includes
mining of approximately 950 acres of forested swamps (including
most of swamp along major drainage courses and the cypress dome)
and mining of marshes as in the previous case.
Table 2.2-A shows the relationship between resource recovery cost
and regulatory constraints.
Table 2.2-A
Resource Recovery Alternatives and Regulatory
Const raint s
Change in Resource
Recover y
Change in Cost
Meets Regulatory
Constraints
Case I
Act ion
Proposed
Case 2 - Loss of
3,850,000 tons
Case 3 - Add
4,400,000 tons
rock
-0-
Would create slightly
higher depreciaiton
rate to account for
the resource loss
Any mitigative action
would add to costs
Permit required for
East Fork Manatee
River System
Would meet maximum
constraints
regarding wetland
protect ion
Would require
approval of DER
and Corps of
Engineer s
With regard to the relationship between resource recovery and
potential adverse impacts on marsh-type systems, for all cases,
freshwater marsh re-establishment through reclamation is expected
to be a relatively rapid process even when unassisted.
Concerning the balance between resource recovery and potential
impacts related to mining of freshwater swamps, each alternative
offers distinctly different implications. Case 2 represents
the "least risk" alternative as all wooded wetlands, regardless
of importance, would be maintained intact. This would defer
for an undetermined time the recovery of several million tons
of phosphate rock product over the other alternatives. Case
3, on the other extreme, offers maximum resource recovery but
with the potential of incurring highly significant, high
magnitude adverse effects on all important biologic and hydro-
logic systems if freshwater swamp regrowth is unsuccessful.
Case 1, not necessarily intermediate to the extremes, also offers
8
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the possibility of moderately significant, high magnitude adverse
effects if freshwater swamp regrowth is unsuccessful in the
mined, three-quarter mile segment of the East Fork Manatee
River .
The current optimal alternative would appear to be somewhere
between Case 1 - Proposed Action and Case 2 - Swamp Exclusion
as large scale wooded wetland restoration efforts are unproven.
Case 2 includes preservation of some wooded wetlands that are
isolated and/or normally intermittent in nature and exhibit
insignificant or minor hydrologic and biologic functions.
Conversely, Case 1 proposes mining of largely undisturbed,
heavily wooded floodplains that contribute significantly to the
overall hydrologic and biologic functioning of the site and
general area. (Note: Case 1, representing Estech's proposed
action, has been revised in the FEIS to exclude mining of the
East Fork of the Manatee River.)
Mining Method Alternatives
Mining methods were evaluated to assess ore recovery rates,
energy use, water use and conservation, environmental resources
and safety. Alternatives examined were electric draglines
(Estech's proposal), dredges, bucket wheel excavators and
technique combinations.
Table 2.2-B Comparison of Mining Method Alternatives
Item/Case Dragline Dredge Wheels Combination
Environmental E ^ ^ c
Water B S B a
Energy Use, KHW/Ton 12.6 25.0 21.7 . '
Ore Recovery 85-87% 80-82% 88%+ 88%+
Safety S S P P
Cost, $/Ton, Prod. 1.30 1.38 1.99 1.38
Ratings; B-Best, S-Satisfactory, P-Poor, E-Equal
Based on the tabular comparison, the dragline would be preferr.ed
although dredging would be acceptable.
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Ore Transportation Alternatives
Ore transportation alternatives were evaluated considering
environmental impacts, technical and operational feasibility,
cost, energy use, and water conservation. Conventional slurry
pumping (Estech's proposal), conveyors and trucks were
transportation methods considered.
Table 2.2-C Comparison of Ore Transportation Alternatives
Item/Case Pumping Conveying Trucking
Environment SB p
Water E E j=
Energy Use, KWH/Ton 17.3 11.2 N/A
Operational Feasibility S U/P p
Cost $/ton, Product $ 0.92 $.0.88 $ 1.33
Rates: B-Best, S-Satisfactory, P-Poor, E-Equal
U/P-Unproven in phosphate. Energy use (KWH) for trucking
is included in the Cost $/ton.
Concerning the environmental ratings, pumping and conveying
alternatives would each eliminate about 15-20 acres of wetland
vegetation due to construction of stream crossings. It is
assumed the construction of truck crossings would eliminate some
greater amount due to the need for heavy duty bridges on pilings
or culverts with approach fill.
The pumping and conveyor alternatives each offer a potential
for spillage of transported materials at stream crossings.
Extensive spills of truck transported materia 1s into streams
is considered remote. The greatest potential for adverse effects
related downstream sedimentation by spill materials would appear
to be associated with pipe-wall rupture in the pumping alter-
native if secondary protective measures fail. The only
alternative with significant implications for addition to air
pollutant burdens is the truck transportation alternative.
The operational viability of transport of ore by conveyor is
unproven. The problem associated with transferring the ore from
the dragline to the conveyor and the need to relocate the
conveyor continuously as mining advances are significant
disadvantages of the conveyor transport method. The continuing
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increase in power cost makes further study of this alternative
prudent. However, in view of the proven reliability of pumping
and its compatabi1ity with the dragline and dredge mining
alternatives, the ore pumping alternative is currently the most
satisfactory ore transport method.
Benefication Process Alternatives
Beneficiation process alternatives were evaluated for energy
and water use efficiencies within proven state-of-the-art
technology. Alternative processes considered were conventional
beneficiation, total acidulation and blast furnace. The total
acidulat ion process (direct acid conversion of matrix) is only
experimental and not available for use at this time. Furnace
alternatives (high temperature decomposition) are cost and energy
intensive and unsatisfactory for this ore body. Thus, conven-
tional beneficiation is .considered optimum.
Process Water Source Alternatives
Process water sources were evaluated to conserve the regional
resource while providing a sufficient quality and quantity of
water. Supply alternatives considered were use of surface water
and groundwater, total requirement from the Floridan Aquifer,
use of surface water in rainfall catchment and use of water from
the surficial aquifer.
Table 2.2-D Comparison of Alternatives for Water Supply
Alt.
Quali ty
*
Dependabi1i ty
Resource
Impact
A11. m Excel lent G/W
Poor S/W
Alt. //2 Excellent
Dependable
G/W and S/W
Dependable
G/W only
Atl. #3
Poor
Not dependable S/W vegetative
system & down-
stream use
Alt. m
Excel 1ent
Not dependable Vegetative
impact
*
Quality is expressed in relative usefulness in the amine
circuit of the flotation system.
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Estech's proposal (Alternative 1) uses both groundwater and
surface water. This alternative provides fr a dependable source
of sufficient high quality water for the beneficiation process
and reduces the impact on the deep aquifer compared to the
exclusive use of groundwater (Alternative 2).
Alternative 2 (Floridan Aquifer) impacts only the groundwater
resource in the deep aquifer. This alternative provides for
a dependable source of high quality water. The impacts of
groundwater pumping are acceptable for the first three years,
but for the long term, Alternative 1 is preferred because of
its reduced impact on the deep aquifer.
Alternative 3 (rainfall catchment) is not acceptable in terms
of water quality or dependability. In addition, this alternative
has the potential of reducing the downstream surface water
supply, would destroy hardwood floodplains by reservoir
construction and has not been proven technically feasible.
Alternative 4 (surficial aquifer) would not provide a dependable
source of water. In addition, this alternative would have an
adverse impact on the maintained vegetation on site because of
drought conditions impoased on the surface soils for the 20-year
mining period.
In view of these considerations, Estech's proposal is the optimum
blend of various resource uses. The mitigative action of
implementing recharge wells makes this alternative even more
attractive.
Waste Disposal/Reclamation Alternatives
The objective of the waste disposal/reclamation plan is to
restore disturbed land to a productive state, considering both
existing and created environmental systems. Considering all
three levels of alternative selection - waste disposal, physical
restoration and revegetation, a set of the alternatives capable
of meeting the applicant's goals can be established. Two cases
have been selected for final comparison.
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Case I - Case I may be described as the best case application
of conventional waste disposal and reclamation techniques. Under
this case, clay and sand wastes would be disposed of in separate
areas. Except for the required initial clay settling area on
natural ground, waste disposal would be confined to mined-out
areas. This requires the construction of approximately 3,604
acres of conventional clay settling areas with dams averaging
50 feet in height, of which 480 acres would be on natural ground.
The remaining 3,500 acres of mined-out land would be used for
sand tailings disposal.
All clay settling areas would be reclaimed by the crust develop-
ment technique so as to leave the clays in the surface soil.
Sand tailings landfills would be capped with overburden to an
approximate depth of two feet. It was assumed that reclamation
of the approximately 255 acres required for the plant site and
support facilities would be the same for both cases.
All reclaimed areas initially would be planted in forage species.
As is frequently practiced, scattered tree plantings would be
made in reclaimed pasture areas at a density of two trees per
acre, of which half would be 2"-4" transplants and half would
be potted seedlings. Since wetland restoration is not currently
part of conventional reclamation technology, it was assumed that
no areas would be restored as wetlands. Also, no areas would
be allowed with mininal reclamation to revegetate naturally since
this is at variance with current local and state reclamation
standards.
Case II - Case II is the Estech plan. Under this plan, the
sand-clay mix technique is the primary waste disposal method,
requiring a total of 5,426 acres, of which all but 200 acres
are in mined-out areas. An initial 480-acre conventional clay
settling area with a dam height of 30 feet is required on unmined
land. Approximately 848 acres of conventional sand tailings
disposal areas in mined-out pits are also elected. The remaining
574 acres of mined-out land is not utilized for waste disposal.
13
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All sand-clay landfills are reclaimed without the use of capping
material. The single clay settling area is reclaimed by the
crust development technique and sand tailings disposal areas
are capped with approximately two feet of overburden. The
acreage not required for waste disposal is reclaimed as land
and lake areas. Of this 574 acres, shallow zones amenable to
marsh establishment would be created on approximately 90 acres
along the margins of four reclaimed lakes and a 100-acre area
would be physically altered only by the partial leveling of
spoils to provide an area for natural revegetation. The 255
acres required by the plant site and support facilities will
be physically reclaimed by conventional means of dismantling
facilities, grading to approved slopes, etc.
Revegetation plans for Case II include the planting of 5,928
acres of improved pasture with a mixture of grass and legume
species. Mixed forest strips totalling approximately 58 acres
would be planted in upland reclaimed pasture areas. Approxi-
mately 485 acres of forested wetland would be planted, primarily
along major drainage swales and also along a restored segment
of the East Fork Manatee River. (Note: In the FEIS, Estech
has revised its proposed action to exclude mining in the East
Fork Manatee River.) Approximately 538 acres of shallow aquatic
environments created in sand-clay landfills would be allowed
to revegetate naturally. Along with the 90 acres of shallow
zones created in the margins of reclaimed lakes, this constitutes
a total planned marsh restoration of 628 acres. The 100-acre
land and lake area subjected to only partial spoil grading would
be allowed to revegetate naturally. All the land areas
associated with the remaining 384 acres of land and lake areas
would be grassed.
In Case II, the approximately 5,400 acres of sand-clay spoils
are projected to be more productive than the soils which result
from conventional waste disposal/reelamation techniques.
Moreover, under Case II, disturbed land will be returned to a
14
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productive use at an earlier date than for the conventional waste
disposal case.
The risk of a dam failure and its resulting environment damage
is greater in Case I. Case II has the most obvious advantage
over Case I in the area of revegetation efforts to mitigate the
loss of natural conrmunities to mining. In Case I, all reclaimed
areas would be improved pasture resulting in a permanent loss
of 364 acres of marsh and 476 acres of swamp. As river swamps
and marshes were found to be the most productive wildlife
habitats of the site, the reduction would significantly reduce
the long-term carrying capacity of the mine site. In Case II,
a variety of revegetation efforts are proposed to attempt re-
establishment of destroyed wetland habitats. The Case II planned
restoration of over 1,100 acres of wetlands represent a signii
ficant contribution towards mitigating adverse impacts of mining
on local wildlife populations. Additionally, reforestation
strips (hedgerows) in upland areas and abandonment of a minimally
reclaimed 100 acre area will provide areas of wildlife habitat
not available in Case I.
The advantages of Case II appear to justify the added costs
this alternative imposes over the more conventional Case I
alternative. Case II, therefore, may be designated as the
optimum alternative. Due to the conceptual basis of the plan,
it is expected that modifications will be made (in practice)
in response to more detailed engineering and to variables in
actual operations.
Surface Water Discharge Volume Alternatives
The alternatives considered were 1) containment of long-term
accumulation, 2) containment of short-term accumulation, 3)
containment to offset evaporation losses and 4) no containment.
Alternative three represents Estech's proposed action.
Alternative one and alternative two possess the potential for
dike failure. A resource loss would also be incurred due to
15
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the construction of impoundments over areas containing mineable
phosphate ore. Neither water conservation nor reduced potential
for surface water degradation is deemed sufficient to offset
the previously mentioned negative attributes. The selection
of the third alternative, however, does not completely define
it as the optimum possible system. Improvements or modifications
possibly can be implemented by Estech, during design or
operation, to further feasibly reduce discharge. Alternative
four would require additional water to be obtained from either
the rivers or deepwells.
Discharge Point Alternatives
Alternatives were assessed with respect to maximizing water
conservation and water management efficiency while meeting water
quality standards for the receiving waters. The alternatives
considered were: 1) discharge directly into East and North Fork
Manatee River; 2) discharge directly into North Fork and into
pool connected to East Fork Manatee River; 3) discharge directly
into North Fork, into river overflow pool when not full, and
directly into East Fork when river overflow pool is full; 4)
discharge directly into East Fork Manatee River; 5) discharge
into river overflow pool connected to the East Fork; 6) discharge
directly into East Fork Manatee River when overflow pool is full;
7) discharge directly into North Fork Manatee River; and 8)
deepwell injection of all discharge water. Alternative three
represents Estech's proposal.
Alternative eight is unacceptable because of increased risk of
contaminating groundwater. Assuming they meet water quality
standards, all other alternatives appear acceptable. Both
alternatives two and three maximize water efficiency and minimize
discharge, although alternative two is more cost effective.
The cost difference is, however, off-set by operational
effectiveness of discharge flexibility inherent in alternative
three.
16
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Rock Drying Alternatives
The objective is to prepare the phosphate rock for shipment in
a condition acceptable to customers while meeting regulatory
requirements regarding air pollution. The alternatives selected
for assessment are: 1) install rock dryer at the Duette Mine
(Proposed Action); 2) ship wet rock; 3) use existing dryer at
remote location; and ^) install rock dryer at a remote location.
Total acceptance of wet rock, as the basic form of the phosphate
rock commodity on the world market, is not expected for some
time. Many users have small phosphoric acid plants and the
designs vary widely making conversion to wet rock not only
expensive, but technically difficult. Conversion to wet rock
also requires installation of wet rock grinding in addition to
major wet phosphoric acid process design changes. Capital for
the modifications is not readily available in many developing
count r ies.
Some dry rock is used to produce triple superphosphate for which
no wet rock process exists. If drying at the acid plant is
desired, small dryers located at small plants are inefficient
and very expensive compared to the large units employed by rock
producer s .
More energy in the form of fuel oil is consumed to dry the rock
than is consumed to ship the additional water in the wet rock,
assuming that the rock will not be dried at the final destina-
tion. In the case of rock dried at the final destination, energy
consumption would be the greatest since the energy consumed in
shipping the water would be added to the energy consumed in
drying the rock.
From an environmental viewpoint, a ranking of alternatives from
best to worst may be characterized and summarized as follows:
o Ship Wet Rock - This is the best environmental choice only
if the rock is not dried in less efficient and less effective-
ly controlled equipment at the destination. However, fj"0™
a standpoint of phosphate rock customer requirements, it is,
in effect, also a no project alternative.
17
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With a gradual shift to wet rock grinding and processing
facilities, wet rock shipping may eventually be demonstrated
as reasonably practical and a preferred environmental
al ternate.
o New Dryer at Remote Site - It is assumed that the site would
be within a developed port facility of the region. Also it
is assumed that the air and water quality conditions at the
remote site are sufficiently marginal with respect to
standards and that the required additional level of emission
control would reduce pollutant contribution to the regional
pollutant burden and produce a better environmental choice.
For example, the best site would be within an area designated
for non attainment, because the new source would have to
negotiate at least a corresponding reduction from another
source so that there would be a projected reduction in area
emi ss ions . 4
o Dryer at Duette Mine (Proposed Action) - It is required that
this new facility be designed, constructed and operated in
accordance with the existing body of environmental legislation
and regulations designed to protect the public health and
welfare. It must be recognized that the environment analyses
suggest these requirements can be satisfied, and in some
cases, with considerable margin. Thus, the alternative is
considered an environmentally acceptable action.
o Use Existing Dryer at Remote Location - Continued or expanded
use of older, less effectively controlled equipment located
in areas marginal with respect to air quality standards would
increase regional pollutant burdens.
Both wet and dry phosphate rock are minor ganrma radiation
sources, and there is no measurable difference in radiation
levels between the two products. Lung dosages of radiation are
higher near rock dryers, but conventional dust control systems
maintain radiation levels within the guidelines for occupational
exposures. The application would reduce pollutant concentration
levels even further. Workers near adequately ventilated wet
and dry rock handling facilities, generally are not exposed to
radiation levels exceeding the guidelines for the general
populat ion.
Pollutant Control System Selection - Prevention of Significant
Deterioration (PSD) regulations include a requirement for
application of Best Available Control Technology (BACT) to major
source developments. BACT is a formalized analysis of
18
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potentially appliable control systems and a final selection based
on performance (i.e., pollutant removal efficiency), economics
(i.e., capital and operating costs) and irretrievable energy
requirements. The process is completed following regulatory
approval of the control concept and issuance of a BACT
Determination.
A preliminary evaluation of pollution control systems narrowed
the evaluation to two practical alternatives for both the dryer
facilities and fugitive dust control systems--fabric filtration
(baghouses) and wet scrubbing technologies. A review of the
advantages and disadvantages of the pollution control systems
lead to the selection of the proposed venturi-absorbers and wet
centripetal vortex contact scrubbers.
Product Transportation Alternatives
The transportation objective is to ship the phosphate rock to
local or port destination as efficiently and safely as possible
with minimum disruption. The alternatives selected for assess
ment are: 1) railroad with truck as emergency mode (Proposed
Act i on); 2) trucks only; 3) pipeline to port; and <0 conveyor
bel t.
The presently feasible alternatives for transportation of the
phosphate rock to the port facilities in the Tampa Bay area
appear to be that of railroads and/or trucks. Both the pipe-
line and conveyor belt alternatives present the significant
problems of obtaining a continuous zone of right-of-way and/or
land purchase for a route to a port and prohibitive capital costs
for construction. The truck alternative will use more energy,
but in some cases, has a higher reliability. However, it
environmental constraints in the form of vehicular emissions
not only from the truck traffic itself but also from the
contributions from any associated traffic connections which might
be expected from such a large volume of trucks required. Rail-
roads are established in Central Florida and they are reliable.
Presently, rail is the most economical transportation available
19
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because it uses less energy and is generally environmentally
acceptable.
Energy Source Alternatives
The objective is to maintain maximum efficiency in energy conser-
vation while minimizing environmental disruption.
Energy source alternatives assessed are: 1) corrmercial ly avail-
able electric power (Proposed Action); 2) on-site coal, oil,
gas powered generator; 3) on-site nuclear power generator; k)
on-site solar power generator; and 5) on-site hydroelectric
generator s .
On-site generation by coal, oil, or gas would result in
additional significant environmental considerations in addition
to those associated with mining. Special measures would have
to be taken to insure a non-polluting energy system. The cost
of construction and operation of on-site generation are con-
sidered prohibitive. With the exception of a reduction in air
pollution, the nuclear generation alternative alternative has
the same drawbacks as generation by coal, oil, or gas. In
addition, strict control of the fuel and security for fuel waste
disposal would have to be resolved. Current solar power
technology has not advanced to the point where sufficient
electrical energy could be obtained from the sun to satisfy mine
requirements on a practical, non-interruptable economic basis.
None of the streams on the property are capable of supplying
the needed steady water flow to provide the mine's electrical
requirements through hydroelectric generators. Therefore, the
only feasible alternative is to purchase the required power from
a corrmercial producer.
No-Action Alternatives
The no-action alternative would be to not construct the proposed
New Source on the Duette tract and to allow the area to continue
its present day socioeconomic and environmental trends.
20
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Basline elements indicate that failure to construct and operate
the proposed new source would exert little effect, positively
or negatively, on general regional or local projections for
population growth, econimic growth or demands for community
services and facilities.
The general result of the no-action alternative on socioeconomic
conditions of the region and specifically Manatee County would,
in effect, be one of unrealized potential economic benefits.
Economic benefits of the proposed mine would be about $4.5
million in local property and state severance taxes with no
appreciable effects exerted on public services, facilities, etc.
Additionally, the projected $25 million annual expenditures by
Estech for products and services would not be realized. The
no-action alternative would represent the loss of 61.5 million
tons of phosphate rock resources.
The present day general trend for eastern, rural Manatee County
to be largely devoted to agricultural activities is not expected
to change in the foreseeable future. The only noticeable change
to this trend, which is viewed as temporary in nature, is the
approval of two phosphate mines in eastern Manatee County as
Existing Sources. The two approved mines, neither of which are
presently in operation, are located irrmediately north and south
of the Estech Duette tract.
In the absence of mining on the Duette tract, it is expected
that little physical modification of the tract will occur over
the next two decades. Because of the relatively poor soil
conditions at the Duette tract, it is unlikely that the native
rangeland (cut-over flatwoods), which comprise the majority of
the site, would be rapidly converted to improved agricultural
uses. The practice of clearing native rangeland for production
of watermelon and/or tomato crops for a few seasons may result
in several hundred acres eventually converted to improved
pasture. This conversion of a hundred acres of the tract to
pasture should not exert significant adverse impacts on the
21
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biology and ecology of the site. As current land clearing
practices for improved agricultural use typically avoid wet soils
due to the impracticality of its use as pasture or for row crops,
significant destruction of wetlands on the tract is not expected.
If additional acreage is cleared for row crops and/or improved
pasture as assumed, irrigation requirements would probably
result in average annual withdrawals of groundwater approaching
that proposed for mining. These withdrawals would be confined
to the dry season only, however, and probably would result in
worst case aquifer drawdowns exceeding those associated with
mining on the tract.
In the no-action alternative, therefore, most if not all unavoid-
able adverse environmental impacts, associated with mining would
not occur. The existing natural setting would continue more
or less unchanged. A projected benefit associated with mining
and reclamation, the improvement of soil quality and productivity
potential, would also not accrue.
2.3 DESCRIPTION OF PROPOSED ACTIVITY
Estech proposes to use equipment and design generally available
and practiced by presently operating mines. The major components
of operation are large walking draglines; hydraulic ore trans-
portation via pipeline to a central washer; a feed preparation
and flotation plant; wet rock storage and drying; and shipment
via rail.
The draglines strip overburden for deposit in mined-out cuts.
Exposed matrix is excavated and dumped into a slurry pit or
"well" -- an excavated sump within reach of the dragline. A
pit control car directs high pressure water guns at the matrix
breaking it into a slurry. Pumping systems deliver the slurried
matrix to the plant.
Slurried matrix is passed through a wet screening process. Un-
acceptable pebble is discarded as waste. Product is stored in
22
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FIGURE
2.3-1
U S. EPA - REblON IV
OH AF r INVIKUUMLNI Al.
MASTER DEVELOPMENT PLAN
IMPACT ATtMt NT FOR
SWIFT AUKlCULfUNAL CMfeMlC.M b
WITH DRAGLINE SEQUENCE
CORPORATION
PROPOSED OUETTE MINE
SOURCE ;
ZELLARS - WILLIAMS ( INC.
MANATEE COUNTY , f'LORlOtt
23
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pebble bins for dewatering and quality control analysis prior
to shipment or placement on storage piles.
Underflow fine material from washer screens moves to the feed
preparation area where hydrocylones separate the waste clays
from the sand-sized particles, termed feed. The feed is
transported to the flotation circuit.
Flotation is a two-stage process; "rougher" flotation separates
phosphate particles from silica sand and "cleaner" flotation
by an amine flotation of the sand particles. The sand-sized
product, termed concentrate, is then dewatered.
Rock dewaters to about 13% moisture while in storage with
drainage directed to the plant water system. The storage system
delivers wet rock to either the dryer feed bins or the wet rock
1oadout bins.
The last step in processing is drying. The average 13% moisture
is reduced to 2% in the dryer. Dry product is transferred to
concrete silos for storage. Conveyors transfer dry rock
from the silos to rail loadout facilities.
The beneficiation of phosphate ore generates two solid waste
products: 1) clay or "slimes" and 2) sand tailings. Estech
has committed in their mine plan to use a sand-clay mix in land
reclamation and thereby reduce the need for traditional separate
disposal areas. Estech plans to use a flocculant thickener
method whereby clays are pumped from the beneficiation plant
to mechanical thickeners where flocculants are added. Sand
tailings from the plant are added to the thickened clays either
directly at the thickener or at a downstream mixing station.
Approximately 5,^26 acres are planned for use as sand-clay type
disposal areas.
A 480-acre conventional clay settling area is planned for the
mine. This area will receive all clay wastes generated before
the sand-clay mix procedure becomes operational. The settling
area will remain active throughout the mine life to receive clay
24
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wastes in excess of the sand-clay mix requirements and to serve
as a secondary water clarification and storage area. By the
end of the mine life, the area will be filled to about 25 feet
above natural grade.
In the first year of mining, sand tailings will be used to
construct retaining dikes. Thereafter, about acres per year
will be backfilled with tailings for a total of 848 acres.
The proposed water management plan divides the needed supply
between surface and groundwater resources, minimizes mining
process consumption and provides for recharge of the Floridan
Aquifer. The Consumptive Use Permit issued by the Southwest
Florida Water Management District allows groundwater withdrawal
at a rate of 13 mgd for the first three years. During this time,
a 200-acre surface water reservoir will be constructed to provide
storage for 3 mgd, thereby decreasing groundwater use to 10
mgd. Prior to withdrawal, a recharge system will be constructed
to transmit water from the surficial aquifer into the deep
s y s t em.
With the exception of a 100-acre area, all land disturbed by
the operation will be reconstructed and/or backfilled with waste
materials in conformance with county and state slope require-
ments. In sand-clay mix landfills, the exterior levees and any
protruding spoil piles will be graded down. In the clay settling
area, the formation of a surface crest will be encouraged by
use of perimeter and interior ditches. When the crust has
formed, the retaining dike will be pushed down. In sand
tailings landfills, the overburden in the protruding spoils will
be distributed over the landfill to an average depth of two feet.
In land and lake areas, the spoils will be graded to conform
with terrestrial slope requirements and to form littoral zones
consisting of 12 to 1 subaqueous slopes out to a depth of 6
feet.
In addition to primary physical restoration techniques, several
special techniques are planned to serve particular reclamation
25
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goals. A three-quarter mile segment of the East Fork Manatee
River is proposed to be restored by creation of an adjacent hard-
wood vegetated floodplain and channel with the same elevation
and gradient as the existing stream. (Note: Estech has revised
its proposed activity to exclude mining of the East Fork of the
Manatee River.)
Shallow basins allowed to form around the drainage outlets in
sand-clay landfills will be retained as marsh environments.
Drainage swales will be constructed through adjacent sand-clay
landfills to interconnect these marshes.
About 6,000 acres of reclaimed land will be planted to forage
grasses and legumes. Forage species will be selected to match
the potential productivity of each reclaimed soil type. Re-
forestation in upland areas will include mixed plantings of
native species such as water oak, live oak, longleaf pine and
slash pine. The shallow basins created in sand-clay landfills
are expected to revegetate naturally with marsh-type vegetation.
The minimally reclaimed 100-acre land and lake area will also
be allowed to revegetate naturally.
Contouring and revegetation of land and lake areas is estimated
to require two years to complete. Backfilling with sand
tailings, capping with overburden and revegetation will require
about three years. In sand-clay landfills, two years has been
allotted to filling, two years to subsidence and consolidation
and an additional year to revegetation, for a total of five years
to complete reclamation. Because of the lengthy period required
to form a surface crust, ten years has been allotted to complete
reclamation of the single clay settling area.
2.4 DESCRIPTION OF BASELINE, IMPACTS, AND MITIGATING MEASURES
OF THE NATURAL ENVIRONMENT
Meteorological Conditions
Meteorological conditions discussed include temperature,
precipitation, evaporation, dispersion phenomena, hurricane,
tornado and hailstorm frequency and thunderstorm activity.
26
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Ai r Qua 1i t y
The analysis of proposed air quality impact was performed in
a manner consistent with objectives of Prevention of Significant
Deterioration (PSD) and includes results of preconstruction
monitoring activities, control equipment selection to achieve
BACT, emissions estimates and mathematical modeling to insure
conformance with PSD increments and National Ambient Air Quality
Standards (NAAQS). (Note: See PSD Preliminary Determination
in Appendix B of the FEIS.)
Project emission estimates are given in Table 2.4-A and include
both construction and operating emissions. The construction
estimates display a worst day representation with all activities
overlapping at one time. The *data from which these estimates
were computed formed the basis for modeling source effect.
Table 2.4-A Project Emissions (Pounds Per Day)
Phase/Pol 1utant
TSP
Fugi t ive
Dus t
HC
NO„
SO,
CO
Gaseou s
Fluor i de
Temporary/Construct ion
Site Preparation
80
--
110
20
n i 1
660
--
Const ruct ion
60
550a
90
1 ,000
60
460
TOTAL
140
550a
200
1,020
60
1, 120
--
Operation/Mining and
Process ing
Mining
10
850a
11
156
77
50
Wet Rock Storage
l,350a'b
--
--
Dr yer s
551
n i 1
3 7C
1 ,819d
206
1 85C
1
Dry Rock Storage
and Transport
279
n i 1
—
—
Transportat ion
(auto/truck/R.R.)
3
20
46
6
108
TOTAL
843
2,200a'b
o
oo
! vo
2,021
289
343°
1
Fugitive dust emissions include a substantial weight percent of
coarse particulate matter (unlike dryer emissions) that will
redeposit relatively close to the point of emission
27
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Table 2.4-A (continued)
k Analysis of product particle size suggests methodology produces
substantial overestimation (99.98% >10 ym).
c Pollutant loadings generated by fuel combustion process for
equivalent industrial boiler capacity. Reduced generation and/or
removal may be expected in fluidized bed dryers and wet scrubbing
dev i ces.
^ Based on field measurements conducted on a similar fluosolids dryer.
Annual total suspended particulate long-term effects of just
the proposed source were determined using the AQDM computer code.
The maximum effect occurs well within the confines of the mine.
The highest property boundary effect occurs on the west bound-
ary. Annual concentration at the point of maximum effect was
estimated to be 1.4 micrograms per cubic meter or about 8% of
the allowable PSD increment. The estimated annual mean at all
points of maximum effect were estimated to be less than 50% of
the federal primary and state standards of 75 and 60 micrograms
per cubic meter, respectively.
The 24-hour total suspended particulate average at the point
of maximum effect was projected to be 12.8 micrograms per cubic
meter and the worst case property boundary concentration was
8.1 micrograms per cubic meter. The maximum point is well within
the property boundaries and very close to the source cluster.
Maximum increment consumption was estimated to about 35% of the
allowable PSD increment of 37 micrograms per cubic meter.
Projected 24-hour effect of all sources was added to the short-
term background as a means of determining conformance with
ambient standards. The results are displayed in Figure 2.4-1.
Annual average sulfur dioxide concentrations at both the point
of maximum effect and at the worst property boundary location
were projected to be less than 1 microgram per cubic meter.
Property boundary values are below the PSD levels of significance
of 1 and 5 micrograms per cubic meter, annual and 24-hour,
respect ively.
28
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FIGURE 2.4-1
U.S. EPA - REGION
IV
DRAFT ENVIRONMENTAL
PROJECTED SHORT TERM (24 HOUR)
IMPACT STATEMENT
FOR
EFFECTS OF ALL STATIONARY SOURCE
SWIFT AGRICULTURAL
CHEMICALS
PARTICULATE EMISSIONS
CORPORATION
PROPOSED DUETTE
MINE
SOURCE CONSERVATION CONSULTANTS INC.
MANATEE COUNTY ,
FLORIDA
29
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The worst property boundary nitrogen dioxide effect of the
combined stationary and non-stationary sources was computed to
be less than 1 microgram per cubic meter. The worst property
boundary effect is less than PSD level of significance of 1
microgram per cubic meter.
The phosphate rock dryer control systems are designed to achieve
as great as 99.8% removal of particulate matter (dusts), and
96.5% removal of the sulfur dioxide and an estimated minimum
of 10-20% of the nitrogen dioxides generated in the combustion
of fuel oil (which is necessary to dry the rock). Use of fuel
oil containing no greater than 1.0% sulfur and 0.3% nitrogen
will further reduce greater potential emissions which might
otherwise be released by the proposed source.
No i se
Noise sources investigated included the dragline and sluice pit,
washer and flotation facility, dryer and bulk loading facility,
switch yard and reclamation activities. Source directivity,
pure tones and background sound levels were evaluated in the
monitoring program.
Based on the noise monitoring program, there are no significant
noises associated with mine-related activities that could be
considered intrusive because of spectral content of inter-
mittency.
The noise impact assessment further demonstrated that none of
the sensitive receptors near the proposed mine will be exposed
to noise levels which will interfere with activity or result
in hearing impairment.
Topography
Mining will significantly alter the site's topography on the
short-term through surface strip mining and wastfc clay disposal
activities. Short term effects are primarily the strip mine
30
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land form of parallel spoil piles protruding from mine pits and
dikes and dams used for waste containment/land reclamation.
Sand-clay landfill (5,426 acres) areas are expected to be near
original elevation and have a very slightly rolling topography
with a very low gradient largely toward the retained, natural
watercourses or created lakes. Tailing landfill is largely
planned for mined areas that correspond to the major, natural
drainage divides to re-establish pre-mining watershed acreages.
Approximately 2,811 acres will not be mined or the existing topo-
graphy disturbed in any fashion.
So i 1 s
The proposed mining operation will disturb the existing soils
on 7,583 acres or approximately three-fourths of the site. Strip
mining will totally alter the nature of the existing soils on
approximately 6,624 acres.
Waste disposal and physical reclamation techniques will result
in the following three new types of surface soils on the site.
Soil Type Acreage
480
CI ay
Sandiay •ii\
Overburden (over sand tailings fill;
t A . 5>"26
Sand-clay . . '848
Total
tT, . . <,9Q _rrps consist of disturbed native soils
Ind land'and lake a%as, the land portions o, which .1.1
be composed of overburden material.
The short-term loss of soils from agricultural use, the initial
absence of organic matter, i.e., humus in all reclaimed
and the decreased bearing capacity of clay and sand-clay soils
relative to the natural soils must be regarded as unavoidable
adverse impacts of the proposed operation.
Geology
In mineable areas, the upper geologic formation will be excavated
to an average depth of 50 feet and a maximun depth of 100 feet.
31
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During strip mining the overburden section of sands, clays and
hardpan will be displaced to spoil windrows within the mining
pit, and the underlying phosphatic ore will be completely removed
down to the "bedrock" layer. These excavated areas will
subsequently be either backfilled with sand and clay process
wastes or left as water-filled areas. Formations below the
mining section will remain undisturbed.
Groundwater Hydrology
Shallow groundwater at the proposed mine site is contained in
the upper, or surficial materials and is found under both water
table and artesian conditions.
The hydrologic properties of the surficial aquifer have been
determined by pump testing and slug (or sensitivity) testing.
The similarity of water levels in wells screened above or below
the hardpan layer indicates the hardpan does not act as a
significant confining layer. Permeability of the matrix has
been shown to be low in comparison to the overlying sands.
The deep groundwater system at the proposed project site
consists of the limestones and dolomites underlying the surficial
or water-table aquifer and the phosphate matrix. This system
includes the productive portions of the Hawthorn Formation and
the Tampa, Suwannee, Oca la, Avon Park and Lake City Formations
and is corrmonly referred to as the Floridan Aquifer. The
producing zones for potable supply are found, in order of
increasing supply potential, in the Hawthorn/Tampa, Suwannee
and Avon Park Formations. The Lake City, Ocala and portions
of the Hawthorn/Tampa Formations act as semi-confining units
retarding the vertical movements of water in the deep ground-
water system. Figure 2.4-2 indicates the groundwater systems
underlying the property.
Water-level elevations in the Floridan Aquifer at the proposed
project site range from 30 to 40 feet above mean sea level at
some times of the year to near mean sea level at other times.
32
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touwc Lflq
UW-MWM 00
tool
wof
MO
•001
•00
H
'*4
CZJ OUMtt IMO
SEES Cuff/tuT
mm limstowk
OOLOMITIC LIMCtTOUC
¦¦ DOLOMITC
wm CASCITIC DOlOMiri
¦¦I OVMUM AMD/OH AMNTOKItl
Wlatr CM'ltMWttr
cocloponw Mo»M*rc
• CHIItT
• CUCITI CRYCTAlt
QUARTZ CftVITAl*
9% IIWW M0/CM
SHALLOW, WATER TABLE AQUIFER
I
CWCRM
X-IW OlPflUCTlON ANALTKI
VERY SMALL PRODUCING ZONES
LAYERED WITH CONFINING BEDS
• s'
MODERATE
PRODUCING ZONE
LOW PERMEABILITY,
SEMI CONFINING BEDS
VERY LARGE
PRODUCING ZONE
LOW PERMEABILITY
VERY LOW PERMEABILITY,
FIRST SIGN OF EVAPORITES
FIGURE! 2.4-2
U.S. EPA - REGION IV
SUBSURFACE
DRAFT ENVIRONMENTAL
GEOLOGY
IMPACT STATEMENT FOR
AND
SWIFT AGRICULTURAL CHEMICALS
GROUND - WATER
SYSTEMS
CORPORATION
PROPOSED DUETTE MINE
SOURCE : WILLIAM F. GUYTON & ASSOC.
MANATEE COUNTY , FLORIDA
-------
Generally, the direction of groundwater flow at the project
area is westerly, towards the coastline.
Effects of the proposed development of Estech's Duette Mine will
be evidenced in both the shallow and deep groundwater systems.
Dewatering of the surficial materials to facilitate mining will,
to some extent, impact the shallow groundwater system throughout
most of the property at some time during the life of the mine.
As the active mining moves from a mined-out area, dewatering
operations, other than those associated with the recharge
project, will cease and water levels in the surficial aquifer
will begin to re-establish themselves to the previous
cond i t ion s .
Within the active mining area, the water level in the surficial
system wi11 be lowered to the top of the ore matrix. The
projected effect of the mine operation on the regional flow
pattern in the shallow groundwater.system wi11 be small in
comparison to the effect on-site. On-site flow patterns within
the surficial aquifer will be altered depending on the specific
locations of the recharge and dewatering wells and the location
of the clay, clay-sand and sand filled areas.
Vertical recharge (natural leakage plus induced recharge through
recharge wells) will increase during the operation of the mine-
recharge project but is expected to return to baseline conditions
at some time after reclamation is complete if the recharge
program is terminated. The reason for the return to the baseline
conditions is that the vertical permeability of the underlying
Hawthorn/Tampa Formations is the controlling factor of natural
1eakage.
The primary effect of withdrawals from the deep ground-water
system is the lowering of the potentiometric surface within the
area of influence of the wells.
Prior to the initiation of withdrawals, the SWFWMD Consumptive
Use Permit requires the construction of sufficient recharge wells
to transmit 3 mgd of water from the surficial aquifer into the
34
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deep system. The effect of the recharge project will be to off-
set the withdrawals from the deep groundwater system by 3 mgd
thereby decreasing the net impact on the Floridan Aquifer.
The effect of the scheduled net withdrawals is at a maximum at
the end of the first three years of operation of the proposed
mine. The decline of the potentiometric surface on the mine
property will decrease when surface water becomes available
beginning in the fourth year and net withdrawals decrease by
3 mgd.
The effect of the proposed withdrawals on the potentiometric
surface is extremely small in comparison to the large seasonal
fluctuation. The effect of the scheduled withdrawals from the
deep groundwater system on the regional potentiometric surface
i s sma 11.
Mitigating measures on the effects resulting from the proposed
mining operations are primarily included in the terms and
conditions of the SWFVWD Consumptive Use Permit (No. 27703739).
Groundwater Quality
The chemical analyses of water samples from the surficial aquifer
throughout the region generally show the water to be soft, low
in chloride content except in areas of brackish or saline waters,
and often with relatively high iron concentrations.
In order of increasing depth, the Hawthorn/Tampa, Suwannee,
Oca la, Avon Park and Lake City Formations comprise the deep
groundwater system at the project site. With the exception of
the Lake City, these formations, which make up the Floridan
Aquifer, are typically relatively hard, clear, occasionally
odorous, with low chloride concentrations except in areas of
saline groundwaters near the coast.
Effects will be noticed in the shallow groundwater system in
response to the recharge and reclamation projects. Effects due
35
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to mining operations and dewatering are expected to be small
i n compar i son.
The use of the mined-out pits as storage areas for the waste
clays and tailing sands will have an effect on the water quality
in the shallow system. The nature of the water quality changes
will depend on the nature of the material placed in the pits.
The deep groundwater system will be affected primarily by the
recharge project. Any effects on this due to withdrawals and
the subsequent water-level changes are anticipated to be
negligible.
The potential effects due to the withdrawal of water from the
deep groundwater system include the upconing of highly-
mineralized water found below the producing zones and the lateral
movement of salt water inland from the coast. It is extremely
unlikely that either of these potential impacts will occur at
the Estech site.
Surface Water Hydrology
The 10,394 acre Estech site lies within portions of the
watersheds of the Manatee River, the Little Manatee River and
the Myakka River. A comparison of the three watersheds which
lie within the site boundaries is presented in Table 2.4-B
be low.
Table 2.4-B Drainage Basin Areas
Area of
Area of % of Water- Watershed
Total Area Watershed shed Within Upstream of
Watershed of Watershed Within Mining Mining Site Mine Site
Name (sq. mi .) Site (sq. mi.) (percent) (Sq. mi . )
Little
Manatee
River 211 2.2 1.0 37
Lake Manatee 123 13.6 11.1 20.2
Myakka River 550 <1 0.1 0
36
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United States Geological Survey (SGS) stream flow records on
the Manatee River, two miles downstream from the confluence of
the North and East Forks, were analyzed to obtain average
maximum, average mean and average minimum monthly flows for the
period of record from April 1966, through September 197f.
Variations in flow were registered for the North Fork of the
Manatee River and the South Fork of the Little Manatee River.
During peak stream flow periods a variable portion of the
discharge of the East Fork Manatee River will be diverted through
an off-channel weir to the surface water reservoir. This water
which will be used to make up 2.88 mgd of the process demands,
amounts to 25% of the average annual runoff of 11.8 mgd which
comes from the total Duette Mine property. The diversion will
not affect low or average flows since it will only occur during
periods of high flow.
A general reduction in runoff from the Estech property will occur
during the mining phase due to: 1) the increased area of water
retention bodies on the property; 2) deep well recharge by
connector wells; 3) dewatering of mine pits; and 4) the diversion
to the surface water reservoir. As a result of these reductions,
the combined average flow of the North Fork Manatee River and
the East Fork Manatee River will be reduced.
The majority of the water which enters the streams on the Estech
property as base flow comes from groundwater stored in the
surficial aquifer within an approximately 200 foot wide zone
adjacent to the streams. Since mining is not planned within
this zone, except for a three-quarter mile segment of the East
Fork Manatee River which will be rechanneled prior to its being
mined, mining will have minimal effect on base flow. It is
estimated that the reduction in base flow resulting from mining
will decrease the average flow of the East and North Forks
Manatee River where they exit the property by 1.0% and 1.5%,
respect ively.
37
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Surface Water Quality
Fairly extensive wetlands border the streams traversing the
proposed site, however, land uses at the mine site are primarily
agricultural. Pollutant loadings of streams in the area arise
almost exclusively from non-point, agricultural sources. There
are presently no industrial or municipal point sources of water
pollutants upstream or in the immediate vicinity of the proposed
mine site.
Because the great majority of proposed mine site lies within
the Manatee River drainage basin, the water quality investigation
(and others preceeding it) focused major attention on the North
and East Forks of the Manatee River which converge and flow into
Lake Manatee.
Occasionally large and/or frequent variations with State and
Federal water quality standards were observed in measured
concentrations of numerous physical, chemical and bacteriological
parameters in both the upper Manatee and South Fork Little
Manatee River basins. For the most part, these variations appear
to reflect natural conditions in these waters. Furthermore,
the quality of the water has permitted the development and
maintenance of moderately dense and diverse faunal communities
in the streams.
Constituents of the plant discharge which might potentially
degrade the quality of the streams leaving the site were
determined through a preliminary screening process.
Of the forty-seven parameters investigated for which standards
exist, fluoride and total dissolved solids (and the related
parameter, specific conductance) are the only parameters whose
concentration in the effluent may be expected to exceed ambient
water quality standards within the limits of detectabi1ity of
standard analytical techniques. These parameters, therefore,
merited further investigation.
In addition to fluoride and TDS, the parameters, total
phosphorus, total nitrogen, Biochemical Oxygen Demand (BOD),
38
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and total suspended solids (TSS) were selected for further
evaluation because of their potential effects on downstream water
supplies. The effects of each of the six parameters was
evaluated by estimating mass loadings (lbs/day) and concen-
trations (mg/l) in both the North Fork and East Fork after
complete mixing.
Hypothetical Failure of Clay Settling Area Embankment
Evaluation of a hypothetical failure of the clay settling area
embankment on the water quantity, quality and biology of the
receiving waters and adjacent wetlands was sunmarized beginning
with a description of the event and a brief discussion of its
probability of occurrence.
The impact analysis was predicted on a ground-level break in
the settling area embankment at the end of the third year of
mining. At that time, the ^80-acre settling area will be filled
to capacity with approximately 23 feet of waste clays covered
with 2 feet of clarified water. Two points of failure were
considered separately.
Evaluation of the impact of the hypothetical settling pond
failure on stream and reservoir water quality was subdivided
irtto six areas or phases of potential impacts: (1) effects
on stream water quality, (2) short-term effects on the Lake
Manatee Reservoir, (3) intermediate-term effects on the
reservoir, (4) long-term effect, (5) impact on the Manatee County
water plant and (6) expected radium-226 levels in the raw and
finished water supplies.
Radiological Environment
Baseline conditions of the radiological environment were evalu-
ated for subsurface and matrix radioactivity, garrma radiation
over unaltered lands, airborne radioactivity and radioactivity
of surface water and ground water.
39
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It is important to re-emphasize that any existing radium-226
in ground waters, especially in the Floridan Aquifer, may have
a variety of sources and the most likely source is the naturally
occurring radium-226 in the lower Hawthorn. This fact also makes
it exceedingly difficult to "trace" radium-226 to its source,
since nearly all materials and strata contain measurable
quant it ies.
The radiological impact of the proposed Duette Mine, its
beneficiation process and other activities are as follows:
Matrix Radioactivity - Radium-226 (9 pCi/g) in the matrix,
some forty feet below the surface, will be mined and
partitioned into waste clays (4 pCi/g), sand tailings
(1 pCi/g), product pebble (29 pCi/g) and product
concentration (24 pCi/g).
Subsurface Radioactivity - Pre-mining radium-226 profiles
(<1 pCi/g at the surface to 18 pCi/g near the matrix)
will be altered to a reclaimed profile having from between
1 and 4 pCi/g nearly uniformly distributed with depth.
Occupational Exposures - The highest potential for
occupational exposure would be in loading tunnels unless
they are ventilated and occupancy times restricted.
Terrestrial Gannma Radiation - The mean outdoor gamma
radiation of the site is expected to increase from 5.1
yR/hr to 8.8 yR/hr.
Airborne Radioactivity - Dryer and other airborne emissions
are expected to deposit over half of the radioactivity
within2& radius of 7.5 miles. The yearly deposition
(pCi/m per year) beyond one mile would not increase the
radioactivity of the soil to any measurable degree.
Lung dose calculations indicate the highest dose rate
for continuous exposure to be 6 mrem/yr at 500 meters
west of the stack. All lung dose rates for continuous
exposure beyond 1.5 miles are less than 1 mrem/yr.
Radon flux from the soil surfaces of the; site are expected
to increase from a basline of 0.2 pCi/m s to less than
0.8 pC i/m s .
Elevation of outdoor airborne radon-226 is not expected
to be measurable.
Land Use Criteria - Residential development for the site
is not expected within the immediate future. For any
homes that are constructed, the predicted indoor radon
progeny (WL) could range from .005 WL (tailings reclaimed)
to 0.023 WL (clay settling areas).
40
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Agricultural development of the site is not predicted
to pose any radiological impact from the limited soil-to-
crop-to-man food chain uptake.
Surface Water Radioactivity - Surface water radium-226
concentrations in off-site environs may be elevated from
natural levels of 0.8 pCi/1 to 2 pCi/1. By comparison,
the drinking water standard for radium-226 is 5 pCi/1
and the discharge guide1inesfor the industry is 9 pCi/1.
Groundwater Radioactivity - The groundwater radium-226
concentrations at the site are less than those observed
in some non-mining regions. Radium-226 in ground waters
appears to be associated with local subsurface
env i ronment s.
The connector wells for recharge of the Floridan Aquifer
represent a potential transport mechanism for radio-
activity. However, monitoring of the more basic water
quality parameters should prevent contamination by
radioactivity.
Biology and Ecology
The biological and ecological baseline characteristics of the
property are presented under three major headings based on
vegetation associations:
o Land - description of terrestrial plant and animal
corrmunit ies
o Land/Water Interface - description of plant and animal
conrmun i t ies inhabiting swamps and marshes
o Water - description of aquatic plant and animal
conrmun it ies
The existing land communities are sand pine scrub, longleaf pine-
xeric oak, xeric oak and longleaf pine flatwoods.
The existing land-water interface communities are freshwater
swamp, freshwater marsh and cypress.
The property contains three stream segments: East Fork Manatee
River, North Fork Manatee River and the Little Manatee River.
The direct effect of mining will be the physical destruction
of much of the present natural vegetatibn by land clearing/minina
activity. The longleaf pine-xeric oak community will be
eliminated on-site while the sand pine scrub community, longleaf
41
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pine-xeric oak connmunity and longleaf pine flatwoods corrmunity
will be partially eliminated (Table 2.4-C). An overall 85% loss
of native upland vegetation represents the magnitude of mining
ef fects.
Table 2.4-C Acreages Before Mining and After Reclamation (1)
Present Acreages After
Corrmun i ty Acreages Reelamat ion
Sand Pine Scrub (2) 73 50
Lonpleaf Pine-Xeric Oak 35 0
Xeric Oak (2) 518 89
Longleaf Pine Flatwoods (2) 5,673 829
Fresh Water Swamp (3) 1,219 1,228
Fresh Water Marsh (4) 600 864
Cypress Swamp (2) 18 18
Improved Pasture 1,677 6,642
Row Crops 468 107
Orange Groves 113 25
Mixed Forest 0 58
Lakes 0 384
Abandoned Mining Operations 0 100
10,394 10,394
(1) Data from Swift Agricultural Chemical Corp. (1978:
DRI/ADA No. 770861 and Addendum)
(2) Acreages after reclamation represent unmined lands that
still contain the vegetation present before the
commencement of mining operations.
(3) 476 acres of natural vegetation lost, mostly from along
tributary creeks and bayheads, also from along 4,000 feet
of the East Fork Manatee River which will be mined.
(Note: Revised in FEIS.) Fifty-five acres will be
recreated by planting saplings of native species at a
density of 60 saplings per acre along the recreated East
Fork Manatee River.
(4) 364 acres of natural vegetation will be lost from mining.
Some additional acreages will be disturbed or lost from
construction of roads, railroads, pipelines, powerlines
and from the crossings of draglines.
Not all sites containing native upland conrmunities will be mined.
The remnants of upland vegetation will primarily be small and
isolated between swamps and/or improved pastures.
During mining, the groundwater table will be lowered beneath
nearby natural communities which are not scheduled for mining.
42
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The water tables will be restored in less than two years as the
mined-out pits are filled during reclamation. Water tables are
expected to closely approximate their pre-mining levels
thereafter. The magnitude of dewatering would be equivalent
to that of severe drought.
The regrowth of fresh water swamps will be slow. Several decades
of tree growth are necessary before a mature forest develops.
Sweetbay, swamp bay and other species that are more common in
bayheads will likely remain relatively uncommon until peaty acid
substrates gradually develop along the minor tributaries.
Fresh water marsh reclamation should be more rapid. Emergent
and shallowly submerged aquatics readily invade borrow pits,
clay settling ponds and other newly created wet habitats in the
region.
The effect of mining on marshes will be short-term with regard
to the rapidity of marsh re-establishment on reclaimed lands.
The probability of cattails predominating in much of the
reclaimed marshland may constitute a long-term adverse impact
of low magnitude with regard to species diversity and wildlife
utilization. This impact would not be adverse with regard to
water quality and flow.
Various mining activities will result in the destruction,
alteration and/or restoration of aquatic habitats as well as
the creation of new habitats. Among the new habitats will be
several large lakes, a type of habitat not presently existing
in the vicinity of the mine site.
Little disruption of the flow in the streams is expected due
to mine pit dewatering (Ardaman & Associates, Inc., 1975), hence
there will be little impact on the aquatic biota.
Phosphate mining will create several lakes on the Estech site.
This is a significant expansion of the aquatic environment and
can be considered a positive impact of mining.
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The mining and reclamation plan incorporates several structural
and non-structural measures intended as safeguards for the
environment and biota of the site.
Sixteen endangered, threatened, rare or special concern species
have been observed on or immediately adjacent to the Estech
property. Of the sixteen observed species listed, none were
considered as endangered on the federal lists, but three were
listed as threatened. They were: pinweed, eastern indigo snake
and American alligator.
Bald eagles, ospreys and caracaras might make occasional visits
to the Estech property, but the present complex of habitats would
not be particularly attractive to these species.
This section assigned environmental sensitivity values to the
various attributes of each corrmun i ty/hab i tat. An area is
considered sensitive if it meets one or more of the following
cr iter ia:
o Contains endangered or threatened species which cannot
survive elsewhere.
o Fulfills an important function, such as aquifer recharge
or high wildlife capacity.
o Represents a unique or rare corrmunity or habitat in west-
central Florida.
Twelve attributes were evaluated on a scale of 1 to 5. Other
potential attributes were omitted because they do not represent
land uses (e.g., camping, hiking) or natural processes currently
associated with the Estech property. The assignments of some
values were necessarily subjective for lack of sufficient
observations or data.
2.5 DESCRIPTION OF BASELINE, IMPACTS, AND MITIGATING MEASURES
OF THE MATvMADE ENVIRONMENT
Demography
Population characteristics and projected growth for the seven-
county region should not be impacted by the planned Duette mining
44
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operation. It is an extension of general mining activities
within the industry and is a replacement for an existing Estech
fac i1i ty.
The local situation is similar to the brief Regional analysis.
Needed mine workers should be easily obtained from the local
labor supply. Support workers serving the mine operation may
reside in Manatee but in small numbers.
Economi cs
The following figures are the projected primary direct tax
revenues to state and local government during mining operations:
Annual Yield
Sales Tax (State)
operating supplies and materials
value - $9,561,000 x 4% = $ 382,400
Severance Tax (State)
Value to be set by Dept. of Revenue
est. value - $16.00/short ton,
tax rate (1980) 8%
25% of revenues - returned to
mine for reclamation
25% of revenues - to Fla. Phosphate
Research Institute
50% of revenues - to State general
jr evenues
production 3,000,000 T.P.Y. x $16.00 =
$48 ,000 ,000 x 8% = $3,840,000 - 50% = $1,920,000
Ad Valorem Tax (County)
value of real estate and plant
$ 120,947,400 x 16.388 mills = $1 ,982,000
Land Use
Land use for the proposed site is proposed to be agricultural
use in the Manatee County Comprehensive Plan. This use is
consistent with the planned mining operation because of the
proposed land reclamation program.
The proposed action will not significartly affect the future
growth patterns within the built-up coastal areas of Manatee
45
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County. The anticipated growth in residential land use will
year life of the mine operation. The corrmercial and institu-
tional land uses generally associated with residential develop-
ment will also develop where they are presently concentrated.
Community Services and Facilities
The Duette Mine is not expected to have a significant effect
upon potable water supplies within the County. Fire protection
and law enforcement facilities largely serve the built-up area
and there is no reason to anticipate any increased service as
a result of the proposed mine. Fire protection and emergency
medical services will be provided on the mine site. Domestic
waste generated by the mine will be treated on-site.
Sensitive Manmade Areas
No facilities, urban development or other significant manmade
features will be displayed by the site. Several long-abandoned
homesites will by removed by the mining operation. The only
significant prehistoric site which meets National Register
criteria is recomnended for protection.
Transportat ion
The initial increase in vehicular traffic due to the proposed
mining operation will be due to the construction of the plant
site, whereas later increases in traffic will be due to the daily
operation of the mine itself. Traffic generation from the Beker
and Grace proposed mines was considered in this analysis.
The proposed mining operation will generate one hundred, 80-ton
rail cars per day. Presently, the Port of Tampa has the only
major bulk loading facilities capable of handling the anticipated
production from the proposed mine. Should Port Manatee construct
a major bulk loading facility, the Duette Mine project would
create a very significant beneficial impact on those facilities
and the Port area in general.
46
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Archaeological and Historical Properties
Two field surveys of the Duette Mine tract were undertaken to
locate historic and prehistoric cultural resources on the
property^ to evaluate the significance of the resources, to
determine impact on the resources and to reconnmend mitigative
measures.
A total of five prehistoric sites were located on the property
durine the course of the two field surveys. One prehistoric
site, the Carruthers Mound, is deemed to meet the significance
criteria on the ground that it may contain data of regional
archaeological importance.
Such sites, few in number, are important cultural resources.
The Carruthers Mound is in an area which is not scheduled for
mining and hence will not be destroyed in that operation.
Resource Use
Electricity, gasoline and diesel fuel will be the energy sources
used during the construction phase of the project. Once in
operation, the mine and plant will operate on electric power
supplied by Florida Power & Light Company.
Fuel oil will be used to provide thermal energy for the product
dryers, and gasoline and diesel fuel will be used for motor
vehicles.
At the planned rate of 3.0 million short tons of product per
year, Estech will deplete the deposits presently identified
recoverable reserves in the projected 21 year mine life. The
60 million short tons of the economic reserves represent 4.3%
of the identified Florida resources.
2.6 COMPARISON OF PROPOSED ACTIVITY WITH ARE AW IDE EIS
RECOMMENDATIONS
The Final Areawide Environmental Impact Statement for the Central
Florida Phosphate Industry published by the Environmental
47
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Protection Agency in November 1978 (Areawide EIS) evaluated the
impact of various alternative scenarios of phosphate mining
in central Florida. The EPA recorrmendat ions represent a scenario
of phosphate development which was determined to be as compatible
as practicable with other desired and intended land uses. This
scenario provides a decision making tool for all new source
phosphate mines in central Florida.
The Areawide EIS recommended the elimination of rock-drying
processing at beneficiation plants and transportation of wet
rock to chemical plants. This recorrmendat ion was accompanied
by a description of conditions whereby the recommendation may
not be app1icable.
Since the Areawide EIS study was undertaken, important study
assumptions relative to air quality were mitigated by a
significant action of the U. S. Congress. The Clean Air Act
Amendments of 1977, required the application of Best Available
Control Technology (BACT) to all significant sources and source
modifications which had potential to deteriorate air quality.
The recorrmendat ion to eliminate rock drying in the Areawide EIS
was based upon greater allowable source emission rates than are
now permitted by U. S. EPA Prevention of Significant
Deterioration (PSD) Regulations promulgated under the 1977
Amendments. For example, study assumptions for particulate
matter were limited by allowable emission rates as provided for
in the Florida Administrative Code (F.A.C. 17-2.05,2, Process
Weight Table). This rule permitted particulate emissions at
least twice as great as allowed under the PSD Regulations. A
conclusion of the Areawide EIS proposed action was that the
phosphate industry pollutant contribution would remain relatively
constant after 1977. However, the PSD Regu1 at ions suggest that
the contribution should decrease as new processing facilities
are constructed and older less efficient control sytems are
replaced with new technology.
By establishing maximum increments of allowable deterioration,
the PSD regulations effectively restrict availability of the
48
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air resource. Once the available resource is consumed by
competing interest, no additional significant source effect can
be permitted without a corresponding reduction in effect from
another source. Thus the objective of the Areawide EIS to
protect air quality will be attained by an enforceable and
pervasive system of air quality control.
Estech proposes to construct a rock drying facility at the Duette
Mine site. Two fluidized bed dryers are planned for drying 252
tons per hour each (dry basis) of phosphate rock from 13% to
2% moisture. The proposed drying facility is subject to PSD
Regulations. These regulations require preconstruction
monitoring of pollutant levels, application of Best Applicable
Control Technology (BACT), and control of emissions to insure
that PSD concentration increments are not exceeded. The rock
dryers proposed for the Estech facility will utilize Venturi-
absorbers and wet centripetal vortex contact scrubbers. The
application of this technology will reduce emissions or parti-
culate matter and sulfur dioxide to levels well below state and
federal standards. The application of BACT will also minimize
the pollutant concentration levels of airborne radiation.
The Areawide EIS recommended that all New Source mines meet State
of Florida and local effluent limitations for any discharges.
Pursuant to Section 401 of the Federal Water Pollution Control
Act as amended (33 USC 1251, 1341), the State of Florida is
required to issue certification for each National Pollutant
Discharge Elimination System permit. All recent NPDES permits
issued by the State for phosphate mining facilities have been
certified subject to the following conditions:
1. The applicant must comply with all applicable requirements
of Chapter 403, Florida Statues and Chapter 17 series,
Florida Administrative Code.
2. Issuance of certification does not constitute State
certification of any future land alteration activities
which require other Federal permits pursuant to Section
404 of P. L. 92-500, as amended, nor does it constitute
approval or disapproval of any future land alteration
activities conducted in waters of the State which require
separate Department permit(s) pursuant to Section 17-4.28,
FAC.
49
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In accordance with Section 17-6.01(2)(a)2a.D., FAC, the
following effluent limitations apply to all discharges
designated as possibly containing contaminated runoff,
process generated wastewater or mine dewatering discharges
from the mining and beneficiation of phosphate rock:
Character i st ic
Di scharge
Limi tat i ons
1-Day Max. 30-Day Avg
Mon i t or i ng
Requ i remen ts
TSS
Total P
pH
mg / 1
mg/1
25
5
6.0-9.0
12
3
6.0-9.0
I/week/24-hr . composite
1/week/2^-hr. composite
1/week grab
This certification must indicate that the terms and conditions
of the NPDES permit will result in compliance with Sections 301,
302 and 303 of the Federal Water Pollution Control Act as
amended. The State may impose as additional requirements
applicable state law or regulations related to water quality
standards.
The elimination of conventional aboveground slime-disposal areas
was recorrmended by the Areawide EIS. In order to meet this
recorrmendat ion, the Areawide EIS encouraged the use of waste
clays, or a mixture of sand tailings and waste clays, in
reclamation, while at the same time it recognized the need for
an initial aboveground storage area and for retaining dikes
around sand-clay mix areas.
Estech's proposal conforms to this recorrmendat ion. Estech has
corrmitted in their mine plan to use a sand-clay mix in land
reclamation and thereby reduce the need for traditional, separate
disposal areas. The initial clay settling area planned by Estech
for the mining operation will receive all clay wastes generated
before the sand-clay mix procedure becomes operational. The
settling area will remain active throughout the mine life to
receive clay wastes in excess of the sand-clay mix requirements
and to serve as a secondary water clarification and storage
area.
Upon completion of mining, drainage and drying will be induced
to provide for subsidence and crust development of the clay
settling area. Once the clay has subsided to the desired level,
50
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the exterior retaining dike will be pushed toward and away from
the settling area to establish a lower grade slope and provide
some coarser textured material for the interior soils.
The Areawide EIS recommended that any New Source mine and benefi-
ciation plant meet Southwest Florida Water Management District
consumptive-use permit requirements. Estech is obligated to
the terms and conditions of the SWFXMD Consumptive Use Permit.
Should Estech fail to comply with all of the conditions set forth
in the permit, then the permit shall automatically become null
and void.
The Areawide EIS recommended that the New Source mine provide
storage that allows recirculation of water recovered from
slimes. The water recirculation system of the proposed mining
and beneficiation facility provides 156.03 mgd, 3.73 mgd are
lost to evaporation, 11.487 mgd by clay absorption, 2.28 mgd
are lost to seepage within the recycle system, and 142.27 mgd
are returned to the process system. Ninety-nine percent of the
water recoverage from slimes by the recycle system is either
returned to the plant process or lost to non-discharge
phenomena. The remaining 1%, or 1.43 mgd, is discharged.
Another Areawide EIS reconrmendat ion was for the use of connector
wells. As a condition of the SWFWD Consumptive Use Permit,
Estech has agreed to the installation and operation of connector
wells to recharge the Floridan Aquifer with an estimated
availability of 3 mgd. Monitoring of the quality of the water
being discharged from the shallow aquifer is required by SWFRMD
permit for various parameters and at a specified schedule. The
water quality analysis will include the following constituents:
a) Total coliform count g) Sulfate
b) Fecal coliform count h) Pesticides
c) Gross alpha radiation (if i) Organic Carbon
greater than 15 pCi/1 j) Specific conductance
analyze for radium-226, k) Nitrate
total radium) 1) Phosphate (ortho, total)
d) Iron m) Total dissolved solids
e) Fluoride n) Total suspended solids
f) Phosphorus o) Turbidity
51
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The permit further provides for the cessation of the introduction
of the water from the upper system for cause.
Another recorrmendat ion of the Areawide EIS was that each New
Source mine address proposed regulations regarding radiation
levels and develop a reclamation plan that considers radiation
of spoil material and the amount of radionuclide-bearing material
left within 3-4 feet of the surface.
All post reclamation criteria for the radiological environment
were estimated without returned topsoil. The mining plan,
however, suggests that approximately 2 feet of topsoil may be
returned to some of the reclaimed area. This procedure is
recorrmended, since expected guidance for construction of
residential homes may require near background levels. The final
clay settling area when returned to any land use will be most
beneficially affected by returned topsoil. The 3-4 feet of
returned topsoil recommended in the Areawide EIS, however, may
have a high cost-benefit ratio in this region of lower matrix
radioactivity.
If the final guidance (EPA, 1979) for reclaimed lands suggests
an upper limit of predicted radon progeny in slab-on-grade homes
of 0.009 WL (normal background of 0.004 WL plus the uncertainty
of 0.005 WL), then the Duette site may have to consider the
return of topsoil to any residential development site.
The areawide EIS recommended meeting county and state reclmation
requirements and including in the DRI and/or site-specific EIS
an inventory of types of wildlife habitat in the area to be mined
and the area immediately surrounding it. In addition, it
recommended the mining and reclamation plan take into account
the protection and restoration of habitat so selected important
species of wildlife will be adequately protected during mining
and reclamation.
Wildlife habitats with their associated fauna and flora are
described in detail in the Biology and Ecology section of the
DEIS and the attendant Resource Document. Restoration or
52
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preservation of some wildlife habitats have been incorporated in
the mining and reclamation plan. Not all areas of the property
will be mined or irrevocably disturbed. Of the unique com-
munities on site, fifty acres of sand pine scrub and the 18-
acre cypress dome will be preserved. Approximately 829 acres
of cut-over flatwoods excluded from mining will be restocked
with pine to enhance wildlife value.
Following the EPA recorrmendat ion to preserve the section of the
East Fork Manatee River scheduled for mining, all floodplain
swamps of streams having greater than 5 CFS mean annual flow
will be spared from mining and will be preserved without modi-
fication. The major stream corridors were found to be the most
valuable wildlife habitat on-site.
The Areawide EIS recommended protection or restoration of
wetlands "under the jurisdiction of the Corps, Section 404,
Federal Water Pollution Control Act, pursuant to 404(b)
Guidelines (40 CFR 230)".
No specific boundaries of wetland areas have been officially
identified by the Corps of Engineers. Three categories of
wetlands were, however, established in the Central Florida
Phosphate EIS:
Category 1 - Wetlands to be protected (not mined)
Category 2 - Wetlands which may be mined but must be
restored as wetlands capable of performing
useful wetland functions
Category 3 - Wetlands which can be mined without restoration
as wetlands
Definitions for the categories established in the Areawide EIS
were developed in the Draft EIS. The definitions were presented
as a suggested methodology for determining the limits of each
category. These categories should be viewed as general guide-
lines to rank natural wetlands on Florida phosphate mining sites
in terms of their value to regional hydrology, water quality
and fish and wildlife protection. This categorization is
intended to aide in the EPA review process of proposed Mining/
Reclamation Plans for New Source Mines. The three categories
53
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are defined in further detail for application to the review of
Estech's Duette property.
The three categories of wetland on the Duette site were
delinated. A segment of the East Fork Manatee River is a major
Category 1 wetland proposed for mining. EPA recormnends that
this segment, as well as all other Category 1 wetlands, be
preserved. (Note: Estech has modified their proposed activity
to exclude the mining of the East Fork Manatee River, a Category
1 wet land.)
Any of the Category 2 wetlands which are proposed for mining
may be mined and must be restored. The proposed reclamation
plan will result in a net gain of 15% for swamp and marsh acreage
on the site.
The Areawide EIS recommended that efforts be made to preserve
archaeological or historical sites through avoidance or
mitigation on sites deemed significant by the Florida Division
of Archives, History, and Records Management. If mitigation
is chosen, the resulting report should be submitted to that state
agency for examination and conment.
One archaeological site of significance, the Carruther's Mound,
was identified on the Estech property. The mound is in an area
which is not scheduled for mining and hence will not be destroyed
in that operation.
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3.0 ERRATA
3.1 DRAFT
ENVIRONMENTAL
IMPACT
STATEMENT
Page
Paragraph &
Line
Correct ion
Summary Sheet
(1)
2
7
Change
"Imapct" to "Impact"
Sumnary Sheet
(4)
3
5
Change
"minig" to "mining"
Surrmary Sheet
(5)
2
2
Delete
"use"
Sunrmary Sheet
(6)
3
14
Change
".023" to ".015"
Summary Sheet
(6)
4
6
Change
"appears" to "appear"
7
3
14
Change
"one-mile" to "3/4 mile"
31
5
7
Change
"3.75" to "3.8"
31
5
7
Change
"6.3" to "8.4"
33
4
6"
Chanee
"at" to "of"
42
1
2
Change
"12.8" to "12.9"
43
Figure 4.2
-5
Replace
4.2-5R
with revised Figure
51
5
3
Change
"drainged" to "drained"
52
4
19
Change "provideing" to
"providing"
53
65
80
82
82
4 3
Figure 4.7-3 (a) (b)
4
3
3
4
3-4
Change "rclaimed" to "reclaimed"
Generalized change (dotted line)
in potentiometric surface will
be to the northeast instead
of to the southwest as shown.
Change "2000" to "200"
Change punctuation at end of
sentence from "1978." to
"1978)."
Replace with "that do not con-
form to either EPA (1976) water
quality criteria, phosphate
mine effluent limitations or
state standards for Class I-A
waters are italicized."
55
-------
- 305£ i 4
-3054
-3052
-3050
-3048
5.2 yg/m
PPTY. BOUNDARY ^
.SECOND
I MAX. PT.
L* 9.8 wg/
IV ji
+ 3 +
AM 8.1 vg/m
PPTY. BOUNDARY
TO HYAKKA HEAD
- 3046
- 3044
z_h_D, *
I J.
FIGURE 4 2-5R
SHORT TERM (24 HOUR) EFFECTS OF INCREMENT
CONSUMING SOURCE PARTICULATE EMISSIONS
SOURCE CONSERVATION CONSULTANTS INC.
U.S. EPA - REGION IV
DRAFT ENVIRONMENTAL
IMPACT STATEMENT FOR
SWIFT AGRICULTURAL CHEMICALS
CORPORATION
PROPOSEO DUETTE MINE
MANATEE COUNTY , FLORIDA
-------
Page Paragraph & Line
83 Table 4.10-A
86 5 1
90 Figure 4.10-2
91-100 All
92 First Line
93 3 3
93 5 5
98 6 2
100 First Line
100 1 3
100 3 1-8
Correct ion
Remove italics from all entries
under pH except for the minimum
values of 5.5 and 5.7 at
Stations 2 and 7, respectively.
Remove italics from all entries
under Fluoride.
Delete "in the" and replace
with "at". Also insert
"stations" after "on-site"
Replace Figure 4.10-2 with
revised Figure 4.10-2R
Pages 91-100 were duplicated
in several copies during
printing process. Not all
copies were affected.
Change "5%" to "1.6%"
Replace sentence with "Loadings
of total nitrogen, BOD and
TDS were based on their expected
daily average concentrations,
whereas loadings and resultant
concent rat ions of total phos-
phorus, fluoride and TSS were
computed for both 30-day average
and daily maximum contaminant
levels."
Change "is" to "are"
Change "of" to "on"
Delete "and instantaneous"
Change "butr" to "but"
Replace paragraph with "The
concentration of suspended
solids at the intake structure
to the water treatment plant
was estimated using Stoke's .
Law (American Water Works As-
sociation, 1971) and a particle
size distribution representative
of waste clay from Central
Florida mines (Lamont, et al.,
1975). It was conservatively
estimated that k7% of the sus-
pended solids would be removed;
56
-------
R 21 I I R 22 E
SOUTH FORK
LITTLE '
manatee
RIVER
FIGURE : 4.10-2R
DISCHARGE POINTS ANr
WATER QUALITY MONITOF
STATIONS
source: ZELLARS - WILLIAMS , INC.
U.S. EPA - REGION IV
DRAFT ENVIRONMENTAL
CT STATEMENT FOR
T AGRICULTURAL CHEMICALS
< ¦'PRORATION
"OSED DUETTE MINE
. jAMATEE COUNTY , FLORIDA
-------
Page Paragraph & Line
100 (con't) 3 1-8
Cor rect ion
hence, a maximum of 425 mg/1
could be expected to enter the
lowermost water intake
structure."
100 4 1-2 Delete
101 First Line Delete remainder of paragraph
beginning with "An increase in
alum " Replace with
"Results of jar tests conducted
by the Manatee County Utilities
Department (Conservation Con-
sultants, Inc., 1980) indicated
that approximately a 61%
increase in the normal alum
dosage would be necessary to
effectively remove 425 mg/1
of suspended solids. The sludge
handling system of the facility
would be potentially stressed
by the increased mass of solids.
To protect the sedimentation
basin scraper assembly from
possible damage, some increase
in the frequency of basin
blowdown would probably be
necessary. The resulting
increase in the volume of sludge
would likely exceed the planned
capacity of the drying bed and
lagooning system. Proper
disposal of the excess sludge
would require either modifi-
cations to the existing facility
or transporation of the wet
sludge to another disposal site.
If a satisfactory method for
disposing of excess sludge were
developed, no reduction in the
water production capacity of
the plant would be necessary."
101 1 1-8 Delete
101 2 13 Change "52" to "425"
101 2 15 Change "0.4 pCi/1" to "3.4
pCi/1"
101 2 20 Change "1.2 pCi/1" to "4.2
pCi/1"
57
-------
Page Paragraph &: Line
103 1 2
111 t 2
111 *
111 5 5
111 8 5
112 Figure ^.11-3
113 * 6
123 5 5
12^ Third Line
12Tenth Line
129 5 10
136 5 7
181 NPDES draft permit
vii Selected Bibliography
xi Selected Bibliography
Cor rect ion
Change "benefication" to
"benef iciat ion"
Change "5.1 R/hr" to "5.1
ViR/hr"
Change "6.3 R/hr" to "6.3
pR/hr"
Change "Uranium-238, Thorium-
230, Radium-226" to "uranium-
238, thorium-230, radium-226"
Change "Uranium and Radium-228"
to "uranium and radium-228"
Change "concentration" to "con-
centrate"
Change "(x0.5 pCi/g)" to
"(-0.5 pCi/g)"
Change "diamond back" to
"d iamondback"
Change "meadow lark" to
"meadowlark"
Change "betwen" to "between"
Change "indefinitely." to
"indef initely,"
Change "carracara" to "caracara"
Pages 6 and 8 were omitted.
Complete draft NPDES permit
included in Section 8.1 of FEIS.
Add the following reference
after the third entry; "Con-
servation Consultants, Inc.,
1980. Personal corrmunicat ion
between R. M. Eckenrod (CCI)
and 3. Zimmerman (Manatee County
Utilities Department), May
1980."
Add the following reference
as the first entry; "Lamont,
W. E., J. T. McLendon, L. W.
Clements, 3r., and I. L. Feld.
1975. Characterization Studies
58
-------
Page
Paragraph & Line
Correct ion
x i (con't)
App
22 1-3 All
of Florida Phosphate Slimes.
U.S. Department of Interior,
Bureau of Mines, Tuscaloosa
Metallurgy Research Laboratory,
University, Alabama."
Replace with "The Tampa wind
distributions show evidence
of land-sea interaction, i.e.,
morning easterly - afternoon
westerly, particularly during
the spring and summer months
(NOAA, 1972). The fall/winter
distributions for both Tampa
and Lakeland suggest each
experience much of the same
effect from the passage of cold
period frontal systems.
The mean annual wind speed for
Lakeland (1942-1945) was 6.8
knots (3.5 meters per second,
7.8 miles per hour). The
highest seasonal mean wind speed
was 8.0 knots (4.1 meters Der
second, 9.3 miles per hour)
in the spring and the lowest
was 5.5 knots (2.8 meters per
second, 6.3 miles per hour)
in the summer. A wind speed
of 11.3 knots (5.8 meters per
3.2 ARCHAEOLOGICAL AND HISTORICAL PROPERTIES RESOURCE DOCUMENT
Paragraph & Line Correction
54 3 4 Change "wtihin" to "within"
endices Site data sheets Delete last 36 pages
were duplicated
3.3 METEOROLOGICAL CONDITIONS RESOURCE DOCUMENT
Page Paragraph & Line Correct ion
6 Table 3-B Delete last two columns
19 Table 6.1-A
-------
TABLE 6,1-AS
SEASONAL WINO DISTRIBUTION FREQUENCY AND WIN! SPEED FOR LAKELAND (1942-1945)
SPRING
STJtWR
rAlU
WINTER
ANNUAL •
01s-
Dis-
01s-
DIs-
01s-
bution
tant ion
bution
butlon
bulion
Fre-
Mean
Fre-
Mean
Fre-
Mean
Fre-
Mean
Fre-
Mean
quency
Mind Speed
quency
wind Speed
quency
Wind Speed
quency
Wind Speed
quency
Wind Soeed
Direction .
X
MPH
Knots
m/Sec
X
MPH
Knots
m/Sec,
X
MPH
Knots
m/Sec
I
MPH
Knots
m/Sec
I
'MPH]
Knots
m/Sec
H
4.1
7.8
6.8
3.5
3.2
5.7
4.9
2.6
10.2
6.6
5.7
3.0
8.6
7.8
6.8
3.5
6.9
7 1
6.2
3.2
m
5.6
9.0
7.6
4.0
2.3
5.1
5.3
2.7
8.5
B.O
6.9
3.6
7.0
8.6
7.6
3.9
6.1
H 3
7.2
3.7
NE
8.4
9.8
8.5
4.4
7.3
6.0
5.2
2.7
18.4
a.1
.7.6
3.5
8.5
8.0
6.9
3.6
U .0
8,3
7.2
3.7
M
9.6
11.1
9.6
5.0
6.0
;.3
6.3
3.3
9.3
a j
7.6
3.9
6.8
8.5
7.4
3.8
8.0
9 0
7.0
4.0
E
9.9
9.2
8.0
4.1
6.6
6.3
5.5
2.8
8.6
1.4
6.4
3.3
6.0
7.5
6.5
3.4
7.7
7 ft
6.8
3.5
ESE
8.0
9.5
8.2
4.3
6.1
6.9
b.O
3.1
3.1
6.5
5.6
2.9
3.1
8.4
7.3
3.8
4.B
R 1
7,0
3.6
SE
8.9
9.0
7.8
4.0
10.7
5.7
4.9
2.6
4.2
b.O
4.2
2.7
4.4
6.9
6.0
3.1
6.7
7 0
6.1
3.1
SSE
6.3
10.5
9.1
4.7
5.7
6.4
4.6
2.9
1.7
t>. a
6.9
3.0
4.3
9.4
fl.2
4.2
4.3
fl 6
7.5
3.8
S
5.1
b.2
8.9
4.6
6.3
6.0
5.2
2.7
2.8
b.l
5.3
2.7
5.5
8.9
7.7
4.0
4.8
7 <>
6.9
3.5
SSW
4.5
11.4
9.9
5.1
6.4
5.4
5.6
2.9
1 .8
6.8
5.9
3.0
4.4
10.8
9.4
4.8
4.1
9 0
7.8
4.0
sw
5.5
11.4
9.9
5.1
7.4
/.0
6.1
3.1
2.9
b.3
5.5
2.8
5.3
9.5
8.2
4.3
5.1
B 7
7.6
3.9
ViSU
3.2
1\ .6
10.1
5.2
2.8
7.6
6.6
3.4
1.7
7.2
6.3
3.2
2.9
9.5
8.2
4.3
2.6
9 ?
8.0
4.1
w
4.0
9.4
8.2
4.2
4.1
S.I
7.0
3.6
2.7
7.2
6.3
3.2
4.6
8.9
7.7
4.0
3.8
8 "i
7.4
3.8
WNW
3.5
9.7
8.4
4.3
3.3
3.5
7.4
3.8
3.1
9.1
7.9
4.1
6.9
10.3
8.9
4.6
4.3
9 f,
8.3
4.3
NW
3.9
9.8
8.5
4.4
4.2
7.2
6.3
3.2
6.3
7.7
6.7
3.4
8.2
8.5
7.4
3.8
5.9
« 1
7.2
3.7
NNW
3.0
8.0
6.9
3.6
2.1
6./
5.8
3.0
5.2
6.0
5.2
2.7
5.9
7.5
6.5
3.4
4.3
7.0
6.1
3.1
CALM
6.4
15.4
9.6
7.7
9.6
Mean Wind
Speed
9.3
8.0
4.1
6.3
5.5
2.8
6.8
5.9
3.0
8.2
7.1
3.7
7.8
6.8
3.5
TA8LE 6.1-8R
SEASONAL WIND DISTRIBUTION FREQUENCY AND WINC SPEED FOR TAMPA (1965-1969)
SPRING
' SUMMER
l-'ALL
01s-
01s-
01s-
butlon
bution
bution
Fre-
Mean
Fre-
Mean
Fre-
Mean
Direction
quency
Wind Speed
quency
Wind Speed
quency
Wind Speed
X
MPH
Knots
m/Sec
X
MPH
Knots
m/Seci
X
tjPH
Knots
m/Sec
N
4.5
7.7
6.7
3.5
3.0
3.3
7.2
3.7
8.2
8.5
7.4
3.8
NNE
3.7
7.9
6.9 .
3.6
3.0
5.8
5.9
3.0
9.5
9.1
7.9
4.1
NE
5.3
8.8
7.6
3.9
5.5
7.1
6.2
3.2
11 .6
9.1
7.9
4.1
ENE
7.7
8.4
7.3
3.8
9.2
7.0
6.1
3.1
14.8
8.6
7.5
3.9
E
14.4
9.7
8.4
4.3
15.7
7.1
6.2
3.2
M.fl
8.8
7.6
3.9
ESE
7.0
9.6
8.3
4.3
8.7
7.5
6.5
3.4
5.1
8.3
7.2
3.7
SE
4.9
9.4
8.2
4.2
6.1
7.3
6.3
3.2
3.0
8.8
7.6
3.9
SSE
4.3
9.2
S.O
4.1
7.0
7.3
6.3
3.2
2.9
7.4
6.4
3.3
S
4.1
11.5
10.0
5.2
5.2
8.3
7.2
3.7
3.1
8.5
7.4
3.8
SS«
3.9
10.8
9.4
4.8
3.1
9.0
7.8
4.0
1.7
8.5
7.4
3.8
Sw
3.1
9.8
8.5
4.4
3.6
3.4
7.3
3.8
1 .7
7.8
6.8
3.5
wsu
4.6
9.9
8.6
4.4
6.0
8.5
7.4
3.8
2.5
8.2
7.1
3.7
w
11.1
11.5
10.0
5.2
11.6
9.3
8.1
4.2
5.4
8.9
7.7
4.0
UNU
6.0
10.1
8.8
4.5
2.8
3.4
7.3
4.3
2.8
9.4
8.2
4.2
NW
6.1
9.3
8.1
4.2
2.6
3.1
7.0
3.6
3.9
8.9
7.7
4.0
NNW
4.7
8.9
7,7
4.0
2.2
7.7
6.7
3.5
4.5
8.6
7.5
3.9
CALM
4.6
4.5
4.2
Mean Wind
Speed ,
9.0
7.8
4.0
7.4
6.4
3.4
8.1
7.0
3.6
Dis-
butlon
Fre-
quency
1
WINTER
8.7
7.8
8.3
9.3
? 1.2
5.0
4.4
5.1
7.2
3.7
1.6
2.1
5.0
3.1
5.4
7.1
5.0
Mean
Wind Speed
MPH Knotsl m/Sec
8.6
9.1
9.1
8.2
8.3
8.6
9.1
9.1
10.4
9.3
8.5
7.8
9.1
10.6
10.7
11.4
8.7
7.5
7.9
7.9
7 ,\
7,2
7.5
7.9
7.9
9.0
8.1
7.4
6.8
7.9
9.2
9.3
9.9
7.6
3.9
4.1
4.1
3.7
3.7
3.9
4.1
4.1
4.6
4.2
3.8
3.5
4.1
4.7
4.8
5.1
3.9
'ANNUAL
OH-
but ion
Fre-
quency
1
6.1
6.0
7.7
10.2
14.0
6.5
4.G
4.8
4.9
3.1
2.5
3.8
8.3
3.7
4.5
4.6
4.6
Mean
Wind Speed
MPH
Knots
m/Sec
8.4
7.3
3.8
8.6
7.5
3.9
fl.6
7.5
3.9
8.2
7.1
3.7
8.4
7.3
3.8
8.4
7.3
3.8
8.5
7.4
3.8
8.2
7.1
3.7
9.8
8.5
4.4
9.7
8.4
4.3
8.8
7.6
3.9
8.8
7.6
3.9
10.0
8.7
4.5
9.8
8.5
4.4
9.4
8.2
4.2
9.7
6,4
4.3
8.4
7.3
3.8
19
-------
Page Paragraph & Line Correct ion
22 (con't) 1-3 All second, 13.0 miles per hour)
was exceeded 13.6 percent of
the time.
The mean annual wind speed for
Tampa (1965-1969) was 7.3 knots
(3.8 meters per second, 8.4
miles per hour). The highest
mean seasonal wind speed of
7.8 knots (4.0 meters per
second, 9.0 miles per hour)
was for the spring.
The lowest wind speed of 6.4
knots (3.4 meters per second,
7.4 miles per hour) was in the
summer. A wind speed of 10
knots (5.2 meters per second,
11.5 miles per hour) was
exceeded 17.6 percent of the
time. Table 6.1-C presents
select wind speed and the per-
cent of time these wind speeds
were exceeded for the Tampa
data base."
23 Table 6.1-C Change "1.51" to "1.54"
24 2 2-12 Replace with "The mixing depth
is the depth above the surface
through which relatively
vigorous vertical mixing occurs
and relates to the dry adiabatic
lapse rate. The ventilation
factor is the mixing depth times
the average wind speed through
the mixing depth. Cubic meters
of air available for dilution
can be determined from this
factor by multiplying it by
a distance transverse to the
wind. Table 6.3-A, lists mean
seasonal mixing depths, mean
wind speed through the mixing
depth and ventilation factors
for Tampa (NOAA, 1968). These
were calculated from non-
precipitation events as the
assumption of a dry adiabatic
lapse rate in the mixing layer
becomes questionable when
precipitation occurs (Holzworth,
1972)."
60
-------
Page Paragraph ic Line
24 (con't) 2 2-12
27
29
Lines 1-S
1 1-4
Cor rect ion
Replace with "A mixing depth
of 150 meters or less occurred
15.7 percent of the time from
1960 through 1964 and a mixing
height of less than 120 meters
can be expected about 10 percent
of the time. The greatest
occurrence of low mixing height
conditions can be expected from
October through May (NOAA,
1968). The average annual
morning mixing depth is 493
meters for non-precipitation
cases with an average wind speed
of 5.3 meters/second. The
average annual afternoon mixing
depth is 1359 meters for non-
precipitation cases with an
average wind speed of 6.2
meters/second (Holzworth,
1972)."
De lete
Replace with "Tornados can occur
anywhere in Florida. Lakeland
and the proposed mine site lie
within a 1° square (latitude -
longitude) which recorded a
total of 42 tornados between
1955 and 1967. During this
same period of years, the month
of June produced a maximum of
92 tornados in the entire State
of Florida (Pautz, 1969)."
3.4 SOILS RESOURCE DOCUMENT
Page Paragraph & Line
S
14
16
17
2
1
2
13
13
12
13
Correct ion
Change "over-burden" to
"overburden"
Change "over-burden" to
"overburden"
Change "or" to "on"
Change "CaO," to "CaO"
Change "over-burden" to
"overburden"
-------
3.5 RECLAMATION METHODOLOGY RESOURCE DOCUMENT
Page Paragraph & Line Correct ion
13 2 2-3 Delete "in the form of fixed
structures (pipes) or". Insert
"established by the"
15 2 15-16 Paragraph is out of place.
Should appear under 3.6 Plant
Site.
34 2 3 Change "approximatel" to
"approximately"
38 3 4 Change "disign" to "design"
48 1 15 Change "of" to "on"
49 Table 7-A Hardwood acreage before mining
should read "5.8" not "0".
Lakes precentage after
reclamation should read "3.7"
not "4.7"
3.6 RADIOLOGICAL ENVIRONMENT RESOURCE DOCUMENT
Page Paragraph & Line Correction
6 2 5 Change "exponeutial" to
"exponent ial"
6 3 7 Change "radium-226" to
"rad ium-228"
7 Fourth Line Change "sufficiant" to
"suff icient"
11 2 4 Change "this behavior" to "the
behavior"
13 2 1 Change "ubitiqous" to
"ubiquitous"
20 Figure 4.1-3 Ra-226 values are graphically
presented approximately 20%
higher than actual values.
Text and related tables are
correct.
26 3 3 Change "United State" to "United
States"
62
-------
46
50
Paragraph & Line Correct ion
Fifth Line Change "may itself a source" to
"may itself be a source"
First Line Delete "of"
Last Line Change "effeciency" to
J "efficiency"
Fieure 2.1-1 Change "concentration" to
"concentrate"
_7 j 7 Change "the beneficiation plant,
3 gamma" to "at the beneficiation
plant gamma"
_Q ,9 Change "1.9 pCi/1" to "1.9
59 pCi/g"
71
77
79
SO
80
83
83
I 3 Change "is" to "are". Change
"aspect" to "aspects"
^ 6 Change "is" to "are"
Second Line Change "paint" to "plant"
64
65
67
. Second Column Change "Garrma, R/hr" to "Gamma,
/l yR/hr"
2
Fourth Column Change "pCi/m s" to "pCi/m s"
2 4 Change "or" to "on"
3 2 Change "servies" to "services"
1 6 Change "oportunity" to
"oppor tun i ty"
1 7 Change "fraction" to
"f ract ionat ion"
if 1 Change "emisions" to "emissions"
9 3 Change "an" to "a"
3.7 SURFACE WATER QUALITY RESOURCE DOCUMENT
Page Paragraph & Line Correction
14 Table 2-D Insert "Supplement to Tables
2-D and 2-F, Part I" after page
14.
63
-------
Supplement to Tables 2-D and 2-F, PART I
Station 9 - Lake Manatee
Parameter MANATEE COUNTY HEALTH DEPARTMENT USGS
Mar/ June/ Sept/ Oct/ Nov/ Dec/ Jan/ Feb/ Mar/ June/ 1970 - 1976
77 77 77 77 77 77 78 78 78 78 Average
Biochemical Oxygen Demand 2 11 1 11 1.6
Chloride 12.5 13.9 8.0 14.5 10.5 14.5
Coliform, Total (Colonies/100 ml) 5850 4900 4800 19000 4900 15000 3550 1204
Fecal 122 140 80 230 240 1100 70
Color (PCU) 80 140 280 100 120 110 66
Dissolved Oxygen 8.4 6.9 4.6 8.4 7.1 6.4 7.3
Fluoride, as F 0.25 0.29 0.15 0.20 0.21 0.22 0.5
Hardness, as CaC03, Total 74
Nitrogen, as N, Total 0.82
Organic 0.58
Ammonia 0.05
Kjeldahl 0.63
Nitrate 0.08 0.15 0.18 0.13 0.13 0.12 0.17
pH 7.5 6.7 6.0 6.5 6.5 6.7 7.3
Phosphorus, as P, Total 0.52
Ortho 0.63 0.47 0.50 0.27 0.35 0.35 0.48
Residue, Total Non-filterable 0 11 27 16 14 9
Total Filterable 0 105°C 103 170 85 177 143 132
Specific Conductance, ymhos/cm 199
Temperature, °C 19 24 30 12.5 18.5 25.5 23.7
Total Organic Carbon 11.8
Turbidity, JTU 44
-------
17
22
25
13-34
35
35
37
55
74
75
75
79
113
Paragraph & Line
Table 2-F
Table 2-H
Table 2-1
Table 4.1-A
Second Column
Footnotes
Table 4.1-B
1
10
1 5
Table 2-C Third Column
Cor rect ion
Corrected by insert of Supple-
ment described for page 14.
Table 2-H was inadvertently
reduced during printing.
Original is available upon
request.
Remove italics from all entries
under Fluoride.
Change F.A.C. 17-22 standard
for Chromium from "15" to "0.05
(Hexavalent)"; change F.A.C.
17-22 standard for Color from
"1.0" to "15"; change F.A.C.
17-22 standard for Chlorine
from "0.05" to "0.50 mg/1
(minimum)"; change F.A.C. 17-3,
Class III standard for Fluoride
from "Marine Only" to "10.0 mg/1
(freshwater), 5,0 mg/1 (pre-
dominantly marine water)."
Add superscript "9" after
"Cr i ter ia"
Add footnote "9 General
Criteria apply to all waters
of the State except when other-
wise noted"
Substitute revised Table 4.1-BR
for Table 4.1-B. Revised table
includes corrected entries for
color, pH and fluoride.
Change "State standard" to "EPA
cr iter ion"
Change "0.5 mg/1" to "0.40 mg/1"
Change "0.034a" to "0.034 (N03
as N)a"
Table 2-C Third Column Change "0.025a" to "0.025 (NH^+
as N) "
Change "5" to "1.6"
2
3
Delete "and instantaneous"
-------
Table 4.1-BR. Frequency of Variation with Water Quality Criteria.
Parameter
(Agency/Cri terion)
Station Identification Number
1
2
3
4
5
6
7
9
10
Physical Parameters
Dissolved Oxygen
(FDER, EPA/5.0*)
5
(12)**
6
(10)
8
(11)
6
(12)
0
1
(2)
23
(36)
1
(13)
8
(11)
Specific Conductance
(FDER/500 ymhos/cm)
0
0
1
(13)
0
0
0
0
0
0
Total Suspended Solids
(EPA/60 max; 30 avg,
daily)
0
0
1 (ID
2 (11)
0
1 (13)
0
1 (14)
1 (2)
2 (2)
,0
1 (2)
0
0
0
0
0
0
Color
(EPA/75 PCU)
8
(12)
9
(10)
8
(11)
8
02)
—
—
—
8
(9)
7
(9)
Major Cations and Anions
PH
(FDER/6.0-8,5)
0
(14)
3
(ID
0
(13)
0
(14)
0
(2)
0
(2)
6
(26)
0
(11)
1
(11)
Fluoride
(FDER Class I-A, 1.5 mg/1)
0
(14)
0
(11)
0
(13)
0
(14)
0
(2)
0
(2)
0
(26)
0
(11)
0
(10)
* Units in milligrams/liter unless otherwise noted.
** Numbers in parentheses denote the total number of determinations
— Denotes either no data or inconclusive results
-------
Page
116
116
116
117
119
119
120
127
128
Paragraph & Line
1 11
1
12-17
2
4
1-8
5
2
2
13
15
First Line
Ninth Reference
Bibliography
APPENDIX E
Figure 4
Cor rect ion
Change "2.5 microns" to "2.2
mi crons"
Replace the sentence beginning
with "With the known " with
"Using an average particle size
distribution representative
of Florida phosphate slimes
(Lamont, et al., 1975), it was
estimated that 42 percent of
the suspended solids would be
removed. Hence, a maximum of
5S percent or 425 mg/1 could
be expected to enter the
lowermost intake structure of
15.25 feet (MSL).
De1e t e
Delete "to the maximum level
of 1.0 Platinun - Cobalt Unit
(PCU) allowed by F.A.C. Chapter
17-22 (Public Water Supplies)."
Change "52 mg/1" to "425 mg/1"
Change "0.4 pCi/1" to "3.4
pCi/1"
Change "1.2 pCi/1" to "4.2
pCi/1"
Delete entire entry beginning
with "Brune, G. M."
Insert the following reference
after the fourth entry; "Lamont,
W. E., J. T. McLendon, L. W.
Clements, 3r., and I. L. Feld.
1975. Characterization Studies
of Florida Phosphate Slimes.
U.S. Department of Interior,
Bureau of Mines, Tuscalossa,
Metallurgy Research Laboratory,
University, Alabama."
Insert Figure 4 following Figure 3
65
-------
waste clay SAMPLE no.!
U5,G PERCENT SOLIDS)
-------
Page Paragraph & Line
APPENDIX F First Page
APPENDIX F Second Page 5
APPENDIX F Second Page 6
APPENDIX F Second Page 17
APPENDIX F Second Page 17
APPENDIX F
APPENDIX F
APPENDIX F
Third Page
Fourth Page
Fifth Page
Correct ion
Replace last seven lines with
"ps = mean particle density
= 169 lbm/ft"*
based on average density
of slimes from fifteen
Florida phosphate mines
(Lamont, et al., 1975).
p = density of water
= 62.2 lbm/ft at 80 F
Change "2.514" to "3.229"
Delete entire description in
STEP 2.
Change "STEP 3" to "STEP 2"
Replace description in STEP 3
with "STEP 3: Compute critical
particle diameter, d , corres-
ponding to critical velocity
using equation from STEP 1.
0.001046 ft/min
1/2
_(60 ft/sec)(3.229 x 10
= 7.348 ft
= 2 .2 microns"
Replace Figure 1 with Figure 1R
Delete Figure 2
Replace description in STEP
4 with "STEP 4: Determine
percent of suspended solids
removed from Particle Size
Distribution Curve.
The estimated waste clay
particle size distribution is
shown in Figure 1. This is
based on the average distri-
bution of particle sizes in
slime samples from fifteen
Florida phosphate mines (Lamont,
et al., 1975).
The percent of suspended solids
entrapped in the reservoir was
estimated by first entering
the abscissa of the distribution
curve with logjg 2.2 microns
66
-------
\
^—
i
i :
i
!
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j
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i
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90
!
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;
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70
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i
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;
2s'
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i.
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i £
: £
ti
n
ft
£
4
10
-------
Page Paragraph & Line Correct ion
APPENDIX F (con't) and reading the percent finer
by weight on the ordinate.
Then
Percent of TSS entrapped
= 100 - (percent finer by weight)
100 - 58
= 42 percent"
Add "STEP 5: Compute suspended
APPENDIX F Page solids concentration at neat-
ment plant intake structure.
Tssintake = <°-»2><730 mg/1)
= 425 mg/1"
3.8 DESCRIPTION OF THE PROPOSED ACTIVITY RESOURCE DOCUMENT
paRe Paragraph & Line Correction
5 Table of Contents Change "Waste Peeble" to "Waste
1 Pebble". Change "Peeble
Product" to "Pebble Product"
4
3 6 Change "recovers" to "recovery"
9 Seventh Line Change "form" to "from"
3.9 AIR QUALITY RESOURCE DOCUMENT
Page Paragraph & Line Correct ion
70
71
7'i
3 2 Change "4.7 micrograms" to "less
than 4.7 micrograms"
Figure 6.1-4 Replace with Figure 6.1-4R.
Revised figure includes proposed
source contributions at points
where influence from external
interactive sources are expected
to be greatest.
2 4 Change "of" to "in"
76 2 5 Change "next highest was
produced" to "next highest,
61.3 micrograms per cubic meter,
was produced"
67
-------
I I
8
<*>
R
3056 i
•3054
.3052
¦3050
3048
3046
3044
INTERACT
+
KEENTOWN
.< 4.7 yg/mJ +
^ MA*- P0INT " 12-8
"T > V MAX. PPTY. BOUNDARY
8.1 yg/m3
TO HYAKKA HEAD
h_Q *
"INTERACTIVE fWX.
ppty: BOUNDARY
3.2 yg/m3
¦
FIGURE 6.1 - 4R
SHORT TERM (24-HOUR) EFFECTS OF PROPOSED SOURCE PARTICULATE EMISSIONS
71
-------
Page Paragraph & Line
APPENDIX A Page 1
APPENDIX A
APPENDIX D
Page 5
Cor rect ion
Page 1 was omitted. Insert
page 1
Page 5 was omitted. Insert
page 5
Insert AQDM OUTPUT (D-2 through
D-20) immediately following
APPENDIX D TSP MODELING DATA.
APPENDIX E
APPENDIX E
Substitute E-2 for page
immediately following APPENDIX E
SO2 & NOx MODELING DATA.
Substitute E-9, E-10 and E-ll
for last three pages of APPENDIX E.
3.10
Page
19
19
22
25
26
26
32
48
57
ALTERNATIVES EVALUATION RESOURCE DOCUMENT
Paragraph & Line
2 S
4 9
Seventeenth Line
Sixth Line
1 3
Cor rect ion
Change "effect" to "affect"
Change "dissication" to
"des iccat ion"
Change "distrubances" to
"d isturbances"
Change "recover" to "recovery"
Change "insoluable" to
"insoluble"
1 S Change "slimed" to "slimes"
7 5 Delete "higher"
Table 11-A Third Column Change "19.000" to "19,000"
Item 1) 2 Change "condesation" to
"condensat ion"
68
-------
Scale in Miles
PRIMARY SITE TSP, ,S02,F"
SECONDARY SITE F;*
-------
SEASONAL WIND ROSES FOR TAMPA, 1964-1969
-5-
-------
AQDM OUTPUT
D-2
-------
BASELINE (1977) ANNUAL PROJECTIONS
-------
2!i
i
0.47 i
.3.322T
J3
:i:
_5.»* s
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0.57 X
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0022.
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0.61
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215
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I 237
I
I 218
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0.49 X
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0.49 i
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0.61 X
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0.0
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-------
POST CONSTRUCTION (1982) AND
INCREMENT CONSUMING SOURCE PROJECTIONS
D-5
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SACC 3UETTE MINE 1982 PROJECTIONS 1969-1973 STAR ME.T OATA (2)
,.r; - nJ . J# f
1
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3ATA 1
S- *
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1
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SACC Ju£TTE 1SS2 »RCJ£C7tONS 1969-1973 STAR iET OATA
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annual particulates
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SACC OJETTe 1INE 19S2 PROJECTIONS 1969-19T3 STAR MET OATA
SCURCS COMTaiBUTtCNS TC FIVE SELECTED RECEPTCRS
ANNUAL PARTICULATES
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r
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SACC 3UETTE «I*E 1982 PROJECTIONS 1969-1973 STAR NET DATA
.iOtMCE .CONTRIBUTIONS. TO FiyE_JEL£CTE0 RECEPTCRS
ANNUAL PARTICULATES
MICROGRAMS
PER CUBIC METER
Erwr"
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1 261
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1 263
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1 265
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1 268
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AFV« 250. 260. 273. 260. 250. 250. 250. 250. 250. 260. 260. 270. 310. 300. 290. 300. 300. 270. 250. 270. 270. 260. 280. 280.
AFVRb 250. 264. 26S. 258. 254. 24E. 254. 246. 254. 256. 282. 274. 311. 303. 288. 298. 298. 271. 252. 274. 269. 263. 282. 276.
1637.
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3.338860E-05 31 0.50
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289. 238. 78d. 287. 2e5. 285. 285. 286. 290. 293. 295. 297. 299. 299. 299. 295. 294. 294. 293. 294. 294. 294. 293. 293.
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18511. 1849. 1841.
J4?3_._1751, 1.751.
10 2. 102. 102.
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4. 0 SUPPLEMENTAL ANALYSES
4.1 ADDITIONAL RADIOLOGICAL DATA
Int roduct ion
Subsequent to publishing of the Draft Environmental Impact
Statement in October 1979, additional radiological data regarding
*
Estech's Duette Mine site have been developed. By an Agreement
entered into by Manatee County, State of Florida Department of
Conmunity Affairs, Sarasota County, and Estech General Chemicals
Corporation, a data collection program was conducted to provide
an expanded radiological data base for the proposed project site.
Purpose
The purpose of this evaluation is to determine if the findings
and conclusions presented in the Draft Environmental Impact
Statement (DEIS) and its attendant Radiological Environment
Resource Document for Estech General Chemicals Corporation have
been altered or modified as a result of supplemental radiological
data unavailable at the time of the DEIS preparation. A
comparison of the DEIS data base used to characterize the
radiological profile of the mine site with the supplemental data
is outlined herein.
Scope of Additional Studies
Twenty-seven cores were drilled on Estech's Duette Mine site
at locations intended to ensure that the previous mineable matrix
sections can be used to delineate the matrix composite zone in
each new hole. The matrix was composited and core washed for
* Agreement of the Parties, State of Florida Division of
Administrative Hearings, Case No. 79-1994, Estech General
Chemicals Corporation, formerly Swift Agricultural Chemicals
Corporation, Petitioner vs. Manatee County, a political sub-
division of the State of Florida, et al., Respondent, March
1980.
69
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twenty-four of the drill holes to obtain the -150 mesh fraction
(clay).
These fractions were analyzed for percent dry weight and
radium-226 content. Three matrix composites were processed for
four fractions; 1) -150 mesh (clay), 2) sand tailings, 3) pebble
and 4) concentrate. Each of these fractions was analyzed for
determination of percent by weight, percent BPL and radium-226.
Sixty-six samples (twenty-four each of matrix and clay fractions
plus three each of matrix, clay, sand, waste pebble, pebble
product and concentrate fractions) were analyzed for concen-
trations of uranium, radium, thorium and potassium. The analysis
results are presented in a report entitled "Analysis of Estech
Core Samples for Natural Radioactive Content"*.
Compar i son
A comparison of the DEIS data with the supplemental data is
presented below:
DEIS Additional Radiological data
1) Matrix reported as 8.6
pCi/g of Ra-226
2) Clay fraction of the martix
reported as k.2 pCi/g Ra-226
3) Pebble fraction of the matrix
reported as 29 pCi/g Ra-226
4) Concentrate fraction of the
matrix reported as 24 pCi/g
Ra-226
5) Sand tailings fraction re-
ported as 1 pCi/g Ra-226
6) Matrix reported as being
in secular equilibrium
(Ra-226 approx. = U-238,
pCi basis)
Twenty-seven matrix samples
yielded Ra-226 at 7.6 ± 2.5
PCi/g
Twenty-seven clay fraction
samples yielded Ra-226 at 6.6
± 3.4 pCi/g
Pebble fraction samples yielded
Ra-226 at 30 ± 1 pCi/g
Concentrate fraction samples
yielded Ra-226 at 21 ± 3 pCi/g
Sand tailing samples yielded
Ra-226 at 0.5 ± 0.04 pCi/g
Twenty-seven samples yielded
a matrix U/Ra ratio of
1.18 ± 0.33
* Cline, James E., and Hollcraft, Joanne. "Analysis of Estech
Core Samples for Natural Radioactive Content," Science
Applications, Inc., Rockville, Maryland. May, 1980.
70
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7) Beneficiation process re-
ported as not producing
significant fractionation
of U-238 or Ra-226 from
equi1ibr ium
8) Sand and clay mix (2,5:1)
used for reclamation plan
reported to yield a final
concentration of 1.9 pCi/g
Ra-226
Twenty-seven clay samples
yielded a U/Ra ratio of
1.29 ± 0.34
Pebble samples yielded a U/Ra
rat io of 1.07 ± 0.06
Concentrate samples yielded
a U/Ra ratio of 1.20 ± 0.26
Tailings samples yielded a
U/Ra ratio of 1.05 + 1.20
Sand and clay samples calculate
a 2.5:1 mix with a 2.2 pCi/g
concentration of Ra-226
9) Very limited data for U/Th
ratios indicated a value of^
between 30 and 180. Analysis
to justify that Ra-226 (a Th
daughter) would not be a po-
tential hazard assumed a U/Th
ratio of between one and two
orders of magnitude (10 to 100)
Forty-two samples with both
U and Th data yielded a U/Th
ratio of 36 ± k7. A few very
high values produced the high
standard deviation.
Analysis of Statistical Difference Between Two Means
As a further analysis of data compatibility, a statistical
comparison was performed using the Student's statistical test.
The ana 1ysis-of-variance F test can also be used; however it
is more general and is most often used to compare more than two
means. Whenever there are only two means involved, as is the
case here, the Student's statistical test will result in the
identical conclusion.
Given a group of independent random samples of "n" measurements
drawn from two populations, each of which possesses an observed
mean, "y" and an observed standard deviation, "a", make
inferences concerning the differences between the true means
"y", of the two populations. Let the subscript "1" represent
the original DRI data and the subscript "2" represent the SAI
data. Assume that both populations have a normal probability
distribution. Thus, one can further assume that the variability
71
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of the measurements in the two populations is the same and can
be measured bv a common variance. The best estimator of that
common variance is the pooled estimator "S":
S
(nj - l)a2j + (n2 - l)cr22
d. f
where d. f. is equal to the degrees of freedom and for the
problem at hand is equal to (nj + n2 - 2).
For small sample tests of the hypothesis HQ: ^ - 2 = DQ,
where Dq is the hypothesized difference between the means, it
would seem reasonable to use the test statistic:
and the logical value for Dq to test is zero. This test
statistic will possess a Student's distribution when the stated
assumptions are satisfied. In other words, the null hypothesis,
Hq: (v^ - y2) = Dq = 0, the hypothesis will be rejected when
t is greater than taf2 for the aPProPriate degree of freedom.
This analysis will use a = 0.05 or a 95% confidence level. See
Table ^.1-A for the critical values of *a/2' Enter at an
appropriate d. f. and consider the column entitled to tQ 025*
The calculations and results are shown on Table 4.1-B. The data
have been arranged in order of best agreement with the hypothesis
(pebble data) to that with the least agreement with the
hypothesis (tailings data). The tailings data will cause a
rejection of the hypothesis if the sigma of the data is used;
however the counting error is the larger sigma in this case only
and therefore controls. It therefore can be concluded, using
the correct statistical jargon, that all data sets cannot be
shown to not have identical true means.
(yx - *2' - Do
t
72
-------
Table 4.1-A Critical Values of t
d.f.
t.100
t.050
t.025
o
o
•
+->
t.005
d.f.
1
3.078
6.314
12.706
31.821
63.657
1
2
1.886
2.920
4.303
6.965
9.925
2
3
1.638
2.353
3.182
4.541
5.841
3
4
1.533
2.132
2.776
3.747
4.604
4
5
1.476
2.015
2.571
3.365
4.032
5
6
1.440
1.943
2.447
3.143
3.707
6
7
1.415
1.895
2.365
2.998
3.499
7
8
1.397
1.860
2.306
2.896
3.355
8
9
1.383
1.833
2.262
2.821
3.250
9
10
1.372
1.812
2.228
2.764
3.169
10
11
1.363
1.796
2.201
2.718
3.106
11
12
1.356
1.782
2.179
2.681
3.055
12
13
1.350
1.771
2.160
2.650
3.012
13
14
1.345
1.761
2.145
2.624
2.977
14
15
1.341
1.753
2.131
2.602
2.947
15
16
1.337
1.746
2.120
2.583
2.921
16
17
1.333
1.740
2.110
2.567
2.898
17
18
1.330
1.734
2.101
2.552
2.878
18
19
1.328
1.729
2.093
2.539
2.861
1 9!
20
1.325
1.725
2.086
2.528
2.845
20
21
1.323
1.721
2.080
2.518
2.831
21
22
1.321
1.717
2.074
2.508
2.819
22
23
1.319
1.714
2.069
2.500
2.807
23
24
1.318
1.711
2.064
2.492
2.797
24
25
1.316
1.708
2.060
2.485
2.787
25
26
1.315
1.706
2.056
2.479
2.779
26
27
1.314
1.703
2.052
2.473
2.771
27
28
1.313
1.701
2.048
2.467
2.763
28
29
1.311
1.699
2.045
2.462
2.756
29
inf.
1.282
1.645
1.960
2.326
2.576
inf.
From: "Table of Percentage Points of the t-Distribution." Computed
by Maxine Merrington, Biometrika, Vol. 32 0941),p. 300. Reproduced by
permission of Professor E. S. Pearson.
73
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Table 4.1-B Statistical Calculations and Results
Item y-i y2 a-, a2 n] n2 d.f. S t tQ Q25 test
Pebble
29
30
2.5
1.0
4
3
5
2.03
0.65
2.57
Ok
Concentrate
24
21
3.0
3.0
4
3
5
3.00
1.31
2.57
0k
Matrix
8.6
7.6
2.6
2.5
11
27
36
2.53
1.10
1.96
0k
Clay
4.2
6.6
1.1
3.4
4
27
29
3.24
1.38
1.96
0k
Equilibrium
1.06
1.18
.23
0.33
20
27
45
0.27
1.40
1.96
Ok
Tailings
1.0
0.5
0.3
0.28*
4
3
5
0.29
2.26
2.56
Ok
~Counting error larger than error on the mean
74
-------
Cone 1 us i ons
The addition of twenty-seven cores and three complete matrix
fractionations did not provide radiological data which would
alter the findings of the Draft EIS regarding the radiological
profile of the site. A re-analysis of radiological impacts based
on the additional data is not deemed necessary for the Final
EIS.
4.2 ELEVATION OF SAND-CLAY DISPOSAL HEIGHT
Proposed Change
In the original proposed waste disposal plan, the crest height
of the temporary dikes surrounding the sand-clay mix areas was
planned to be 14 feet, with a maximum thickened clay-sand level
of 9 feet. This design was based on two critical factors:
o The proportion of clay in the matrix was taken as
18 percent, based on available prospect data.
o The clay was assumed to reach a solids content of 30
percent after two years, based on limited laboratory
settling tests.
More recent investigations have shown that both of these factors
were unconservative. First, a re-analysis of the sample data
has shown that the proportion of clay in the matrix is actually
24 percent rather than IS percent. As a result, the mass of
waste clay to be disposed is actually one-third more than
originally had been thought.
Second, a more sophisticated technique for waste disposal
analysis has been employed . This analysis represents the state-
of-the-art for analyzing and predicting the consolidation of
phosphate waste clays. Based on the best available geotechnical
data for the Duette Mine site, this analysis evaluated the mass
of dry clay (mixed with sand) that could be contained in a
disposal area.
Bronwel 1, L. G., and Carrier, W. D., III. "Consolidation
of Fine-Grained Mining Wastes". Proceedings of the Sixth Pan-
american Conference on Soil Mechanics and Foundation Engineer inc.
Lima, Peru. 1979.
75
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It was found that the clay will reach a solids content of only
about 24 percent after two years in the mine cuts, rather than
30 percent.
Thus, the combination of an increase in the mass of the waste
clay and a decrease in the anticipated solids content at the
end of filling has resulted in an increase in the volume of clay
of more than 50 percent.
Three alternatives were considered in evaluating the proposed
increase in sand-clay storage volume: 1) no action; 2) extension
of time period necessary for consolidation and final grading;
and 3) Estech's proposed increase in the height of the sand-clay
disposal areas.
The no action alternative would effectively preclude the mining
operation due to the unavailability of storage area to accomodate
the projected 50% increase in clay volume. The disposal and
storage of mining waste on the applicant's property is an
inherent responsibility of the operation. The effects of the
no-mining alternative have been presented in the Alternatives
Evaluation section and may be applicable to the no-action
alternative of the sand-clay storage question.
In evaluating the remaining alternatives, the primary goal was
to select the plan that achieved the final reclamation at the
approximate original level with the least significant
environmental perturbation. This goal can only be realized by
either extending the time period necessary for consolidation
and final grading or increasing the height of the sand-clay
storage areas.
If the sand-clay disposal areas remain as originally proposed,
time required for consolidation and reclamation of the sand-clay
mixture estimated to be is extended by approximately 5-8
years. This additional required time would significantly alter
the timely reclamation schedule and mining plans as presented
for regulatory review in the Manatee County Master Mining Plan,
State of Florida Development of Regional Impact Application and
76
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the Draft Environmental Impact Statement. More importantly,
several elements of the environmental considerations may be
adversely affected by the extension of the reclamation schedule.
The elevation of the land surface by the sand-clay mixture for
additional years will result in modified topographic contours
and attendant watershed changes for a period of time, which could
conceivably influence stream and river flow volumes. The
extended modification of flow volumes may change the water
quantities available to habitats dependent upon specific hydric
condit ions.
A redefinition of hydric periods within areas dependent on xeric
conditions will result in the eventual demise of the vegetation
as well as a modification of soil moisture required by various
species of upland wildlife.
Perhaps most significantly would be the necessity of greatly
increasing the clay settling area. In order to provide an area
for the clay waste generated during the time required for the
sand-clay mix to subside to a level which would allow for ad-
ditional input, additional clay settling facilities would have
to be constructed. This necessity alone appears sufficient
reason for excluding this alternative from further consider-
ation. Present EPA policy (Areawide EIS) as well as public
opinion promote the elimination of conventional aboveground clay
disposal areas.
The increased height will provide the additional storage volume
required to contain the predicted volume of waste clay, and will
also result in a higher ultimate solids content owing to higher
average compressive stresses.
In order to maintain the original reclamation time schedule,
Estech proposes to increase the height of sand-clay disposal
areas and the surrounding temporary dikes. Based on the computer
analyses described above, the crest height of the temporary dikes
for the first ten years of mine life is now planned to be 23
feet, with a maximum filling level of IS feet, so as to provide
77
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5 feet of free board. The ^80 acre initial settling area is
to remain as originally proposed with a dike height of approxi-
mately 30 feet and fill to approximately 25 feet above grade.
It should be noted that these analyses are based on the best
available data. However, geotechnical data will continue to
be obtained even after mining begins, and the analyses will be
updated and revised accordingly. Thus, it may be necessary to
raise (or lower) the crest heights of the temporary dikes as
mining proceeds. However, it is not expected that the actual
crest heights will differ substantially from 23 feet above
original ground.
Impact Analysis
In assessing the impacts of the proposed change, emphasis was
directed to those elements of the modification which may affect
impacts and/or conclusions presented in the Draft EIS. The
primary focus of this analysis is to identify the resulting
Impact changes and the alternatives which may affect the decision-
making process of NPDES permit application review.
Possible impacts of the proposed revisions were considered for
various geotechnical topics addressed in the Draft EIS. Specific
impacts were identified in the following areas:
o Reclamation Schedule
o Water Requirements
o Final Topography
o Permeability of Sand-Clay Mix
o Groundwater
o Reclaimed Land Radiological Characteristics
o Energy Requirements
o Reclaimed Land Use Potential
o Reclaimed Soil Types
The nature and magnitude of the identified impacts is discussed
for each area in the following sections.
Reclamation Schedule - The allotment of five years to reclaim
sand-clay disposal areas is not altered in the revised plan.
However, the sequence of filling, consolidation and final grading
78
-------
and revegetation have been revised. In the original plan, two
years were allotted for filling of an area, two years for
consolidation and one year for final grading and revegetation.
The clays were projected to be at approximately 25 percent solids
at the end of filling and at approximately 30 percent solids
at the end of the consolidation period. The revised plan calls
for stage filling of sand-clay disposal areas over a three-year
period with one fill per year. The clays are projected to be
at approximately 25 percent solids at the end of the third year.
One year is allotted for consolidation of the landfill at the
end of which the clays are projected to reach approximately 30
percent solids. The fifth year is allotted for final grading
and revegetation. Therefore, both the original and revised plans
project the clays in the mixture to be at approximately 30
percent solids at the end of the fourth year. The two plans
differ in that the original plan allowed two years for the clays
to consolidate from 25 percent to 30 percent solids, whereas
the revised plan allows one year.
There are no field scale demonstrations upon which to base
predictions of consolidation rates for sand-clay landfills.
Therefore, the question of conso1idation rates in sand-clay
landfills is somewhat conjectural. However, the consolidation
rates projected in the revised plan are within the limits defined
by laboratory studies and mathematical modeling.
Water Requirements - The water balance prepared for the original
plan provided for average groundwater and surface water with-
drawals of 9,000 gallons per minute (GPM). These withdrawals,
along with the water entrained in the ore, make up for the losses
incurred in the mine water recirculation system. The primary
loss in the recirculation system is 7,977 GPM lost due to
entrainment to waste clays. The quantity of water entrained
per ton of waste clays is not constant; it depends on the water
release that occurs as the clays consolidate. Therefore, clay
entrainment losses are not necessarily directly proportional
to the amount of waste clays generated.
79
-------
The clay entrainment losses of 7,977 GPM calculated in the water
balance are based on achieving water recovery as the clays
consolidate to 18 percent solids. This water recovery efficiency
is typical of many operating mines. Additional water is released
as the clays consolidate beyond 18 percent solids. However,
the rate of water release and the amount of released water that
can be recovered is difficult to determine since some of the
released water is lost to evaporation, runoff and seepage. The
sand-clay mix waste disposal technique proposed by Estech is
projected to enhance water recovery efficiency and, therefore,
reduce losses due to entrainment in clays.
The increase in proportion of clay in the matrix (from 18 to
25 percent) will result in an increase in water loss to clay
entrainment. This will make more critical the effective recovery
of water as the clays consolidate. In order for Estech to hold
their clay entrainment losses to a level such that their ground-
water and surface water withdrawals do not exceed the permitted
9,000 GPM, they must achieve effective water recovery as the
clays consolidate to approximately 22 percent solids. Although
there has not been sufficient field demonstration to assure that
this recovery efficiency can be achieved with the sand-clay mix
technique, such recovery is within the capabilities projected
for the system. If, however, water recovery is only achieved
up to 18 percent clay solids, it may be calculated that Estech
will require an additional 2,100 GPM above their permitted
groundwater and surface water withdrawals. The proposed in-
creased height of the sand-clay disposal areas with the attendant
increase in compressive stresses will enhance the water recovery
efficiency to a greater degree than the originally proposed
height.
Final Topography - The revised action proposed by Estech calls
for filling sand-clay disposal areas to an average height of
18 feet above ground level instead of 9 feet proposed in the
original plan. Both the original and revised plans project the
clays to be at approximately 25 percent solids at the end of
80
-------
the fill period. Both plans also call for reclamation to begin
at the end of the fourth year when the clays are at approximately
30 percent solids. Approximate subsidence predictions can be
made based on the volume of water that is released during
consolidation. Based on these calculations, the nine-foot fill
level proposed in the original plan would subside to 2.4 feet
above natural ground level by the time reclamation begins. Due
to the approximations inherent in the calculation of subsidence
rates, this level was referred to as "approximately five feet"
above ground level in the Draft EIS. For the revised plan, the
approximate calculations indicate that the proposed 18 foot level
will subside to 7.4 feet above ground level at the beginning
of reclamation.
After reclamation is complete, subsidence is likely to continue
over an extended period of time at an unknown rate. In the
original plan, long-term subsidence from 30 percent to 35 percent
clay solids may be calculated to bring the level to 2.1 feet
below ground level. Again, due to the approximations inherent
in the calculations, this level was referred to as "near natural
grade" in the Draft EIS. For the revised plan, it may be
calculated that subsidence to 35 percent clay solids will bring
the sand-clay level to 0.2 feet above existing ground level.
Over an extremely long period of time, subsidence may continue
as the clays consolidate beyond 35 percent solids. However,
predictions beyond this point are strictly conjectural as there
are no empirical data to support them.
In summary, according to approximations used in subsidence
calculations, the revised plan will result in sand-clay levels
that are a few feet above those proposed in the original plan.
Long term subsidence to 35 percent clay solids is projected to
bring the sand-clay levels to essentially natural ground level.
Based on these results, the increased fill level for sand-clay
mix should have no impact on the formation of shallow depressions
near the outlet end of waste disposal areas. The formation of
81
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these depressions is based on differential subsidence within
the landfills which will not be altered by the proposed revision.
Permeability of Sand-Clay Mix - Since the percent clay solids
in the sand-clay mix is the same for both the original and
revised plans, the permeability coefficient for the mix has not
changed. Published coefficients of permeability for phosphate
clays indicate that the mixture should have coefficients of
permeability of about 8 X 10"7 CM/Sec. at 30 percent solids and
about 3 X 10~7 CM/Sec. at 35 percent solids*.
Groundwater - The increase of sand-clay fill heights is not
expected to cause any changes in the quality of the water leaking
from the disposal area from those projected in the Draft EIS
due to the fact that the proposed disposal practices will not
alter the sand-clay mix ratio of approximately 2.5 to 1.
Likewise, the permeability of the sand-clay mix is not expected
to change as a result of the proposed fill height increase.
Changes anticipated are 1) thickness of the waste material and
2) the head drive moving water through them. It is believed
that these changes will tend to counterbalance each other
resulting in a slight increase in the leakage over what was
estimated in the Draft EIS. This change is expected to be
ins ign i f icant.
Should Estech be unable to attain effective water recovery as
the clays consolidate to 22 percent, it has been calculated that
an additional 2,100 GPM wi11 be required above the permitted
groundwater and surface water withdrawals. In order to obtain
\
additional quantities of water for the project, Estech will be
required to submit factual information to the Southwest Florida
Water Management District delineating the sources and uses of
this additional water and the impacts created as a result of
them. The district board will then act on modifying the existing
Consumptive Use Permit. It would be speculative to attempt to
* Keshion, Berg, C. C. Ladd and R. E. Olson. "Sedimentation
Consolidation Behavior of Phosphatic Clays," Geotechnical
Practice for Disposal of Solid Waste MaterialsT A.S.C.E.
Specialty Conference, June 1977.
82
-------
determine the need for additional water qualities until
operational data is available specifying the water recovery
efficiency at 22 percent consolidation.
Reclaimed Land Radiological Characteristics - According to the
data presented in the Radiological Environment Resource Document
of the Draft EIS, overburden from the site has an average radium
-226 level of 1.5 pCi/g while the sand-clay mix has an average
radium-226 level of 1.9 pCi/g. Therefore, the greater extent
of overburden capping which results from the revised plan will
serve to reduce the radium-226 content of reclaimed surface
soils. The radium-226 levels for both overburden and sand-clay
mix are relatively low and this impact is relatively minor.
Energy Requirements - The $0.30 per ton additional pumping cost
calculated for the mine and beneficiation areas equates to
approximately 7.5 kilowatt-hours additional electrical energy
use requirement per ton of product. In addition, approximately
20 percent of the additional earthmoving cost may be attributed
to increased fuel consumption. This equates to approximately
$0.06 per ton additional fuel cost or, on an electrical energy
equivalent basis, to about 1.5 kilowatt-hours additional energy
cost in earthmoving. Therefore, Estech's revised plan will
require a total of approximately 9.0 additional ki1 owatt-hours
per ton of product over that required in the original plan.
Reclaimed Land Use Potential - Most of the land to be reclaimed
for agricultural uses is to be used for improved pasture.
Overburden has been shown to be an acceptable soil for this use.
Therefore, the revised plan will have no impact on the planned
agricultural uses of reclaimed land.
Areas to be reclaimed for environmental uses include the marshes
created in sand-clay depressions and forested drainage swales
that interconnect the reclaimed sand-clay landfills. As
previously stated, the revised plan should have no impact on
the sand-clay depressions. Overburden soils have been shown
83
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to be an acceptable medium for tree growth. Therefore, there
Should be no impact on the plans to reforest the drainage swales.
Reclaimed Soil Types - Due to the projected agronomic superiority
of sand-clay soils, the original plan provided for no capping
of sand-clay soils with overburden beyond that which occurs in
grading the dikes to approved slopes. Some capping inevitably
occurs when the dikes are graded to approved slopes. Since
the 23 foot dikes contain more material than the originally
proposed 14 foot dikes, the revised plan will result in greater
coverage of sand-clay soils with overburden.
In the original plan, the maximum extent of overburden capping
can be approximated by assuming-that all sand-clay dikes are
exterior dikes and that the dike material above a 7:1 slope must
be graded over the sand-clay landfill. Based on these
assumptions, the original plan would result in the capping of
approximately 21 percent of all sand-clay soils with over-
burden ranging from a few inches to five feet in depth. Using
these same assumptions, the revised plan would result in the
capping of approximately 37 percent of sand-clay soils with
overburden ranging from a few inches to'seven feet in depth.
Sand-clay soils are projected to be superior to overburden soils
in terms of inherent fertility, plant nutrient retention
properties and moisture retention properties. On the other hand,
overburden soils should have better tillage properties than the
sand-clay soils. In addition, overburden soils are agronomically
equal or superior to native soils on the site due to their higher
content of clay and available plant nutrients. Therefore, while
capping of sand-clay soils is not ideal from the agronomic stand-
point, the overburden soils will still be an acceptable medium
for plant growth.
Cone 1 us i on
The proposed modification does not significantly alter 1) the
ultimate consolidated sand-clay fill elevation, 2) subsidence
84
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rate, 3) soil characteristics (permeability, leakance, etc.),
4) water balance and 5) marsh development. These elements have
been identified as the controlling factors that would produce
any effects different from those described in the Draft EIS.
Therefore, the elevation of the sand-clay fill height to 18 feet
will not constitute major changes in the impact analysis and
conclusions presented in the Draft EIS.
85
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5.0 PUBLIC PARTICIPATION
The Draft Environmental Impact Statement (DEIS) was published
in October 1979 and made available to the Council on Environ-
mental Quality and the public. A public notice appeared in the
local newspapers. The Federal Register (Volume kb, No. 202)
dated October 17, 1979 announced the availability of the DEIS
and the proposed issuance of an NPDES Permit. The DEIS was
provided to numerous Federal, State and local agencies as well
as concerned individuals, interest groups and public officials.
A notice of the public hearing was promulgated October 5, 1979.
The public hearing was held in Bradenton, Florida, November 28,
1979 and was attended by 82 participants. In addition to the
public input afforded by the hearing (transcript provided
herein), many letters were received and are included in this
Final EIS.
The designations in the margins of the letters (W-l thru W-130)
identify those specific comments for which responses have been
developed. These responses follow the letters. In a similar
manner, the designations in the margins of the hearing transcript
(T-l thru T-65) identify those comments which have been responded
to. The vast majority of the transcript comments were very
similar, and in many cases identical to many of the written
comments. Consequently, most of the transcript responses refer
directly to responses previously presented.
86
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5.1 WRITTEN COMMENTS AND RESPONSES TO WRITTEN OOMWENTS
87
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COUNTY OF SARASOTA
FLORIDA
BOARD OF (COMMISSIONERS
ANDREW SANDEGREN • DISTRICT t
BEVERLY CLAY • DISTRICT 2
JAMES D. NEVILLE * DISTRICT 3
JOHN M. SABA. JR. * DISTRICT 4
LARRY RHODES * DISTRICT 3
ED MARONEY ' COUNTY ADMINISTRATOR
P.O. BOX 8
SARASOTA. FLA. 33579
PHONE: 813/365-1000
December 11, 1979
Mr. John E. Hagan, III
Chief EIS Branch
EPA Region IV
345 Courtland Street NE
Atlanta, Ga 30308
Re: Comments on the Draft EIS for the Estech General Chem-
icals Corp. Proposed Duette Mine, Manatee County, Florida
Dear Mr. Hagan:
On behalf of the Board of County Commissioners of Sarasota County,
please find enclosed additional comments prepared by Mr. Russell
P. Klier concerning the draft site-specific Environmental Impact
Statement on the proposed Estech General Chemicals Corporation
phosphate mine in Manatee County.
These additional comments focus on deficiences in the draft EIS
concerning the proposed rock drying facility, and show that the
proposed rock dryer would use more than twice as much energy to ^
dry the phosphate rock at Estech's mine than would be expended i
by shipping the wet rock as far as the Far East. Permitting a $
rock dryer, which is fired by fuel oil, at the Estech mine site
would therefore waste tremendous amounts of this nation's oil
supplies in addition to creating a new source of air pollution.
Accordingly, as with other aspects of the draft EIS previously .
commented upon by the County*, the economic justification for i
the rock dryer is inconsistent with the recommendations of the £
EPA Areawide Environmental Impact Statement. The primary justi-
fication in the draft EIS for permitting a rock dryer in Manatee
County is that over the 20 year life of the mine it would deprive
*A copy of the County's previous comments is enclosed for
reference.
88
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Mr. John E. Hagan, II
Chief EIS Branch
Page Two
December 11, 1979
Estech of some potential customers who still require dry rock.
The EIS alternatives assessment document, however, states on
page 50:
As obsolete smaller phosphoric acid plants
are replaced with new facilities, it is
certain that more wet rock processing will
be incorporated and a gradual shift to this
more desirable system will occur.
The draft EIS prepared by Conservation Consultants, Inc., seems
more concerned with preserving the widest possible market for
Estech and allowing it to cater to the most obsolete and ineffi-
cient chemical plants, rather than minimizing environmental
damage to our area and seeking ways to bring the Estech project
into conformity with the recommendations of the EPA Areawide
Environmental Impact Statement.
Based upon the enclosed comments prepared by the County's pro-
fessional staff, the Board of County Commissioners of Sarasota
County believes that the draft EIS violates both the letter and
the spirit of the National Environmental Policy Act and that,
accordingly, it would be improper for the EPA to issue any per-
mits to Estech based upon the draft EIS document.
Revision of the draft EIS, which is clearly necessary before the
issuance of any permit by EPA, should await the outcome of pend-
ing appeals of the decision of the Board of County Commissioners
of Manatee County to deny land use approval for the Estech project.
The project, even if ultimately approved, may be substantially
altered, and the EIS should then assess the project as it would
actually exist. If the land use decision by Manatee County is
upheld, further effort to revise the draft EIS would, of course,
be unnecessary.
Your attention to# and action upon, the enclosed comments will
be appreciated by the Board of County Commissioners and the
people of Sarasota County.
Very truly yours,
BOARD OP COUNTY COMMISSIONERS
OP SARASOTA COUNTY, FLORIDA
LRs jm
Enclosures
89
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A Report Prepared for the Sarasota County
BOARD OF COUNTY COMMISSIONERS
on
ESTECH GENERAL CHEMICALS CORPORATION'S
PROPOSED ROCK DRYING FACILITY
90
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The Environmental Impact Statement prepared for the Estech
General Chemicals Corporation proposed Duette Mine, high-
lights the fact that the use of a rock dryer at this facility
will use more energy and also cause more environmental damage
than the alternative of shipping wet rock. In other words,
it would worsen our local environment and worsen our national
energy picture to allow a rock dryer at this facility.
The Areawide Environmental Impact Statement (AEIS) that was
prepared by the federal government to protect our environment
from the cumulative effect of the phosphate industry specifi-
cally recommended: "eliminate the rock-drying process at
beneficiation plants and transport wet (6 to 20 percent moisture)
rock to chemical plants." This phosphate mine is proposing to
construct rock drying facilities at the mine site in direct
conflict with the AEIS recommendation. The AEIS did allow for
some exceptions, as it states on page 2.1: "A possible exception
on a case-by-case basis could be made for rock to be shipped
outside of Florida for chemical processing; if the energy for
transporting the moisture were greater than the energy saved
by eliminating drying, drying at the beneficiation plant would
be considered if air quality (including radiation) could be
adequately protected." The reason that Conservation Consultants
give for justifying the use of a rock dryer can be found in the
Alternatives Evaluation document on page 49: "Ship Wet Rock -
shipping wet rock to all customers may be technically feasible,
but Swift would lose customers who cannot use wet rock." This
EIS justifies a rock dryer not because of the energy considera-
tion as required in the AEIS, but because of the marketing
situat ion.
This Environmental Impact Statement Alternatives Evaluation
actually points out the conflicts between the AEIS and this
facility; for instance, on page 52: "more energy in the form of
fuel oil is consumed to dry the rock than is consumed to ship the
additional water in the wet rock assuming the rock will not be
dried at the final destination." This is further highlighted on
page 54 where figure 12-2 (attached) shows that the energy con-
sumed to ship the water in the rock to the Far East (10,000 miles)
would be only 150,000 BTU per ton, while the energy consumed to
dry the rock would be 425,000 BTU per ton. In other words, it
would take more than twice as much energy to dry the rock than to
ship it to the far side of the earth. This document also points
out that all of the energy used to dry rock is "domestic energy" •
thereby worsening our energy problems. On page 25 the environ-
mental aspects of the different scenarios of transporting wet
rock or dry rock are presented. The scenario of shipping wet
rock is listed as the most environmentally sound, whereas the
scenario of drying rock at the mine site and shipping it dry is
the third worst of the four scenarios presented.
91
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2
The alternatives assessment document on the top of page 5*0
discusses the fact that "As obsolete smaller phosphoric acid
plants are replaced with new facilities, it is certain that
more wet rock processing will be incorporated and a gradual
shift to this more desirable system will occur."
I suggest that since this project will span more than twenty
years and more wet processing will "occur" in the future, the
EPA should deny the use of a rock dryer at this facility and
require Estech to ship wet rock.
RPK:rkt
92
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-------
A Repott PKtpcjiiid tka Scuuuota County
BOARD OF COUNTY COMMISSIONERS
on
ESTECH'S (FORMERLY SWIFT'S) DRAFT
ENVIRONMENTAL IMPACT STATEMENT - PROPOSED
DUETTE PHOSPHATE MINE, BENEFICIATION
PLANT AND ROCK DRYER
PH.zpM.ext by
JEFFREY L. LINCER, Pk.V.
and
RUSSELL P. KLIER, M.S.
NOVEMBER 27, 1979
-------
A Rzpofut VruLpaAzd &o?i the. SaAa&ota County
BOARD OF COUNTY COMMISSIONERS
on
ESTECH'S (FORMERLY SWIFT'S) DRAFT
ENVIRONMENTAL IMPACT STATEMENT - PROPOSED
DUETTE PHOSPHATE MINE, BENEFICIATION
PLANT AND ROCK DRYER
November 27, 1979
Russell P. Klier, M.S.
95
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Section
CONTENTS OF THIS REPORT
Page
Introduction
AIR POLLUTION
Fuel Oil to be Used in the Rock Dryers
Estimated Emission Rates from the Rock Drying Facility
Predicted Ambient Air Quality in Relationship to Recent Changes
Presentation of Air Quality Data in DEIS
Cumulative Impact
SOIL/ HYDROLOGY AND WATER QUALITY
Holistic Approach Necessary
Radical Changes in Water Quality
ABOVE-GROUND SLIME POND
Contrary to Areawide EIS
Contrary to Local Governments Desires
Slime Pond Dam Failure
Lack of Serious Discussion of Alternatives
WATER MANAGEMENT
A Matter of Relativity
Reduction of Available Potable Water
A Need to Reassess the Proposed Water Management Plan
WETLAND PROTECTION
Proposed Action
In Opposition to EPA's Areawide EIS Recommendations
Impact of Proposed Water Management
OTHER HABITAT LOST
What Would be Lost
Long-Term Impacts
In Opposition to Local Policy
RARE AND ENDANGERED SPECIES
Federal Recognition of the Values of Endangered Species
Rare and Endangered Species On Site
The Impact
In Opposition to the Intent of Policy at All Levels
Additional Endangered Species
Shouldering the Responsibility
RECLAMATION
Conclusions
Recommendat ions
Literature Cited
2
3
6
7
9
10
11
12
14
15
16
17
96
- DEIS Review, page 1
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INTRODUCTION
As indicated by EPA's notice of October 5, 1979* a Draft Environ-
mental Impact Statement for the Estech General Chemical (formerly the
Swift Agricultural Chemical) Duette Mine has been prepared pursuant to
Section 102(2)(c) of the National Environmental Policy Act (NEPA)
(P.L. 91-190) and applicable EPA Regulations at 40 CFR part 6.9. This
report is the result of a review of that Draft Environmental Impact
Statement (DEIS) and the resource documents associated with it.
- DEIS Rev^#f page 2 -
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AIR POLLUTION
Fuel Oil to be Used in the Rock Dryers. The ambient air quality
analysis is based on the presumption that the fuel oil to be fired in
the facility would contain "a maximum of 1.0% sulfur by weight" (page
20 of the Resource Document regarding Air Quality). We know from ex-
perience with the Florida Power and Light (FP&L) Manatee Plant that
the 1.0% sulfur oil is not available on a regular basis, in fact, the
federal government and the State of Florida have recently had to relax
sulfur regulations because FP&L could not obtain sufficient quantities
of 1.0% sulfur fuel oil. Currently, FP&L is allowed to burn 2.5%
sulfur oil. It is, therefore, unrealistic to plan on this facility
being able to burn 1.0% sulfur fuel oil. This is even further high-
lighted by the fact that we have historically received large quanti-
ties of low sulfur fuel oil from Iran, and now the Iranian supply has
been cut off. Clearly, the air quality analysis should be reevaluated
based upon a more realistic fuel oil of at least 2.5% sulfur oil.
Estimated Emission Rates from the Rock Drying Facility. Not only
was it estimated that low sulfur fuel oil would be fired in the faci-
lity, but it was also estimated that 96.5% of the resulting sulfur
dioxide would be removed in the wet scrubbing system (page 35 of the
Air Quality Resource Document). This 96.5% removal of sulfur dioxide
is extremely high and overly optimistic, was poorly documented in the
report, and is far in excess of what is considered "state of the art."
According to a recent EPA review of sulfur dioxide removal in utility
scrubbers in this country, 90% removal was the maximum that could be
achieved on a reliable basis (Devitt et al., 1977). Host, in fact, do
much more poorly. If this high removal estimate is to be used in cal-
culating the emission rates, then Estech should be able to document it
much better than it has.
If the 96.5% removal cannot be achieved, then the actual SO2 emis-
sions will be higher than that predicted through the modeling. The
same criticism can be applied to the NO2 and particulate removal in
the rock dryers, in that none of their removal efficiencies were well-
documented in this Draft EIS.
Page 10 of the Resource Document, regarding Air Quality, discusses
the methodology used to predict the sulfur dioxide concentrations af-
ter construction. It states that because the estimated sulfur dioxide
emission rate would not be very great, a detailed modeling analysis pf
the sulfur dioxide concentration would probably not be warranted. Be-
cause of the above two points, a more detailed "major source" analysis
of sulfur dioxide should be performed. Further (on page 77), the Re-
source Document for Air Quality indicates that the annual sulfur di-
oxide concentrations were computed by factoring the nitrogen oxide
- DEIS Revig^, page 3 -
-------
emission rates. This "shortcut" approach is not justified, considering
the potential sulfur dioxide emissions, and because of these addi-
tional sources, the sulfur dioxide analysis should be done indepen-
dently as a "major source.
Predicted Ambient Air Quality in Relationship to Recent Changes at
The Florida Power & Light Manatee Plant. Ambient air quality monitor-
ing was performed during the Spring of 1977 through the Summer of 1978
to identify the ambient air quality in the area for this DEIS. Future
air quality predictions (i.e., after startup of this mine) were ar-
rived at by computer modeling, based on emissions fcom this source and
other future sources within a "sphere of influence" (as defined by the
Environmental Protection Agency).
The FP&L Manatee Plant was subject to a 1.0% sulfur fuel regula-
tion during the time of ambient air monitoring for this project. How-
ever, because of a shortage of low sulfur oil, this plant was allowed
to burn higher sulfur fuel (2.5%) during June of 1979. This resulted
in an increase of 150% in the allowable sulfur dioxide (S02) emis-
sions. This increase was not included in the computer model run for
this analysis. In other words, the computer analysis took a baseline
that was measured before the standard was relaxed, and then it did not
input the increase in SO2 which the plant would emit.
The Federal PSD Guidelines establish a minimum "significant cri-
teria" of 1 and 5 ug/m3 for annual and twenty-four-hour maximum S02
increases, respectively. Sarasota County recently ran a computer model
for the FP&L Manatee Plant and found that the increase from 1.0 to
2.5% sulfur fuel would exceed this increment, thereby identifying the
Manatee Plant as a "significant source," by definition.
The DEIS states in many places (including page 72 of the main doc-
ument and page 77 of the Air Quality Resource Document) that the SOj
PSD and Ambient Air Quality Regulations would not be exceeded without
"major source development" in the area. Clearly, an increase of 150%
in the allowable fuel oil sulfur content for the two largest oil-fired
boilers in the State of Florida would be a "major source development,"
and should, therefore, be included in the analysis.
Since, not only the sulfur dioxide regulations but also the opac-
ity and nitrogen dioxide regulations that apply to this plant were
recently relaxed, these two parameters should also be more carefully
considered in this DEIS.
Presentation of Air Quality Data in Draft Eis. The Air Quality
Documents were presented in a manner that made review of the actual
computer input data very difficult. For example, the interactive
sources that were actually inputed to the computer were not cross-ref-
erenced, the various computer runs were not indexed or properly iden-
tified, and the input codes used were inadequately explained.
Cumulative Impact. Based upon the foregoing, the DEIS is tech-
nically inadequate and does not provide a valid basis for EPA action
-------
pursuant to the Natinal Environmental Policy Act (NEPA) with respect
to air quality impacts of the mining project.
Almost as if EPA's Areawide EIS (AE1S) on the Central Florida
Phosphate Industry (EPA, 1978) had never been written, Estech has pro-
posed a new rock dryer. The AEIS: (1) was predicated on the fact
that there would be no additional rock dryers; and (2) clearly recom-
mended (on page 2.1 of Volume I) the elimination of the rock-drying
process at beneficiation plants. Manatee County has indicated its
concern over additional air pollution by denying land use approval to
the project including the rock-dryer. With the above twp points in
mind, the alternative of using an existing dryer at a remote location
(page 20, DEIS) becomes a far more attractive way to handle the drying
process. The apparent problems of using "older, less effectively
controlled equipment located in areas marginal with respect to air
quality standards" is, in fact, an opportunity for a double benefit.
By choosing this alternative, the industry has the opportunity to
retrofit these existing facilities with adequate environmental protec-
tion equipment (such as scrubbers), which would significantly decrease
the existing air pollution in an"area of marginal air quality.
The DEIS dismisses with little more than one sentence the recom-
mendation of the Areawide EIS that any rock drying be performed at
existing facilities. In light of the fact that Estech owns an exist-
ing rock dryer, the lack of vigorous analysis of this alternative
greatly undercuts the credibility of the DEIS. It is incredible that
the DEIS tries to justify a rock dryer in Manatee County on the
grounds that Estech's existing rock dryer may be creating air quality
problems in Polk County (DEIS, p. 20). The EPA must require good
faith analysis of using existing rock drying facilities in accordance
with the recommendation of the Areawide EIS and consider requiring
upgrading of the existing rock dryer as a condition of granting any
NPDES permit for new facilities.
- DEIS Re^i^r pa9e 5 -
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SOILS, HYDROLOGY AND WATER QUALITY
Holistic Approach Necessary. The sections of this DEIS relating
to soils, hydrology, and water quality, should be reassessed using an
holistic approach in an earnest attempt to clearly identify impacts
that are unavoidable and/or without mitigation so that intelligent
policy decisions can be made with respect to the desirability of
trade-off options. As the text now stands, important data are subor-
dinated under apparently unrelated sections, with little effort to
indicate cause-and-effect relationships in a straightforward manner.
As indicated on pages 71 and 72 of the DEIS, the use of mined-out
pits for storage areas for the waste clays and tailing sands will have
an effect on the water quality in the shallow system but {the nature
of these changes! will depend upon the nature of the materials placed
in these pits.
According to the text (page 12) , the lack of reliable data on the
water quality of waste clays prevents projection of this impact. Al-
though the text indicates that changes in the water quality within the
surficial aquifer, as a result of the clay storage area, "should" be
restricted to its immediate vicinity, the DEIS states that the actual
differences between the water quality of various waste products and
that of surficial deposits can only be characterized after the mine
begins its operations. At that point, it will likely be too late.
For 60 days during August and September of an average rainfall
year, two million gallons per day (mgd) will be discharged from the
mining, reclamation and plant site in the southeast portion of the
property (through point 002 into the East Pork Manatee River).
Effluent will also be discharged for 90 days during August, September
and October of the average rainfall year to the North Fork from the
clay settling area through point 003 at a rate of 1.8 mgd (DEIS, page
89).
Radical Changes in Water Quality. As indicated in the DEIS, there
would be, at least, a doubling of radium—226 concentrations in surface
waters; there would be up to a ten-fold increase in phosphorous con-
centrations and mass loadings in the North and East Forks of the Mana-
tee River (as indicated on Tables 4.10 C & D of the DEIS); there
would be as much as an 18-fold increase in fluoride; there would be a
doubling of biological oxygen demand; there would be up to a five-fold
increase in suspended solids; and there would be an increased contri-
bution to these rivers of over 14,000 lbs. of total dissolved solids
per day (even during minimal flow conditions).
In view of the above negative impacts, Manatee County has denied
land use approval for this mine upstream from the region's most
valuable potable water reservoir.
- DEIS Review, page 6 -
101
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ABOVE-GROUND SLIME POND
Contrary to Areawide EIS. The Draft EIS proposes (on page 27) a
48^-acre conventional above-ground slime pond. This slime pond will
remain active throughout the entire mine life to receive clay wastes.
By the end of the mine life, the area will be filled to about 25 feet
above natural grade. This proposal is diametrically opposed to the
recommendation of the iyreawide EIS (page 2.1, line 1), which states
"eliminate conventional above-ground slime disposal areas."
Contrary to Local Government's Desires. Both Sarasota and Manatee
counties depend upon Lake Manatee for potable water. The very spatial
relationship between the proposed above-ground slime pond and the
downstream reservoir demands a reassessment of the sanity of allowing
an above-ground slime disposal area. As indicated by Mr. Randall,
Pollution Control Director for Manatee County, on February 15, 1979,
at a public hearing on this proposed mine, "The best way to protect
Manatee's most valuable asset (that is, its water) is to have a below-
ground settling pond."
Slime Pond Dam Failure. The applicant has chosen to devote an
entire section (starting on page 98) to the "hypothetical" failure of
the clay settling area embankment. With an above-ground slime pond
filled to 25 feet above ground level, and an earthen dam holding back
literally billions of gallons of waste clays, spread out over almost
500 acres, and this condition being directly upstream from Manatee's
roost precious asset (its potable water source), it is not too dif-
ficult to determine why both the applicant and the local communities
should be concerned about this unnecessary state of affairs.
As indicated on page 100 of the Draft EIS, should the dam fail,
total suspended soilds would increase by 730 milligrams per liter and
the additional sediment load over a two-month period would deposit up
to 60 acre feet of this material in the reservoir. With expected in-
creases in.suspended clay particles, which determine to a great extent
the amount of radium-226 in the water column, total radium-226 will
exceed the State standard of 5 piC per liter for Class I-A waters upon
entering Manatee's reservoir (DEIS, page 101). Based upon related
environmental perturbations along the Apalachicola River (DEIS, page
101), the effect of the solids on the Manatee River floodplain will be.
to kill most trees and severely stress many of those that do survive.
In addition, the spill would result in the destruction of aquatic
fauna of the river with few, if any, organisms surviving. In addi-
tion, the spill would destroy the present littoral zone in the upper
end of the reservoir, which, in turn, would significantly reduce the
biological productivity of the reservoir.
- DEIS Review, page 7 -
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Lack of Serious Discussion of Alternatives. Although it is
apparently financially unattractive to the industry to comply with
this AEIS recommendation relating to slime ponds, no alternatives to
the conventional above-ground slime pond are even discussed. A
conscientious attempt should be made to investigate and honestly
discuss partially, or totally, incised s}.ime ponds, thereby signifi-
cantly decreasing the chances of an environmental disaster.
Based on recent major dam failures, including that at FP&L's faci-
lity in the Okeechobee area, putting faith in a once-a-year inspection
by a registered professional engineer, and his monthly review of re-
ports by on-site operation personnel, is woefully inadequate consider-
ing the above projected impacts. Based upon the known impacts of
above-ground slime ponds and the failure of the DEIS to analyze alter-
natives, an above-ground slime pond cannot be accepted by the EPA at
this time as part of its proposed action.
DEIS Review, page 8
103
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WATER MANAGEMENT
A Matter of Relativity. As indicated on page 28 of the DEIS, 89%
of the total water requirements will be recycled water. However, the
apparently innocuous 11% makeup water required to offset system losses
will average 16+ million gallons per day.
According to the DEIS, this differential is proposed to be sup-
plied by groundwater pumpage until the fourth year, when surface di-
versions from the East Fork Manatee River supply approximately 3 mgd
to the makeup requirements. How will this plan be affected when, for
environmental reasons, the industry is not allowed to mine the East
Fork Manatee River? Specifically, where will this 3 mgd come from?
Reduction of Available Potable Water. During active mining, a
total of 7.2 mgd reduction of stream flow will take place in the North
and East Forks of the Manatee River. As indicated on page 80 of the
DEIS, this reduction of flow would actually decrease *3ae discharge
into the Manatee Reservoir by approximately 9%. What seems to have
been lost in the statistical manipulations presented in the DEIS is
that the total flow of potable water, specifically from the North and
East Forks of the Manatee, would be reduced by 33%.
A Need to Reassess the Proposed Water Management Plan. With the
above almost 10% decrease in potable water reaching the Manatee Reser-
voir, a 33% reduction in potable water supplied by two major contribu-
tors to that reservoir, and the ecological impact of discharge reduc-
tion in the North and East Forks of the Manatee (see the section on
Wetland Protection, which begins on the following page)# the entire
water management program needs to be revisited.
- DEIS Reyi^#, page 9 -
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WETLAND PROTECTION
Proposed Action. Section 2.3 (Resource Recovery Alternatives)
proposes mining approximately 360 of the 600 acres of the freshwater
marsh, 55 acres of the East Fork Manatee River, and most of the small
feeder streams (DEIS, page 6).
In Opposition to EPA's Areawide EIS Recommendations. As stated
(DEIS, page 180), "The segment of the East Fork Manatee River proposed
for mining has been determined to be a Qategory 1 Wetland." Such wet-
lands provide important ecological functions, including erosion con-
trol protection and acting as a living filter by removing sediments
and other pollutants from floodwaters. In addition, these wetlands
are extremely productive and export a portion of this biological pro-
ductivity to downstream areas. Based upon the recommendations of EPA's
Areawide EIS relating to the protection of wetlands (pages 2.2 and
2.3), Category 1 should "be protected" and any mining in the East Fork
would be contrary to the recommendations of the AEIS.
In addition, disturbing Category 2 and 3 Wetlands should be re-
examined, when they are upstream from Category 1 Wetlands, and when
that perturbation can be expected to affect the downstream Category 1
Wetlands. In addition, the biological, as well as the hydrological,
input from these juxtaposed wetlands, is extremely important and
should be addressed more completely.
Impact of Proposed Water Management. Another very important con-
sideration is the ecological impact of water flow reductions on the
separate parts of the drainage system, which is glossed-over by group-
ing statistics. For example, the DEIS (page 80) indicates that a 5.4
mgd reduction in stream flow will occur in the East Fork. A comparison
with existing statistics (on page 77 of the same document) reveals
that this 5.4 mgd exceeds the average minimum flow during wet months,
as well as the average mean and minimum flows for dry months (5, 3,
and 0.8 mgd, respectively).
With a vision of dried-up streambeds and the complete annihilation
of fish, aquatic invertebrates and other wildlife totally dependent
upon stream water for their existence, Estech's proposed water manage-
ment program is unacceptable.
DEIS Re\^g?, page 10 -
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OTHER HABITAT LOST
What Would be Lost. As indicated on page 127 of the DEIS, the di-
rect effect of mining will be the destruction of much of the present
natural vegetation by land clearing and mining activities. The Long
Leaf Pine/Zeric Oak Community will be eliminated on-site, while the
Sand Pine Scrub Community, Long Leaf Pine/Zeric Oak Community, and
Long Leaf Pine/Flatwoods Community will be partially eliminated (see
DEIS, Table 4.12-a).
Long-Term Impacts. As indicated on page 127 of the DEIS, these
impacts on habitat are largely long-term and irreversible. Unfortun-
ately, there are no known instances of these upland communities
naturally restablishing themselves and fully recovering when the soil
has been radically disturbed. In that many of the dominent species,
representing original vegetation like wire grass, have negligible
reproductive potentials, recolonization by these species will be quite
limited. In addition, since many of the natural upland vegetation
communities are dependent upon fire for maintenance, and since fires
will likely be excluded from these and adjacent areas, prolonged fire
supression will constitute a long-term or even irreversible impact.
Perhaps the most devastating aspect of the proposed mining and
reclamation plan on upland communities is their replacement by mono-
cultures, like improved pasture. For instance, and as indicated in
Table 4.12-a (DEIS), there will be an increase in improved pasture of
almost 5000 acres (an increase of four-fold over that existing at the
present time).
In Opposition to Local Policy. Since major changes in existing
habitat are proposed and since these changes will adversely affect
aquatic and other wildlife, including species considered of special
concern, threatened or endangered, the proposed changes would also be
in violation of the Manatee County zoning Ordinance (paragraph 16,
Section 9. "Violations," pages 108-4 and 5), which states, "no person
or organization holding an operating permit under this ordinance shall
pollute land or water, or damage aquatic or marine life, wildlife,
birds, public or private property or allow any extraneous matter to
enter or damage any mineral or freshwater-bearing formation."
Preserving 50 acres of sand pine scrub and an 18-acre cypress
pond, while mining all around it, and devasting a major portion of the
floodplain swamps, is not a reassuring committment to protecting
important habitats. Clearly, the provision of a small stand of sand
pine scrub and a few "tree plantings within pastures" (page 108 of
Swift's DRI) cannot, even broadly, be interpreted as being adequate
protection of habitats or the species they contain.
- DEIS Review, page 11 -
106
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RARE AND ENDANGERED SPECIES
Federal Recognition of the Values of Endangered Species, The fed-
eral government has recognized the importance of the medical, scien-
tific and aesthetic values of endangered species and the need to pro-
tect the ecosystems upon which such species depend. In fact, EPA's
Areawide EIS provides data which support extending P.L. 95-87 to
phosphate mining to ensure that federally recognized endangered spe-
cies will receive meaningful protection.
Rare and Endangered Species On Site. Sixteen species considered
endangered, threatened, rare, or of special concern have been observed
on or immediately adjacent to the Estech property (Draft EIS, page
136). Of these, three (pinweed, the eastern indigo snake, and the
American alligator) are considered threatened on the federal list.
Thirteen sighted on the property are recognized on the State list.
One, the wood stork, is considered endangered, five are considered
threatened (gopher tortoises, southeastern American kestrel, Florida
scrub jay, Florida sandhill crane, and Sherman's fox squirrel), and
seven are of special concern (common egret, Louisiana heron, black-
crowned night heron, little blue heron, white ibis, burrowing owl, and
caracara).
The Impact. At least two species (the southeastern kestrel and
the sandhill crane) will have their preferred nesting habitat "sub-
stantially decreased by mining" (Swift DRI, page 109). The third spe-
cies, the Florida scrub jay, "may be able to survive in one of the
disturbed scrubs but, there will be little suitable habitat after
mining" (DRI, page 111).
In Opposition to the Intent of Policy at All Levels of Government.
The proposed mining will significantly destroy many existing wildlife
habitats. In that the radical alteration of these habitats will spe-
cifically and greatly affect wildlife denizens of those habitats, the
proposed alterations are in direct conflict with the intent of the
federal Endangered Species Act and the equivalent State act. Closer
to the geographical area under consideration, the proposed actions are
in conflict with regional development policies—see especially Tampa
Bay Regional Planning Council's "Future of the Region," 1979, which
states, "wildlife and natural vegetation are recognized as important
resources .... Special protective efforts regarding preservation of
rare, endangered, or threatened species and habitat required to sup-
port these species in the region are encouraged."
Additional Endangered Species. As indicated by a recent seven-
county study (by Layne, et al., 1977), other endangered or threatened
species, like the Florida panther, Florida bear, Florida mouse, bald
eagle, osprey, and others, may be present on this site. However, and
DEIS Review, page 12 -
107
-------
as admitted by the pEIS, the field techniques relating to these spe-
cies may not have been extensive enough to reveal the presence of
these other important species.
Shouldering the Responsibility. This DEIS, like most others re-
viewed to date, simply lists the threatened or endangered species that
will be affected, if not annihilated, and makes no serious effort to
actually preserve these unique gene pools. The time is long overdue
for the phosphate industry to justifiably shoulder the responsibility
of accurately identifying the unique and endangered species present on
a proposed site and, then, in appropriate detail, indicate how these
species will be protected.
1
- DEIS Review, page 13 -
108
-------
RECLAMATION
In addition to the unacceptibility of mining and "reclaiming" a
major secton of the Manatee River, there are foreseeable problems as-
sociated with the proposed reclamation program. For instance, the
majority of the mined-out areas will be filled with a mixture of waste
clays and sand tailings (DEIS, page 62). This method of reclamation
may reduce the effectiveness of recharge wells by decreasing the per-
meability of the property and decrease bearing capacity of the new
soil assemblage (relative to the natural soils) which would limit
future land use options for the site. If land use is to remain rural
in nature, this limitation may not be serious. However, should land
use plans for the area change, then future developers might find it
necessary to take extraordinary precautions in order to stabilize
foundations or to take other measures that would increase the cost of
development.
- DEIS Review, page 14
109
-------
CONCLUSIONS
The Draft EIS describes a number of installations and land uses
which are in direct conflict with EPA's Areawide EIS. The most
outstanding, of course, are the rock dryer, the above-ground slime
pond, and the devastation of Class I and juxtaposed wetlands.
Not only is the pr
-------
RECOMMENDATIONS
1. That no further agency action he taken until the DEIS is re-
focused so that EPA can make an intelligent decision, as required by
NEPA, based upon a conscientious analysis of environmental impacts
identified by this report, that have been glossed-over in the DEIS.
2. That no federal permit be issued because it cannot be justi-
fied in the absence of local approval of the proposed Bstech mining.
- DEIS Review, page 16 -
111
-------
LITERATURE CITED
Devitt, T., R. Gerstle, L. Gibbs, F. Hartman, R. Klier, and B. Kaseke.
1977. Flue Gas Desulfurization Systems Capabilities for Coal-
Fired Steam Generators. EPA Contract No. 68-02-2603 Task #1.
Layne, J.N., J.A. Stallcup, G.E. Woolfenden, M.N. McCanley, and D.J.
Worley. 1977. Fish and Wildlife Inventory of the Seven-
County Region Included in the Central Florida Phosphate In-
dustry Areawide EIS. U.S. Dept. of the Interior Contract No.
14-16-0009-77-005.
Manatee County. Zoning Ordinance. Section 14, "Special Exceptions"
and Section 16, "Earth Moving." Pages 95 through 108-5.
Tampa Bay Regional Planning Council. 1979. Future of the Region: A
Development Statement for the Tampa Bay Region.
- DEIS Review, page 17 -
-------
BACK COVER
OF
LINCER, KLIER REPORT
113
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NATIONAL CENTER FOR ATMOSPHERIC RESEARCH
P. O. Box 3000 • Boulder, Colorado 80307
Telephone: (303) 494-5151 • TWX: 910-940-3245 • Telex: 45 694 • FTS: 322-5151
November 28, 1979
Director, Region IV
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, GA 30308
Dear Sir:
I have reviewed the Draft Environmental Impact Statement of the
Estech General Chemicals Corporation, Report EPA 904/9-79-044G, October
1979, entitled Radiological Environment. This report was sent to me
by Ms. Gloria Rains of Palmetto, Florida who invited my comments. In
my opinion the assessment of risks is inadequate and I seriously doubt
that EPA's proposed standards for public exposure to contaminants from
the phosphate fertilizer industry ara adequately conservative. My
comments on this DEIS are. enclosed.
Sincerely yours
\
J
Enclosure
cc: EPA Office of Radiation Programs
W.E. Bolch
Gloria C. Rains
Tht ~ - . — ...... ....„ ltion
-------
NATIONAL CENTER FOR ATMOSPHERIC RESEARCH
P. O. Box 3000 • Boulder, Colorado 80307
Telephone: (303) 494-5151 • TWX: 910-940-3245 • Telex: 45 694 • FTS: 322-5151
November 28, 1979
TO: Director, Region IV
U.S. Environmental Protection Agency
Atlanta, Georgia
FROM: Dr. Edward A. Martell A
National Center for Atmospheric Research
Boulder, Colorado
SUBJECT: Comments on DEIS, Radiological Environment,
EPA904/9-79-044G, October, 1979
I have reviewed subject report of the Estech General Chemicals
Corporation, prepared by Dr. W.E. Bolch. The author is to be commended
for a report which treats many aspects of the problem of radioactive
contamination from phosphate fertilizer production in a highly competent
and professional manner. However this report gives no adequate consid-
eration to two serious problem areas: (a) ground water contamination
from soluble uranium radioisotopes and other radioelements, and (b) the
nature and magnitude of risks attributable to 0.02WL of radon progeny
in structures built on reclaimed lands. The EPA has proposed 0.02WL
as the acceptable limit for public exposure to radon progeny in homes
and other structures built on lands contaminated by the phosphate
fertilizer industry. It is therefore incumbent on the EPA to assess
the magnitude of the chronic health risks from 0.02WL and to determine
whether or not such risks are acceptable to an informed public. The
same questions apply to current standards for radioisotopes in drinking
water: 5 picocuries per liter for radium-226, and 10 picocuries per
liter for soluble uranium (recently proposed, see below). What is the
expected incidence of leukemia, bone cancer, liver cancer and other
effects from lifetime exposure to these levels of alpha emitting
radioisotopes in drinking water?
My specific comments and questions on subject report are as follows:
Affiliation given for address purposes only. The National Center for
Atmospheric Research is sponsored by the National Science Foundation.
The National Center for Atmospheric Research Is Operated by the University Corporation
for Atmospheric Research under sponsorship of the National Science Foundation.
An Equal Opportunity!Affirmative Action Employer
115
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1. Top of page 57: It is assumed that ore processing does not
modify uranium-radium equilibrium. Such an assumption is highly questionable
and unjustified. Radium-226 is similar to calcium in its chemical
properties and may be highly fractionated in by product gypsum, in
triple phosphate, and in wastes and waste water fractions. In particular
one should look at the distribution of soluble uranium in the waste
water and in contaminated ground waters of reclaimed Florida phosphate
land areas. Only recently, the contamination of ground waters by soluble
uranium from uranium mines and uranium mills has been recognized as a
potentially serious problem in Colorado and other uranium mining areas.
2. Bottom of page 67: For completeness U-238 and Pb-210 should be
added to this list. Both are bone seekers and the U-238 as well as the
Po-210 daughter of 210Pb emit alpha radiation and contribute to the risk
of bone cancer and leukemia. The concentration of these isotopes should
be assessed in drinking water, in cereal grains and other vegetable foods,
and in dairy products of reclaimed phosphate lands. These two isotopes
also should be included in the list of radionuclides measured in airborne
dust particles generated by phosphate fertilizer production.
3. Page 77, Par. 6: Here again it is "assumed" that the uranium
is present in equilibrium with radium In the phosphate fertilizer product.
However, Spalding and Sackett (Science, Vol 175, 629-631, 1972) showed
that uranium is readily leached from phosphate fertilizers by water.
Thus, high concentrations of uranium isotopes are to be expected in waste
waters and ground waters in and downstream of phosphate production sites
and in wells and streams throughout reclaimed phosphate lands.
4. Page 78, third paragraph: It is stated here that "Community
water systems shall not exceed 15 pCi/1 of gross alpha (including radium-226
but excluding radon and uranium). The combined radium-226 and radium-228
shall not exceed 5 pCi/1."
The lack of a soluble uranium standard for water quality here is a
very serious omission. Recently Dr. Wm. L. Lappienbusch (EPA Office of
Radiation Programs, Criteria and Standards Division) has proposed a
water standard of 10 pCi/1 for soluble uranium radionuclides (mainly
U-238 and U-234). And I must comment that based on current knowledge,
this is not necessarily a conservative standard. Based on studies by
Dr. Miriam P. Finkel of Argonne National Laboratory, the bone tumor risk
for uranium and radium are very nearly the same per unit of alpha activity
in bone. Uranium also gives rise to' cancer in the kidney. The bone
uptake and retention of uranium is very much higher in young children
than in adults. The relative risk for uranium and radium should take
into account both the relative uptake and retention on a cumulative basis
for chronic exposure. The distribution in bone also may be very important.
Per unit activity, Pu-239, which is highly non-uniform in bone, gives rise
to a 10 times higher bone tumor risk than Ra-226. For chronic exposure, is
the uranium distribution in human bone similar to that of Ra-226 or to
that of Pu-239? The risk may be expected to vary accordingly.
116
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The need for a drinking water standard for Pb-210, which is a
bone seeking radionuclide with a Po-210 granddaughter which emits alpha
radiation, also should be determined.
Radon in the water supply is an added source of indoor radon
progeny for all residents in the affected areas (see comment 5).
5. Page 72, lines 7-10: The EPA proposed standard cited here,
0.020WL total exposure to radon progeny, including background, represents
a substantial risk that may not be acceptable for public exposure when
its full cancer risk implications are understood by the general public.
Lifetime exposure to 0.02WL will givB rise to about 3,000 excess lung
cancer deaths per 100,000 people (EPA Report, Indoor Radiation Exposure
due to Radium-226 in Florida Phosphate Lands, EPA 520/4-78-013, February
1979). In addition, it is now evident that this level also may
contribute to a large increase in skin cancer risks (Sevcova et al,
Health Physics 35, 803-806). I estimate that lifetime exposure to 0.02WL
in homes and other structures may give rise to about 10 times higher
than normal incidence of skin cancer.
117
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anaSota -88
A Project for tnvironmontal Quality I96S-1988
I am Gloria C. Rains of 531^ Bay State Rd, Palmetto, here as a
member of the Izaak Walton League and as Chairman of Manasota-88.
Some of our members find this hearing at a time when the Estech
application to mine phosphate in Manatee County has been denied
by our local government and when the matter is under litigation,
incongruous and an event that could be misconstrued by some as
an attempt by the federal government to usurp the power of local
government. Certainly, if the county's decision to deny this firm's.,
application is upheld, as we have every hope it will be, this
hearing is unnecessary.
We are opposed to the permitting of this Estech facility for the
following reasons* ?
The quantity of uranium oxides mixed with phosphate rock* exceeds
the quantity extracted by the domestic uranium industry. These
radioactive substances are redistributed and concentrated during
mining. No small matter when you realize after mining that
of total radioactivity remains with the slime ponds and liquified
clay and 12# remains in the waste sand tailings.
Therefore, I would like to bring tn. your attention s°me most serious
comments ret the separate document entitled Radiological
Environment, EPA 90v9-79-0^4g dated October 1979<
In this document you will find reference to an article in Science
Magazine and a reference to Spalding. It appears these references *
are> incorrect in text. Therefore, it appears the assumptions i
through this document may be incorrect. £
Due to weather problems and a holiday, information I hoped to
present you from Dr. Edward A. Martell, National Center for
Atmospheric Research, Boulder, Colorado will be mailed by Dr.
Martell to both the Atlanta office and to the National Administrator.
However, Dr. Martell has provided the following information ret
"possible ground water contamination from uranium contamination
in the reclaimed land areas and on the magnitude of risks due to
radon progeny in structures located on reclaimed lands."
Dr. Martell finds on the top of p. 57» referenced volume, "it ^
is assumed that ore processing does not change the uranium to •»
radium equilibrium. This assumption is unjustified and highly >
questionable. R-226 is similar to calcium in its chemical properties
and is highly fractionated in phosphate wastes and waste water
(also in byproduct gypsum & triple phosphate)."
118
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Page 2
"In particular one should look at the distribution of soluble
uranium in the waste v.ater and in contaminated ground water of
reclaimed Florida phosphate land areas. Only recently the
contamination of ground water by soluble uranium from uranium
mines and uranium mills has been recognized as a potentially
serious problem in Colorado and other uranium mining areas."
Re: to the bottom of p. 67, Dr. Martell states,"for completeness
U-238 & Pb-210 ohould be added to this list. Both are bone seekers ®
and the U-238 as well as the Po-210 daughter of Pb-210 emit alpha i
radiation and contribute to the risk of bone cancer and lukemia. 3B
The concentration of these isotopes should be assessed in drinking
water and in cereal grains, other vegetable foods and dairy products
in and near reclaimed phosphate lands. These 2 isotopes also should
be included in "he list of radionuclides measured in dust particles."
Re: page 77, para. 6, "here again it is "assured" that the uranium *-
is present in equilibrium with radium in the phosphate fertilizer f
product. However, Spalding & Sackett (Science, Vol. 175, 629-631, £
1972) showed that uranium is readily leached from phosphate fertilizers
by water. Thus light concentrations of uranium isotopes are to be
expected in waste waters and ground waters in and downstream of
phosphate production sites and in wells and streams through reclaimed
lands."
Re: p. 78, para. 3: "It is stated here that "Community water systems
shall not exceed 15 pCi/l of gross alpha (including radium-226 but
excluding radon and uranium). The combined radium-226 and radium-
228 shall not exceed 5 pCi/l."
"The lack of a soluble uranium standard for water quality here is
a very serious omission. Recently, Dr. W.L. Lappenbusch, EPA Office
*
of Radiation Programs, Criteria & Stds. Div. , has proposed a water 1
standard of 10 pCi/l for soliubl.e uranium radionuclides (mainly U-238
& u-23^)."And. Dr. Martell feels he"must comment that, based on
current knowledge, this is not necessarily a conservative standard.
Based on studies by Dr. Miriam P. Finkel, Argonne Natl. Laboratory,
bone tumor risk for uranium & radium are very nearly the same per
unit of alpha activity in bone. Uranium also gives rise to cancer
in the kidney. The bone uptake and retention of uranium is very
much higher in young children than adults. The relative risks for
uranium and radium should take into account both the relative uptake
and retention on a cumulative basis for chronic exposure. The J
distributions in bone also may be very important." ^
"Per unit activity, Pu-239» which is highly non-uniform in bone,
gives rise to a 10 times higher bone tumor risk than R-226. Chronic
exposure is the uranium distribution in human bone similar to that
of R-226 or to that of Pu-239• The risk may be expected to vary
accordingly. The need for a drinking water standard for pb-210,
which is a bone-seeking radionuclide with a p0-2to grandaughter
which emits alpha radiation should also be considered."
£
Radon in the water supply is an added source of indoor radon progeny
for all residents in the affected areas."
Re: P. 72, lines 7-10: "The EPA proposed standards cited here, 0.020
WL total exposure to radon progeny, including background, represents
a substantial risk that may not be acceptable for public exposure
119
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rage j
when its full cancer risks are known by the general public. Lifetime
exposure to 0.020 WL will give rise to about 3,000 excess lung
cancer deaths per 100,000 people. Actually, EPA concedes this could
be as high as 5,000 excess lung cancer deaths per 100,000. (EPA
Report, Indoor Radiation Exposure due to R-226 in Fl. Phosphate
Lands, EPA 520/4-78-013, Feb "79, revised July "79). In addition, g
it is now evident that this level will also give rise to a large ' »
increase in skin cancer risks (Sevcova et al, Health Physics, 35, £
803-806)." Dr. Martell estimates that life-time exposure to 0.020
WL in houses and other structures will result in about 10 times
higher than the normal incidence of skin cancer."
Additionally, one rock dryer emits 64.5 tons per year of particulates
and 2,450,000,000 picocuries of R-226, an amount which exceeds the _
equivalent radionuclides which would be allowed by the NRC from a *
1000 megawatt nuclear power plant. The 2 dryers proposed at this »
plant will emit 1290 tons of particulates and 4,900,000,000 pico- »
curies of R-226. These emissions can be somewhat controlled, but
not eliminated through scrubbers.
However, scrubbers have a high rate of failure and are only as good
as their maintenance. High stacks to aid dispersal of these radio-
active residual particulates and pollutant gases over the county
is hardly a satisfactory resolution of this problem. Further,
disposal of radioactive residue from these scrubbers pose another
problem.
Despite scrubbers and stack dispersal, there can be no question
that significant and dangerous to human health levels of radionuclides
and particulates will continue to be emitted into our county air.
There can be no doubt how dangerous this mining operation will be
to human health. However, other studies, including those presented
at a U.S. Dept. Of Energy meeting on March 20, 1979 show that
experiments indicate the effect of multiple low-level doses of
radiation may be greater than that of one equivalent dose - that
the cumulative effects of low-level radiation exposure may be much
more harmful than has been believed.
Based on the latter, there can be no justification for the permitting
of these rock dryers or for that matter mining as it is presently
done.
Particulates from routine mining operations, transport of the rock
and loading operations also create problems. Among other things,
they cause obstructive pulmonary changes and alpha particulates,
thought to remain in the lungs for years, also can cause death
before cancer becomes evident.
As far as reclamation, the EIS says it will be too expensive for
Estech to follow EPA recommendations for land cover of 3 "to 4 ft.
of topsoil. Actually, to date, there is no way to guarantee, either
through home design or 3 "to 4 feet of "relatively" radiation free earth
cover, freedom from adverse health effects while living on
reclaimed lands.
There can be no doubt radioactive soil in reclaimed phosphate mining
lands is a serious problem - so serious that overburden, waste sands &
120
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Page 4
clay used for fill have been proposed for classification as
"special" hazardous waste.
Additional information re: radiation danger for residents of
homes on phoshate lands comes from Mr. W.A. Mills, head, of
EPA's Radiation Program, who stated the phosphate danger might
"be greater than the cancer risk for soldiers who participated in
a variety of atomic bomb tests in Utah and Nevada during the 50's.
It is doubtful reclaimed lands can be safely used for housing -
It is doubtful they can safely be used for cattle or crop
production eithar.
The EPA Phosphate EIS and other sources state consumption of foods
(crop foods or beef) produced on reclaimed lands provide a route
for secondary radiation impact exposures.
Gross alpha radioactivity in vegetables grown on reclaimed lands
has been found to be higher than in vegetables grown outside the
reclaimed regions. High levels of radioactivity have been found
in wild game on reclaimed land, the latter producing a warning as
to how much game could be safely consumed by humans from the
Director of the Health & Rehabilitative Services. And as Dr. Marteli
has pointed out tests for other radioactive substances need to be
done in these areas-
Approximately 3^0 acres of lands will be reclaimed as lakes if this
application is approved. It is most questionable that these increasing
numbers of phosphate pits filled with water have recreational ^
potential until definitive tests by someone outside the industry ^
res the uptake of radioactive materials by fish and other wildlife »
are accomplished and prove that these areas can be safely used *
for fish management or recreational use.
If this mining is permitted, we may experience a permanent decrease
in agricultural lands which wi.i l impact unfavorably on our balance
of trade. In fact, as radiological studies are made known, it-may
well be that phosphate mining (Constitutes; a permanent use of the ^
lan d.
Restoration of wetlands on this site is impossible because of
changes in adjacent land terrain, alteration of the local hydrologic
regime and changes in the particular constituents of the water.
To date, the creation of wetlands has neven been successfully
demonstrated.
Marsh-type reclamation projects will not replace the natural
functions of the true marsh.
Mining as it is proposed here, will destroy native vegetation, natural
watersheds and the natural order of the soil's layers from top to
bottom of the mined-out zone. Topsoils will be obliterated, breaking
up the water-holding hard pan underlying most of the property and
121
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Page 5
will so chsinge soil profiles and land contours as to irrevocably
alter surface drainage patterns. Reclamation cannot restore these '
©
10
systems.
We ask that the Technical Staff of EPA's Air Quality Section check
the EIS Air Quality report for sufficiency and accuracy which we
understand has not been done. We base this request on information
obtained from the DER/Agrico vs. Freeport Sulphur/Sulphur Terminals
Inc. Administrative Hearing where this same preparer was used £
and where extremely serious omissions of data were found. (See
attached information).
¦o
We need to know if all emissions that could reasonably be anticipated
and all the proposed emission points, including the most significant
ones, were included for consideration .in this EIS.
ei
to
There appears to be some question that the concentrations predicted
by the Air Quality Display Model are reliable because
of the nature of the emission estimates on which they were predicated.
We quote p. ^2 of the EIS which says, ''It is recognized that the J*
utility of this estimation is highly dependent on the estimate of i
background concentrations." "However, consideration of available ^
facts will suggest etc etc."
*
It should also be mentioned that cumulative effects of all mining f
operations presently permitted in our region plus Estech do not £
appear to have been considered. Additionally, the impact of the
support activity, electricity generation - in this case, the daily
generation of 73.955 KVA to supply this facility, which will produce T
further deterioration of air quality, does net appear to have been ^
considered.
What is listed as the hypothetical failure of the clay settling
area embankment, more commonly referred to as a slime pond break,
is not so unlikely, as we know from the recent FPL dam break.
wi
<0
ci
It appears the effect of such a spill on our reservoir as described
in the EIS may be understated and based on assumptions with 1 Which we
disagree?; .£ A number of rather important facts are not discussed, £
such as how much it will cost to return the reservoir to operating '
condition.
Predicating the short-term effects of this hypothetical spill on K
the "instant mixing of the 1000 acre feet of clear water discharge ®
from the clay nettling area with the minimum of 6,920 acre foot of' ^
rr;:;r: rvoi r v,torix{r,<: doecj not appear realistic.
Careful reading will show the water flow into the reservoir will
be reduced because of waste clay damming the stream involved. This^
will mean a reduction of 9 to 12 mgd of water flow to the reservoir,
leaving the slime to ooze in
The EIS is correct in stating all life will be severely stressed in
the Manatee River floodplain, that most trees and all vegetation
will be destroyed, that the aquatic fauna will be destroyed, all benthic
organisms will bo destroyed and species diversity obviously lowered.
122
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k (-
the transfer point between the inclined conveyor belt and the
olevated conveyor belt and for various placet above and around
the storage pile. Ho water cprays have been planned for spray-
ing into the ships' holds. To catch sulphur dust, U-shaped
concrete beds are planned for underneath all of the conveyor
belts and the head pulleys of all conveyors are to be equipped
with scrapers.
In support of its application, Agrico caused estimates
of sulphur dust emissions from the proposed facility to be made.
The only emissions considered, however, were those to be
anticipated as a result of sulphur falling from the elevated
conveyor belt onto the stockpile, wind erosion of the stock-
pile, vehicular traffic around the stockpile and scooping from \
the stockpile by front end loaders. Tho great bulk of the emlo-
oions reasonably to be anticipated and a substantial majority
o'f the proposed emission points, including tho moat significant
emission points,^ere omitted £rom_consideration, Those omis-
sions went unnoticed by the DER personnel who recommended
issuance of a construction permit to Agrico.
In preparing emission estimates for submission to
DER, it was assumed that prilled sulphur would have an emission
factor comparable to the emission factor for aggregate. Sub-
sequently, other experts assumed prilled sulphur would have
an emission factor like coal's. Making such assumptions is
acceptable methodology in the absence of information about a
particular material but the possibilities for substantial
error are significant.
Dusting properties vary even among different types
of sulphur prills, depending on, among other things, their
friability, method of manufacture, moisture content, and the
distribution of particle sixes. Water formed or "wet" prills
are produced by introducing drops of molten sulphur into a
stream of water or a "quench tank"; air formed or "dry" prilling
techniques use air to cool drops of molt.cn sulphur, transforming
8
22
123
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Page 6
However, considerable evidence exists to assume expensive installation
of new drying beds and probably new lagoon facilities and other new a
equipment will be necessary if this reservoir could ever operate w
again. The speed which with the EIS says this area is supposed to i
be revegetated again is questioned. Further, based on the conclusion
of TBRPC 208 consultant, it is doubtful the reservoir could ever
be used again for a potable water source. If it were possible, the
expense in rendering it operable would be catastrophic.
EIS projections re: radioactive levels>, total suspended solids etc. fl»
after the spill appear quite optimistic. We ask EPA thoroughly f
examine these projections and the basis for them. ^
As fas as probabilities of a dam break are concerned, we are talking
about our public-drinking water supply upon which the overwhelming
number of people in Manatee County and many in Sarasota County rely.
It will take only one spill to put us out of business.
While the EIS sees recharge for our groundwater aquifer as posing
no problem, accumulated information shows injection through connector
wells of surface aquifer water, long in contact with radioactive
materials, into deeper zones of different and generally higher
chemical quality, prior to mining, will further contaminate our
groundwater with radioactive materials.
Monitoring, as proposed here, has not prevented this from happening
nor have adequate remedies to protect our groundwater from this
contamination been successfully implemented in other mining areas.
(As examples: Well No. TR-9 at Borden's Big ^ mine in Hillsborough
County has displayed a gross alpha reading of 3,700 picocuries
per liter, approximately 250 times the recommended level.IMC's
Kingford mine's water quality report from May to Dec 1978 for 60
wells listed 23 instances of gross 'alpha radioactivity above the
federal standards). 0
•
As to cumulative effects, even before any mines are operating in ^
Manatee County, SWFWMD staff members estimate the amount of water
from mining operations presently injected into our Fl. aquifer,
which provides water for thousands of Floridians and has been
designated by SWFWMD as the best potential source of drinking water
for Sarasota County, is between 25 and 30 mgd.
In order to protect our groundwater from further contamination, we
recommend against this proposal. Recharge wells should not be
permitted until radiation problems are solved.
Further, based on such evidence as exists, to intimidate as the EIS
does, that contaminated groundwater will remain under the mining
site for the foreseeable future or will migrate only a short ^
distance is, at best, unscientific.
Also, there will be deterioration of groundwater due to the addition
of flocculants added to the sand-clay disposal system, seepage c*
losses from highly contaminated recycled water and seepage from •
slime ponds. £
124
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Page 7
Our surface water will be severely impacted from this proposed
mining. It should be noted the cumulative effects of more than
one mining operation have not been considered.
The water resource regime will be changed before mining even
begins when all vegetation is stripped from an area. This will
eliminate plant evapotranspiration, intake of water from the ^
soil and the release of water from all living plant tissues. Small «
climate changes will result which can significantly alter rainfall i
regime. Natural flow patterns and storage capacities will be *
irretreviably altered. Runoff patterns will be demolished as will
be natural recharge areas.
The runoff from this mining tract now contributes 11.6$ of the
total flow into the Manatee River. Even with such reductions as are
possible with controls, we can expect steady deterioration of the ^
Lake Manatee watershed as a result of normal discharge of <0
phosphate wastes. As an example, EPA's Surveillance Div. has ¦
determined that despite environmental controls, tons of pollutants *
from mining areas not subject to permitting are pouring daily
into the Peace <5-. Alafia Rivers. The average runoff of 11.8
mgd from this site will be just as polluted.
10
Mining of minor tributaries and bayheads adjacent to major streams •
will also further contribute to water degradation. ^
For a minimum of 2 months of the year, 1.959 ingd will be discharged
from point 2 into the East Fork of the Manatee River; 3 months of
the year, 1.773 mgd will be discharged into the North Fork. This
means Estech will dump in the neighborhood of 36,700 gallons per
minute of excess water into the North Fork of the Manatee. Aside
from the hazards of radioactivity and the residue of known
carcinogen reagents used in the flotation process, the EIS concedes £
that federal/state standards for total suspended solids, total i
phosphorus and fluorides will be exceeded for varying amounts of time ^
up to 14$. Additionally, we are told fluoride concentrations based
on acceptable methods of data projections, cannot meet the state
standards at a station near to the Manatee County water plant intake.
However, we are not to worry because runoff from an unnamed source
will probably dilute this fluoride to acceptable Class I levels.
The applicant acknowledges that NPDES standards cannot be met
before mining even begins.
However, we are told Swift will regularly monitor efflunet water
quality at the permitted points of discharge to assure compliance
with NPDES permit conditions and that these discharges of effluents
will not noticeably alter water quality.
Of course, accumulated levels of fluorides, solids, phosphorus,
reagents and radium will adversely affect water quality and permit
accumulations of harmful materials. It will just be accomplished,
perhaps, at permitted levels.
Further, the company saying, when the situation can be corrected,
that it is too expensive to clean up or prevent this degrading
to water quality discharge from entering the North Fork is not
cause for reassurance nor is the fact that monitoring abuse is
prevalent throughout the industry and that water quality cannot
125
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Page 8
often be checked by our regulatory personnel.
We can 'think of' no justification for permitting new source discharges
of pollutants that should be terminated by 1985 anyway. This discharge
is clearly not in the public interest and should not be permitted.
The 13 mgd, after 3 years 10 mgd, withdrawal by Estech from the
deep ground-water system will further divert water that normally
seeps through the aquifer south and west through Sarasota. Combined
use with the withdrawals proposed by the Beker and Phillips operation £
will result in withdrawals of 35 mgd of water - 6 times that of 1
the City of Sarasota and more than our Manatee Utilities distributed 5
during its heaviest use period to residents of Manatee County and
parts of Sarasota County. This withdrawal may permit further salt-
water intrusion into our groundwater.
The proposed rerouting of a portion of the East Fork of the Manatee
River will inevitably lead to degradation of water quality.
The decline of water quality and quantity from this proposed mining
is inevitable and it will exert its effect upon all water consumers.
Time does not permit a detailed examination of the economic impacts
of this proposed facility. Suffice it to say»it poses no positive
benefit to the area, region or nation. Carefully reviewed, it can
only be considered an economic negative.
Finally, it appears several parts of this EIS may be 1 faulty and
we cannot, until they are investigated and proven to be correct,
accept it as accurate.
In line with its responsibilities to protect the public health,
we ask EPA to select the no-action alternative. To do otherwise,
when sufficient evidence exists to demonstrate the damaging effects
of this industry as it is now operated, is abdicating that responsibility
126
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SINCE NINETEEN HUNDRED
December 12, 1979
THE VOICE OF CONSERVATION"
John Hagar)
E.P.A. Region tV
345 Cour+land Street, NE
Atlanta, Georgia 30308
Dear Mr. Hagan:
I would like to offer some remarks on a limited segment of the
Estech Draft EIS (Estech General Chemical Corporation, Duette Mine,
Manatee County, Florida).
I will restrict my observations to the question of reclaimed
soils, largely because I am unsatisfied with the success of reclama-
tion In the Central Florida mining area, and because If the miner
Is not successful with his reclamation then he has destroyed many
thousands of acres of land. If that Is the case, then the grand
bargain the phosphate Industry has struck with the public - to mine
but to restore a living earth - will be foresaken.
{ cannot say I find the Estech soils section to be confidence
Inspiring. Soil, regardless of its agricultural potential, Is an
extraordInarTIy complex medium with physical, chemical and biological
properties. By his action, the miner destroys these properties.
His challenge is to replace them.
In section 4.5 - Soils, we do learn the soil "types"'of the
native substrates that Estech Intends to mine. These "types" are
well documented In the literature and have meaning to the plant 2
ecologlst. Thatils, he can reasonably predict vegetation charact- I
eristics for each of the soil types. But, the EIS states that these 3*
soils will be replaced with either "clay" or "sand-clay" or
"overburden". These terms have no ecological meaning.
The new soils are predicted to have certain limitations. The
clays will be unusable until dewatered. After that, their utility
will remain In question. The sand-clay soils will exhibit dewaterlng
problems similar to the clay wastes, according to the EIS. The over-
burden will be reclaimed for pasture.
fn the soils "Mitigation" section (p.54) the defclencles of the
FLORIDA AUDUBON SOCIETY
921 Laic* Sybalia Driva • P. O. Drawer 7 • Maitland, Florida 32751
(305) 6^615
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Page 2.
new soils are considered "short term". I see nothing In the section at
to encourage me to look forward to the bur geonlng of a verdant •
country-side during my lifetime In the Estech mining area In which >
clays and sand-clays are used.
As for the overburden soils, to reclaim for pasture grass is £
to commit the area to energy-Intensive agricultural techniques just
to keep It green. It Is green now with no help from man. Why the >
dIfference?
As I said In the beginning, soils are complex and alive -
I IteraI I y. V IrtuaI 1y all soils are colonized by rema rkabIy dI verse
flora and fauna of microscopic size. This microblota performs
various chemical and physical functions, Including establishing
symbiotic relationships with la.rger rooted plants that permit the
plants to absorb the nutrients the soil may bear.
in mined soils, all this mlnature life is lost. Consequently,
to make pasture grass grow, one must help the grass with machines
and chemicals. Pasture grass on the mined sites of Florida Is a
sign of reclamation failure. It Is but a green toupee on the life-
less scalp of mother earth.
To my knowledge, no miner In Florida seeks to reestablish the £
mlcroblota of reclaimed soils. That I believe Is the chief explan- i
atlon for the resistance to plant reco1 onizatI on that so much of ^
the mined land of Florida exhibits.
If that biota could be reestablished, the advance of rooted
plants could not be prevented. They would rush to occupy the barren
expanses of relatively rich overburden. Ask any farmer who falls
to graze or mow his pasture for a year or so. It is very difficult
to arrest plant succession In a place like Florida, but the Florida
phosphate miner has done It.
Please note that If these soils would accept natural vegetation
colonization, one would be assured that the soils were alive and that
agriculture could take place If the land owner or county planner
desired to exercise that option.
Current reclamation to pasture grass leaves society with only-
two options: continued maintenance of the pasture at significant
expense; or development.
As 1 believe I once argued on the occasion of the Area Wide E1S,
it Is tncumbant upon the miner to restore to society at least those
broad options for land use that society currently enjoys. Restoring
the mine site to a less rugged relief, restoring surface water
systems to a functional, se1"fmaIntaInIng status, and bringing the soil
back to life would provide most of those options. The healing
abilities of nature would take It from there. However, the miner
128
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Page 3.
has somehow blocked those healing powers from working.
The Estech EIS promises no relief from the status quo.
Ultimately, the public will bear the burden of forcing the reclaimed
soils to grow. That's no good.
The final EIS should more fully address soil biology. Estech
and all mining companies to follow, must show that the thousands
of acres of affected landscape will become seIf-ma Inta i nIna .
living communities.
1 frankly don't consider this much of a problem. Coal miners
are doing It In the strip mined areas of the Midwest. There exists
notable literature on soil mlcrobiota. We can solve the problem
If we have the courage to Identify the problem.
It's time to get serious on reclamation In Florida. Let Estech
lead the way.
^ | n ra ro I \/
Archie Carr III, Ph.D.
Special Assistant to the President for Science
c.c. Florida DNR
129
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
PUBLIC HEALTH SERVICE
CENTER FOR DISEASE CONTROL
ATLANTA, GEORGIA 30333
December 7, 1979
Mr. John E. Hagan III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30308
Dear Mr. Hagan:
We have reviewed the Draft Environmental Impact Statement (EIS) on the
Estech General Chemicals Corporation's Duette Mine, Manatee County, Florida.
We are responding on behalf of the Public Health Service.
We are pleased to note that the plans for this facility will incorporate
effluent limits and air quality standards that meet new source performance
standards. However, we do have some areas of concern with other aspects
of the proposed mining project.
We understand the amount of water to be withdrawn from the Floridian aquifer
under the comsumptive use permit allows a withdrawal rate of 13 MGD for
the first three years of the mining operation. Will the aquifer be able to
support this type of drawdown and continue to provide sufficient amounts of
potable water to private or public wells in the area beyond seasonal fluc-
tuations? Also, have future residential development and needs been considered
in the aquifer potential supply?
The prevention of possible adverse exposure to the workers needs to be
addressed in more detail. Epidemiological studies of the phosphate fertilizer
and mining industry are presently underway to investigate the question of
possible excess lung cancer mortality among workers associated with these
industries. The levels of worker protection that will be implemented at the
reactors, dragline area, beneficiation plant or other area where materials
in process are concentrated needs to be discussed in the EIS.
We assume and expect the level of fluoride emissions for any area of the
facility will not exceed the recommended NIOSH standard of 2.5 mg/cu/meter
over an eight hour time weighted average.
Also what type monitoring will be instituted in the rock pile transfer
tunnels to measure the possible build-up of airborne radon progeny levels?
Even though the Duette Mine will have properly ventilated tunnels, close
monitoring of these areas would be prudent to prevent excessive occupational
exposure.
130
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Page 2 - Mr. John E. Hagan III
We noted on page 115 that the EPA guidance for reclaimed lands suggests an
upper limit of predicted radon progeny in slab-on-grade homes of 0.009 WL
against a normal background of 0.004 WL plus the uncertainty of 0.005 WL.
If this assumption is correct, then we agree the Duette site may have to
consider the return of topsoil to any residential development site.
Thank you for the opportunity of reviewing this statement. We would appreciate
receiving a copy of the final statement when it is issued.
Sincerely yours
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Bureau of State Services
131
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United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
NOV 2 7 1979
In Reply Refer To:
ER-79/978
Mr. John E. Hagan, 11,1
Chief, EIS Branch
Environmental Protection Agency
Region IV
34-5 Courtland Street, N.E.
Atlanta, Georgia 3 03 08
Dear Mr. Hagan:
We have reviewed the draft environmental statement for the
Estech General Chemicals Corporation Duette Mine, Manatee
County, Florida, sent to us on October 5, 1979. We
strongly support EPA's recommendation that because of
environmental considerations, the East Fork Manatee River
not be mined.
General Comments
The project is within the range of several threatened and
endangered species. Should the responsible Federal per-
mitting agency determine that any of these species may be
affected by the work, they should initiate consultation in
accordance with Section 7 of the amended Endangered Species £
Act of 19 73 by requesting from the Regional Director, N
U.S. Fish and Wildlife Service, a list of the threatened >
and endangered species found in the area. The consultation
process is a set, legally established procedure. Coordina-
tion with this Service as provided for by the Fish and Wild-
life Coordination Act will not relieve the permitting
agency of its responsibilities under the Endangered Species
Act.
The National Park Service is conducting a study of the
Myakka River to determine its potential for inclusion in
the National Wild and Scenic Rivers System. We are concerned
about several factors of the Duette Mine operation which may ^
set precedents. These precedents may result in the accep-
tance of mining practices which could have adverse impacts on i
the Myakka River system should the phosphate industry pro-
ceed with planned mining activities within the Myakka River
Basin.
132
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2
The document demonstrates extensive evaluation of archeo-
logical and historic resources to date. However, the final
environmental statement should provide evidence of full
compliance with 36 CFR Part 800 and 36 CFR Part 63. In con-
sultation with the Florida State Historic Preservation
Officer (SHPO), the Environmental Protection Agency (EPA) ^
should request determinations of eligibility for the Parrish 1
and Carruthers Mounds from the Keeper of the National Register ^
of Historic Places. If found eligible, EPA should consult
with the SHPO and the Advisory Council on Historic Preserva-
tion to determine project effects and develop appropriate
mitigation measures.
Specific Comments
The document contains no information as to design specifica-
tions or construction methods for the tailings embankment.
Both the tailings pond location and the past record of failures
for tailings retention warrant a closer examination of this
particular project element. In estimating the probability of
embankment failure, it is stated that the annual risk of a
modern dam failure is approximately 1 in 10,000 and it is
concluded that in the case of the proposed embankment the
annual risk of failure is "about one chance in 100,000 or one- £
tenth the probability of a clear water dam failure" (p 9 8
par. 3). However, it was reported in the Environmental '
Protection Agency's notice on Development of Standards for
Uranium Mill Tailings and Report on Uranium Mining Wastes
(Federal Register, Vol. 44, No. 113, June 1, 1979) that while
water retention dams have failed only once in 1,500 to 1,800
dam—years, uranium mill tailings dams have failed once in onlv
40 dam-years, on the_average, or about 40 times more fre-
quently. If those figures are correct, they suggest that the
conclusion that embankment failure has an annual risk of only
one chance in 10 0,00 0 may be optimistic and appears to merit
reconsideration or further justification.
It is suggested (par. 3, p. 58) that significant recharge to
to the relatively deep Floridan aquifer might occur at the
site. The magnitude of such local leakage into the important
artesian aquifer should be more thoroughly discussed and 2
assessed in view of the very low leakance values indicated 1
elsewhere^(pars. 2 and 5, p. 58, and in Table 4.7A on p. 60). ^
This clarification is significant in impact evaluation
because of the_importance of the confining layers in protect-
ing water quality. ^
133
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3
It is stated that recharge (connector) wells are to be cased
for the upper 150 feet or so (p. 64). The tentative casing ^
schedule should be reassessed and explained in view of the «s
probability that the highest levels of radioactivity are i
found in the lower Hawthorn Formation between about 200 and *
400 feet (DEIS: p. 55; figs. 4.7-1, 4.11-2; Radiological
Environment Resource Document: p. 23, 26).
The probable source(s) of Coliforms in the shallow aquifer
(DEIS: p. 27), the movement of such pollutants as a result of
dewatering and recharge operations, and the possibility of
effects on the Floridan aquifer through connector well opera- ®
tions should be more thoroughly assessed. The discussion £
should include at least general plans for methods of monitor-
ing both the shallow and deep aquifers during recharge.
The report states that erosion runoff can cause serious short-
term negative impacts (p. 132). It is not clear whether the
added sediment loads, or possible increased phosphate levels
in the streams, will present risk to the manatee population
down river. A map should be included in this portion of the
environmental statement showing the mine site in relation to i
the rest of the county. Without this type of map, we were ^
unable to determine how far this mining operation would be
from designated critical habitat of the mantatee on both the
Manatee and Little Manatee River.
We appreciate the opportunity to review this statement and
will be glad to provide any needed assistance in the areas
where we have expressed concern.
134
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DEPARTMENT OF THE ARMY
JACKSONVILLE DISTRICT. CORPS OF ENGINEERS
P. O. BOX 4970
JACKSONVILLE. FLORIDA 32201
SAJEN-EE
19 December 1979
Mr. John E. Hagan III
Chief, EIS Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
Corps of Engineers comments on the Draft Environmental Impact Statement
for Estech General Chemicals Corporation Duette Mine, Manatee County, are
confined to matters within the Corp's functional area of responsibility,
and are presented below:
1. Statement on page 58 is that downward leakage into the Floridan
Aquifer occurs continuously throughout the project area. On page 139 is *
the statement that there is minimum recharge on the proposed mine site. ?
Clarification of this point is needed to answer: (a) are the affected £
wetlands "prime natural Recharge areas" (40 CFR 230.4-1 (a)(1)(vi)? and
(b) what quantitative effects on recharge function will exist after reclamation?
2. The requirements of Section 7 of the Endangered Species Act are itf
not specified accomplished. Reconciliation of the proposed action with the ®
Florida Wildlife Code on endangered species and threatened species needs •£
definition.
3. It appears that a Memorandum of Agreement with the Advisory Council e
on Historic Properties may be necessary if mining is to be permitted on the
Carruthers Mound (page 165), deemed potentially significant by the criteria i
of 36 CFR 800. w
Reference: EPA 904/9-79-044 NPDES
Application Number: FL0036609
135
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United States Department of Agriculture
FOREST SERVICE
1720 Peachtree Road, N. W.
Atlanta, Georgia 30309
1950
December 4, 1979
r
Mr. John C. White
Regional Administrator
United States Environmental Protection Agency
345 Court land Street
LAtlanta, Georgia 30308
Dear Mr. White:
We have reviewed the Draft Environmental Impact Statement (EIS) for
Sstech General Chemical Mine. The following are our comments:
1. Overall, the EIS was well written, particularly those sections
pertaining to Water Quality and Wildlife.
2. We support your recommendation on page 108 that the segment of
the East Fort Manatee River proposed for mining be left intact
as a natural functioning system.
3. On page 123, it is stated that the present longleaf pine
flatwoods have been logged, and that the canopy covers less than
10% of the site. With this fact in mind, we would agree with n
your statement on page 128, that "Timber values are presently •
small." However, we would add that the timber values are only £
small because the timber stands are understocked. Under
intensive management, timber values would be substantial.
4. On page 128, it is stated that the "Reclamation is designed to
replace most natural land communities with improved pasture."
We do not feel that the impact of this action is adequately
assessed. For example, the table on page 127 shows that almost
5,000 acres of longleaf pine flatwoods will be converted to •
pasture. In the absence of site specific facts, assume that the £
average production of timber per year through a rotation is 150
board feet per acre per year, or 750,000 board feet per year on
5,000 acres. The gross stumpage revenues would be approximately
$100,000.
We recommend that the Final EIS contain an evaluation similar to the •
one above. It would also be helpful if the outputs expected as a (
result of conversion to pasture were calculated, and the two results £
compared.
136
6200-11 (1/69)
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2
Attached are seme basic facts concerning timber production in
Florida's Multi County Planning District #8. The project area is in
this district. Should you require information in greater detail, we
recommend that the State Forester's office in Tallahassee be
contacted.
Thank you for the opaortunity to review the Draft EIS.
NOTE: The "basic facts concerning timber' production"
referenced, above are not included herein due to
the volume of the material. The attachments
are on file at the EIS Branch offices of the
U. S. Environmental Protection Agency, 345
Courtland Street, N. E. 3 Atlantas Georgia
30365.
Area Director
Enclosure
cc: State Forester, Florida
Dave Ketcham, WO
137
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
State Office, P. 0. Box 1208, Gainesville, FL 32602
November 20, 1979
John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agenpy
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
RE: Draft Environmental Impact Statement
Estech General Chemicals Corporation
Duette Mine
Manatee County, Florida
We have reviewed the above subject draft statement and offer the following
comments.
On page 128, paragraph 3, it is stated that "the significance of mining
will be substantial loss of natural upland habitat and a substantial
gain in improved pasture." Although animals may move temporarily from
active mining areas to adjoining range, as pointed out, the net result
is a loss of the population displaced. Regardless of the size of the animal,
the area will not provide much suitable wildlife habitat after reclamation.
It is acknowledged that hunting is an important form of recreation in the
region. Therefore, it appears that more thought should be given to the
restoration of some wildlife habitat. Developing some diversity in topogra-
phy and plant life would provide both aesthetic and wildlife benefits, and
would be less costly to reclaim than the land use now planned.
We appreciate the opportunity to review and comment.
Sincerely,
138
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/v\
v../
Washington, D.C. S0S30
(202)377- 4335
December 11, 1979
Mr. John E. Hagan III
Chief, Environmental Impact Statement Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
This is in reference to your draft environmental
impact statement entitled "Estech General Chemicals
Corporation Duette Mine; Manatee County, Florida."
The enclosed comments from the National Oceanic and
Atmospheric Administration are forwarded for your
consideration.
Thank you for giving us an opportunity to provide
these comments, which we hope will be of assistance
to you. We would appreciate receiving twelve (12)
copies of the final statement.
Sincerely,
for Environmental Affairs
Enclosure Memos from: Norton D. Strommen
Environmental Data a:id Information
Service
National Oceanic and Atmospheric
Administration
Gordon Lill
National Ocean Survey
National Oceanic and Atmospheric
Administration
y- )
138
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f
%
/ v
\
vsy
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
ENVIRONMENTAL DATA AND INFORMATION SERVICE
Washington, D.C. 20235
Center for Environmental Assessment Services
November 28, 1979
D24:NS
TO:
FROM:
SUBJECT:
PP/EC - R. Leh
OA/D24 - No:
DEIS 7910.12 - Estech General Chemicals Corporation; Duette Mine
Manatee County, Florida
Specific Comment:
Page 31, paragraph 5: The EIS states that the average annual wind
speed is 7.3 knots (3.75 mis; 6.3 mph). The last number in paren-
thesis, however, is not equivalent to the other values; 7.3 knots
equals 8.4 mph, not 6.3 mph.
(RF: D. LeCante, D242)
140
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1/
2>
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL OCEAN SURVEY
Rockville. Md. 20852
i: b 0A/C52x7:SKM
TO: PP - Richard L. Lehman
FROM: OA/Cxi
ichard L. Lehman^ .
-------
MARY L. JELKS, M.D.
PEDIATRICS
1700 SOUTH OSPREY
SARASOTA. FLORIDA 33579
TELEPHONE (813) 366-2002
Nov. 28, 1979
(Dl PLOMATEOF AMERICAN BOARDOf PEDIATRIC.
(DIPLOMATS OF AMERICAN BOARDOF ALLERGY AND IMMUNOLOGY)
John E. Hagan III
Chief, EIS Branch
EPA Region IV
345 Gourtland Street, N.E.
Atlanta, Ga 30308
Estech General Chemical Duette Mine
Policies that would encourage rapid phosphate mining in Florida
today should consider the very rapidly changing economic international
stresses. Since our main positive product in the world trade is our
agricultural exports and these are a result of our farming practices
with the use of fertilizers, we should be concerned about d^pletionr-of
our phosphates. It may be of more value in our land undeveloped than
to be so eager to place it into foreign markets, competitively priced.
In the near future the lands that we hold in central Florida may be
of more value as they are now, than the little profit gleaned plus
the very lessened value after expensive recommended reclamation.
A third area of stress, I can foresee in the future will be a shortage
of cheap water resources, and this again will be poorly managed in a
policy of allowing rapid phosphate mining now.
In the ElS draft there are questions:
1.2 I question that the water management plan can recharge the
Floridan Aquifer without contaminating it.
2.2 last paragraph—How can annual S02 emissions be the same for
alternative one and two, with 1.5 million TPY and 3.0 Million TPY, respect. •
«4
Q»
l
*
10
01
2.3A The Case 2 seems the most credible plan, since the loss of the
East Fork Manatee R. is not acceptable in case 1.
0
0»
1
*
0»
I
*
CO
01
I
*
2.11 Rock drying alternatives should be considered. The energy saving
at the foreign destination is not relevant to the US and the expense
and pollution generated by rock drying is unacceptable. The company is -
pretty flip about lung dosage radiation near rock dryers when actually we
are not very knowledgeable about these factors, since they are only now
being studied. Also the ambient radiation released from phosphate rock
mining and gypsum ponds and tailings has not been adequately studied.
According to Donald Guthrie and Sam Windham(Polk Co. Eng and EPA Montgomery!
there is considerable radioactivity and it continues for a number of
years after abandonment of mining. Studies of radiation are in process and
as this knowledge is developed, it should be allowed to alter any decisions
that are made and strategies to curtail radiation dispersed. (For
instance, neutralization of the acidity would decrease the release of
radioactivity). The art of storage of the piles of waste gypsum needs
further regulation. In 1975 a sinkhole opened up beneath a gypsum pile
and dumped the radioactive contents into the underground Florida Aquifer from
which many wells obtain water. The Brewster incidence of lung cancer has
challenged the attitude of the phosphate industry in regard to the
absence of serious health effects. The statement of some employees that
142
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some of the more hazardous esposure jobs were not regular employees ?
but done by contract and follow up has been difficult, statistically. *
8
4.2 The weight values of the TSP may not give as serious a picture as
we might understand if we knew the type of particles, size, and ^
radioactivity and chemical variety. Technology has not come to grips
with this measurement yet but I suspect TSP fromthis activity is worse than
TSP of same amount weight from some other industries. i
•f ^
4.2 Sulfur dioxde effects-- there is no consideration of the effects 2
of the increased energy demand and increased background from the power
sources, which again are using higher sulfur than when this draft was
drwn op—page 43 refers to usa of fual oil containing no greater than T
1% sulfur—where can they get that now.
Radiation comment* were not vary re •••wing in that nothing was mention** §
about the alpha emission which l§ soluble and also of serious concern. i
Gamma is more penetrating but the alpha gets into the air and water and ^
will be available to the population as the ore is uncovered and emission
occurs. m
The reclamation section is optimistic. The recovery of natural vegetation *
will never recur. To replant and develop these areas will take 50 years. ,T
In the meantime, what will the policy be for handling the hazardous JtP
wasteland. The slime ponds are very dangerous and the dams have had T«*,
many failures. The removal of the water from our limestone undergorund «0
will make the area more prone to collapse and dam breakage with auifer 7
contamination. We are also due to have a hurricane if the lin 20 yrs 9^
rule is true. How safe are the clay embankments to heavy rains and S
how much fluride and acid will escape with the radioactive contents? ^
Please implement the newer guidelines being developed by EPA, require
recovery of uranium and fluride, lining of the waste ponds with
impervious material, eliminate rock drying, require strict compliance with
water consumptive uses, require reclamation rules and post such
lands as hazardous until they are safe, avoid conventional slime ponds
and do not allow mining of the East fork of the L. Manatee R.
Sincerely,
M. L. Jelks, M.D.
143
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EPA Hearing on Estew (Swift), November 28, 1979, __.C, Bradenton
Hilda Quy, 1619 Palma Sola Boulevard, Bradenton, Florida 33505
I refer first to page 2, Project History, of this EIS. "Other
local, state and federal permit applications are in various phases of
development. . •" This should be corrected to show that the Manatee County
Commission last August voted k to 1 to deny the special exception applied
for by Estech. That decisipn was entirely within the authority of the local
legislative body.
Many concerned local citizens objected to the first application to
mine in our county because phosphate mining threatens our environment, our
health and our quality of life. We objected to the second, the third and the
fourth applications, citing cumulative, increasingly dangerous effects. When
Swift, the fourth company,applied, our County Commission denied the permit,
in our opinion weighing the significance of the cumulative effect of several
mines.
Nowhere in this EIS do I find reference to this factor. I ask you,
the United States Environmental Protection Agency, at what point you would
be concerned with the cumulative effect of an industry you know to be
hazardous? At the 10th mine? The 100th? When a dragline has walked over
^square^
every/inctf of vacant land in Manatee County? Our local governing body has
said "this far and no farther". How can you, the Environmental
Protection Agency do less? How can you ignore the total environment?
Second, I question the objectivity of Conservation Consultants, Inc.
which has prepared part of this report. This company is employed by Port
Manatee whose present and potential profitability is closely linked to
growth in phosphate shipment. This firm has a financial interest in increased
phosphate business for the Port, creating a clear conflict of interest by
participation in preparation of this EIS. In addition, the firm's employer,
the Port Authority is made up of our County Commissioners. Estech is now
involved in litigation with our County Commission. Conservation Consultants
may be incapable of recognizing a conflict of interest here but it is astound-
ing that EPA has cooperated in such a violation of professional etocs.
In fact, without commenting further, it appears that holding a hearing at
this time may well be a serious interference in the judicial process.
-------
It is impossible in a few short minutes to deal with many
substantive issues raised in this EIS, so I will simply touch on a few at
random which are symptomatic of the superficiality and bias in the document.
1. The recently completed EPA Area-wide phosphate Ely made some courageous
recommendations for improving the industry's operations in the future. Among
them were elimination of rock driers and of above-ground slime ponds. Not
requiring Estech to conform to either of these two recommendations makes a
mockery of the Area-wide study.
2. The last page of the Summary Sheet states that the operation . .
will be self-sufficient in terms of minor medical treatment, water supply,
fire and police protection, • Within the last two weeks, an explosion
and fire at the International Mining and Chemical Co. near Bradley Junction
required firefighting units from Bartow, Lakeland, Mulberry and New Wales
and foam units from McDill Air Force Base at Tampa. So much for self-
sufficiency. The taxpayer is stucK with the bill as usual.
3. Page 23, under "no-action" alternative, we read ". . .a potential for
positive impact on the United States balance of payments would be lost due
to unrealized sale of the rock product. . ." If this simplistic argument is
permitted in a supposedly serious document, an unbiased statement must add
that, with 6% of the world's population using 30$ of the world's fossil fuels,
nearly half of that imported, America's unfavorable balance of trade is due
to our excessive use and importation of oil and that, furthermore, at our
present rate of mining and exportation of phosphate, the U. S. will be
dependant on imports of fertilizer within as little as 6wo decades. Dr. Ellis
Verink, Chairman of the U. of Florida Materials Science and Engineering
Department recently said "Many indicators suggest that non-fuel materials will
represent the next national crisis for the United States." An 6PEC-type
fertilizer cartel can then hold us hostage as easily as we are held hostage
by oil producers today. You can not throw in a glib, one-sided remark about
balance of trade without some semblance of unbiased treatment of the issue.
-------
i
k. On page 103 are outlined various measures to prevent the possibility of
a settling area (slime pond) failure and release of waste clay (slimee) to
the Manatee River. These mention "design by an experienced professional
engineer. . .thorough investigation of foundation and soil conditions. . .
daily inspection by qualified representative. . .annual inspection by a
registered professional engineer. . " etc.
On February 26, 1972, 125 persons were killed when three coal waste dams
collapsed in Logan County, West Virginia.
On June 6, 1976, the Aeton Dam collapsed in Idaho, killing 11 persons.
On November 6, 1977, an earthen dam failed at Toccoa, Georgia,silling 39 persons
On October 31 of this year, the FP&L reservoir near Indiantown ruptured, flood-
ing an area three miles wide by 22 miles long.
No doubt in each case the dam was designed by a so-called"registered Professiona
engineer" who would have said the chance of failure was nil.
On page 52 of the EIS, we read that "limitations on use of the surface soils
for construction of homogeneous pond embankments are considered severe." Who
will be out there watching that none of these poor soils are used in slime
pond embankments. Registered professional engineers have been unable to
restore the Peqce River since a slime pond dam break killed it many years agq.
The truth is, dam safety in Florida is in limbo. Responsibility is ambiguously
shared among the DER, the Corps of Engineers and water districts, with inspect-
ion meagerly funded. These Estech slime ponds will contain vast quantities of
hazardous waste. The drinking water of many thousands of people is at stake
if a dam should fail.
5. A reading of Section A-.12, Biology and Ecology, leaves the impression
that even the authors of this document bleed a little. Page ikl states:
"Wilderness Area: The wilderness area will consist of spoil piles which
will bellowed to become revegetated by natural means. The vegetation of
similar sites throughout the central Florida phosphate district consists of
woodlands which do not closely resemble any indigenous plant communities
in structure or species composition." If you have seen Polk County, you know
an understatement when you hear it.
Later, we read . .The steepness of the slopes will retard the establishment
of more luxuriant vegetation. This vegetation will have a low aesthetic value.
The angle of slope will cause continual erosion in wet seasons. .
146
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I'quote the author earlier, page 51, "This area, termed "wilderness" by the
applicant, will result in permanent, parallel rows of steeply sloped island
chains in the northernmost created lake," I doubt if any dictionary so
defines wilderness.
While an entire 18-acre cypress swamp will be saved and all of 50 acres of
sand pine scrub as well, we read "it is unknown whether or not the swamps
and marches on reclaimed land will have as high a value as they presently
have. and also "Natural habitat restoration as proposed for the Swift
site has not been attempted previously". (l^O-^fl).
5. From your million dollar area-wide study, you in the Environmental
Protection Agency know the phosphate industry poses serious dangers to the
environment and to mankind. I believe you reported in June that Florida
phosphate mines pose radiation hazards to local residents that could increase
risks of lung cnacer by as much as 50 per cent. You know that Florida has
three times as much chemical waste as any other state, much of it from Polk
County's phosphate industry. It is hard to understand how you can complacently
give your stamp of approval to create more of the same against the wishes
of the people of Manatee County and our own local government. I ask simply
that you take another look at your name, the Environmental Protection Agency,
and act accordingly. TA .*f fi., dc»y -f he pe, >»,!?. i.<^ tr.t, 11.
147
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1619 Palma Sola Boulevard
Bradenton, Florida 33505
December 11, 1979
Mr. John E. Hagan III
Region IV, U. 3. EPA
3^5 Courtland Street
Atlanta, Georgia 30308
Dear Mr. Hagan:
Recent news reports indicate that the eand/clay mixing
technique, proposed by ESTECH in the Draft EIS has not
been successfully used by Brewster Phosphate Co.Please
see the enclosed editorial from the SARASOTA HERALD-
TRIBUNE, December 9, 1979.
In view of this evidence, I would like to request that
account be taken, in assessing ESTECH's application for
permits, of the probability that the company would be
led to "Case I" (pages 12-15 of the EIS) when it finds
that "Case II" is not a viable method of reclamation
of mined land. This alters the whole proposal as it
relates to the recommendations of the Area-Wide study
on slime ponds, and also as it relates to damage to the
environment and subsequently the people of this area.
NOTE: The December 9, 1979 editorial
ie on file at the U. S. Environmental
Protection Agency, Region IVEIS
Branch, 345 Courtland Street, NE,
Atlantas Georgia 30365 and is not
included herein.
Sincerely
148
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-------
J. Scott Brown
P. 0. Box 3498
Sarasota, Fl. 33578
December 7, 1979
Mr. John E. Hagan
U. S. Environmental Protection Agency
345 Cortland Street
Atlanta, Georgia 30308
Dear Sirs;
In regard to the Environmental Protection Agency public hearing
of November 28, at Manatee Junior College: I would like to consider
the ultimate "reclaimed" condition of S-Techs* Duette mine.
The proposed Duette mine is presently very productive land. It
consists of palmetto and pine flatwoods and hummock, wetlands.
This land supports healthy populations of Deer, Turkey, Hogs and
many other game and non-game animals.
The agricultural use of the lands include cattle production, citrus
groves, tomato and watermelon farms.
The wetlands on the proposed site are shallow and seasonally dry.
The ponds are never more than six feet deep and usually average closer to
six inches in depth.
These wetlands are very productive in terms of wildlife. They sup-
port a fantastic variety of birds, small mammals, reptiles and amphibians.
Not known for large fish, these areas do produce a large volume of small
fish and invertebrates, which form a major part of the food web.
S-Tech proposes to leave certain sensitive hummock and swamp areas
unmined. They also say valuable new wetland habitat will be created by
mining. S-Tech admits that a large percentage of the land will be left
in the form of spoil banks. What remains is for reclamation.
The process of mining will destroy all the natural stratification
that exists down to a depth of one hundred to two hundred feet. Gone
will be the impermeable and permeable layers that give the land its water
holding characteristics. Because of this, land that is eventually re-
turned to native grade and replanted would be unable to hold water nor-
mally.
150
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The areas that S-Tech does not mine will be surrounded by mining
activity. When a swamp or a hard wood hummock suddenly becomes a mesa,
what is going to stop it from drying out?
The valuable wetlands S-Tech proposes to create will likely be huge
pits. Deep and slab sided, this type of lake wouldn't have the product-
ive shallows of natural wetlands. Without any rooted bottom life there is
not any basis for a food web. Only floating plants could exist, such as
water hyacinths.
Twenty years hence, when mining is complete, the dense rank growth
that colonises disturbed land will have taken over. Palmetto and pine
will be replaced by dog fennels and briars; hard wood hummock, that for-
merly provided wildlife with food and shelter will be replaced by the
very undesirable exotics, melalucca, Brasilian pepper and Austrailian
pines.
If mining proceeds as planned, we will be left with unusable and un-
reclaimable spoil banks, land vegetated by exotics, leaving it of little
practical use, and lakes that will be largely steril except for water
hyacinths. If reclamation can not be more complete than this, a phosphate
mine is not justified.
Bachelor of Science Biology
Sarasota, Florida
151
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'Robert, A XqiKM
REG. REAL ESTATE BROKER / TELEPHONE: 747-5855
755-8790
5422 — 26th STREET, WEST
BRADENTON, FL 33507
November 28, 1979.
Mr. John E. Hagan III
Chief, EIS Branch
Environmental Protection Agency
Region IV
3^5 Courtland Street, N.E.
Atlanta, GA 30308
Rei Environmental Impact Statement
Estech General Chemical Corporation, Duette Mine, Manatee
County, Florida Draft EPA 90^/9-79-0^ October 1979
Dear Mr, Hagani
The above document has been received from Mr. John C. White,
Regional Administrator to me as a concerned individual.
This document and the resource documents have been
reviewed, with Interest. The following comment is respectfully
submitted.
These voluminous documents have the potential of being
good references for economic and academic uses. However, there is
need for corrections, revision, and more clarification in the agri-
cultural presentations.
This is important as the highest and best use is agri-
cultural and will continue after mining. It is currently a high
potential for the future needs of more intensive uses and yields.
You can and should correct and improve your documents
by becoming Involved with personalized direct exchanges with local
agencies for basic and common information as well as potential
planning. This includesi
Land and Water
Forestry
Economics
Roads
USDA Soil Conservation Service
Forest Service, State of Florida
Economic Research Department
IFAS, University of Florida
Manatee County
This includes pages 120,122,123,128,138,139,157. The
subjects presented are too diverse and voluminous for any one
individual or agency to adequately revieafor present.
Thank you for this opportunity, to show my concern.
cci List attached
Vgry, truly^yours,
Robert A./xyman
-------
page 2
Mr. John E. Hagan III, EIS Branch, EPA November 28, 1979
cci List
Louis E. Drlggers, Chairman, Manatee County Commissioners
Court House, Bradenton, Florida, 33505
I.H. Stewart, District Conservationist
U.S.D.A. Soli Conservation Service
P.O. Box 965
Palmetto, Florida 335&1
J. Walter Prevatt, Extension Area Economist
University of Florida
Institute of Food and Agricultural Sciences
5007 60th Street East
Bradenton, Florida 33508
George Montgomery, III, County Forester
Florida Department of Agriculture
& Consumer Services
1*723 - 53rd Avenue E.
Bradenton, Florida 33508
Dr. C.W. Hendry, Chief
Bureau of Geology
903 West Tennessee Street
Tallahassee, Florida 32303
153
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ManaSota
A Project for Invironm«ntal C
88
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c*^~- s-t. * °Q
ef ^ *4"^' y '\
-j— —^ ^ -s— /Us 1
/ j CU *~zL ^
Uj^j cj <£>>- Jl&S
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Cjl ^7^
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154
-------
<
t
the trnnsCor point between the inclined conveyor belt and the
elevated conveyor belt and for various placet; above urtd around
the storage pile. Ho water sprays h;>ve been planned for spray-
ing into the ships' holds. To catch sulphur dust, U-shaped
concrete beds are planned for underneath all of the conveyor
belts and the head pulleys of all conveyors are to be equipped
with scrapers.
In support of its application, Agrico caused estimates
of sulphur dast emissions from the proposed facility to be made.
The only emissions considered, however, were those to be
anticipated as a result of sulphur falling from the elevated
conveyor belt onto the stockpile, wind erosion of the stock-
pile, vehicular traffic around the stockpile and scooping from
the stockpile by front ena loaders. Tho great bulk of the cmin-
sions reasonably to be anticipated and a substantial majority
of the proposed omission points, including tho moist significant
emission pointSj^were omitted from consideration, Those omis-
sions went unnoticed by the DEU personnel who recommended J
issuance of a construction permit to Agrico.
In preparing emission estimates for submission to
DER, it was assumed that prilled sulphur would have an emission
factor comparable to the emission factor for aggregate. Sub-
sequently, other experts assumed prilled sulphur would have
an emission factor like coal's. Making such assumptions 1b
acceptable methodology in the absence of information about a
particular material but the possibilities for substantial
prror are significant.
Dusting properties vary even among different types
of sulphur prills, depending on, among other things, their
friability, method of manufacture, moisture content, and the
distribution of particle sizes. Water formed or "wet" prills
are produced by introducing drops of molten sulphur into a
stream of water or a "quench tank"; nir formed or "dry" prilling
techniques use air to cool drops of molten sulphur, transforming
8
22
155
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ManaSota - 88
A Project lor Bnvironmontal Quality 1968 - 19
November 2^, 1979
Mr. John E. Hagan III
Chief, EIS Branch
U.S. EPA, Region IV
3^5 Courtland St. NE
Atlanta, Ga. 30308
Re i Estech. EIS
Dear Johnj
I am not quite sure my request to withhold a decision re: the
issuing of the Estech permit, if indeed this is the agency's
desision, until all litigation has ended rei Estech was clear.
What I intended to convey is the prejudicial effect even the
announcement of intent to issue a permit could "be expected to
have-on the outcome of pending litigation.
We would certainly hope such action is withheld by EPA.
Additionally, quite frankly until many serious issues raised
res this EIS are settled, we do not see how EPA could even
contemplate the issuance of such a permit.
Thank you for your interest.
Sincerely,
Rains
Chairman
Replyj531^ Bay State Rd.
Palmetto, Fl 33561
c» Mr. Perry
Gloria C.
156
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MIIIET Mniwuwuu
SVWrl CHEMICALS
December 10, 1979
An Estedl Company
Mr. John E. Hagan, III
Chief, EIS Branch
United States Environmental
Protection Agency
Region IV
345 Courtland Street NE
Atlanta, Georgia 30308
Re: Estech General Chemicals Corporation
Duette Mine, Manatee County, Florida
Draft Environmental Impact Statement
(EPA 904/9/79/044) and Draft
NPDES Permit No. Fl0036609
Dear John:
The following comments are submitted on the above-referenced
draft environmental impact statement (EIS) and draft NPDES
permit in response to the public notice dated October 5, 1979.
Estech General Chemicals Corporation (Estech) is the permit
applicant in this case and has proposed the activity that is
the subject of the draft EIS. Accordingly, Estech is a vitally
concerned member of the public.
Estech supports the overall analyses, conclusions and recommen-
dations concerning proposed action set forth in the draft EIS.
The document represents many months of intensive effort by
numerous expert consultants and is a significant contribution
to the public's understanding of impacts, mitigating measures,
and alternatives pertinent to the phosphate rock mining and
processing industry in Central Florida.
Estech is disappointed that EPA has tentatively proposed to
include in the final NPDES permit the condition that no mining
is to be carried out in that portion of the East Fork of the
Manatee River designated as "Class I Wetlands". Estech is con-
findent that mining the valuable resources located beneath this
segment of the river could be carried out without significant
long term adverse environmental impacts. Indeed, Estech's
plans would have required demonstration of an effective program
Swift Agricultural Chemicals Corporation
First Commercial Bank Building - Suite 27S
410 Cortez Road West
Bradenton, Fl. 33507
Tel: (813) 758-8688
-------
Mr. John E. Hagan, III
Page 2
December 10, 1979
for the relocation and restoration of the stream bed prior to
beginning mining. Furthermore, Estech has serious reservations
concerning the authority of the Agency to insert "dredge and
fill" type requirements (especially an absolute prohibition)
in an NPDES permit. Estech has, however, elected to acquiese
in the proposed action of the Agency in light of its need to
commence mining operations at the earliest time consistent
with applicable laws and regulations.
Prompt further action, including preparation and issuance of
the final EIS and final NPDES permit, is of extreme importance
to Estech. Estech made initial contact with the Agency concerning
this project in November, 1977. After discussions with the
Agency, Estech elected to use the "third party" approach for the
preparation of a draft EIS in order to avoid unnecessary delays
in the process. Now, two years later, after the expenditure of
nearly $500,000 by Estech for the preparation of the draft EIS
under EPA supervision, there is some indication that the Agency
may be considering deferral of final action on NPDES permit
issuance pending the resolution of local land use matters. Such
deferral can only lead to additional potential delays in the
permitting of this project. Such delays would be severely
detrimental to Estech because of binding commitments to supply
phosphate rock to customers. Estech must obtain all necessary
construction approvals and permits by June of 1980 in order to
meet an already very tight construction schedule.
Estech is committed to compliance with all applicable federal,
state and local environmental and land use requirements when
properly interpreted and enforced. All parties with the necessary
standing should be afforded ample opportunity to present their
views on the proposed Duette Mine in appropriate forums. Estech
believes, however, that this time should be spent in considering
the merits of the issues. No time should be wasted on purely
procedural grounds. Deferral of final action in the NPDES permit
is very likely to lead to such waste.
Estech believes that proposed major industrial developments such
as phosphate rock mine and beneficiation facilities should undergo
thorough preconstruction environmental review and approval pro-
cedures. These procedures, however, should proceed expeditiously
and should not result in inordinate delays in needed industrial
development.
158
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Mr. John E. Hagan, III
Page 3
December 10/ 1979
Over the last two years, inflationary pressures have resulted
in a 15% annual increase in the costs of building materials,
labor and equipment. The proposed Duette Mine is a $160,000,000
Project. This means that every month of delay in commencing con-
struction will add in excess of $2,000,000 to the overall costs
of this project. The Agency must not be a party to any un-
necessary delay resulting in such massive, wasteful and inflationary
cost increases.
It is clear that final action by the Agency on the NPDES permit
will not preclude state or local officials from carrying out
their appropriate mandates under applicable laws. Section 510,
Clean Water Act; 40 C.F.R. § 122.11(d)(3). On the other hand,
pending local issues should not be allowed to preempt federal
action on matters expressly made subject to federal review.
Estech urges the Agency to move with reasonable speed to respond
adequately to public comment, to formulate the final EIS, and
to issue a final NPDES permit authorizing a waste water discharge
subject to appropriate terms and conditions in accordance with
applicable regulations.
Sincerely yours
ESTECH GENERAL CHEMICALS
CORPORATION
JED/nal
cc: Mr. John C. White, Regional Administrator
Charles Perry, Esq., Regional Counsel
159
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ASSOCIATION, INC RO. BOX 1333/SAMSOn, FLORIDA 33578
Fred. C. Duisberg
Rt. 1 Box >-6
Englewood, Fla.
33533
Dec. 1|., 1979.
PRESIDENT
Ffsd C. Duisberg
VICE PRESIDENT
Dante Vezzoli
SECRETARY
Joseph F. DeNtnno
TREASURER
JohnL. Engete
^y/C. AJflt—^
GeageH. Anner
Samuel B. Appiebaum
EknarG. Berwl
Capt. Wm. B. Bernard
Gouge A. Bishopric
T.Mabry Carlton. Jr.
EkMgeCanws
Jerome Chambers
Chartes R. Covert
.Mrs. Agnes Cowap
.Joseph F. OeNinno
.Fred C. Duisberg
John L. Engete
Gen. Arnold Funk
Homer Greer
Ansel E. Grfdley
J. Randall Grobe
Franldin H. Graf
James A. f '
Ms. Anita Hocker
Carton Johnson
Robert M. Johnson
Dr. Karl Keeier
,Ms. Mary Kumpe
M^Wmed A. LePage
C«rtyleA. Luer, M.D.
.RiertMaas
t John Malpezzi
.Mrs. Jeanne McElmuray
UmlmMmw
Christy Payne, Jr.
WikamE. Pensyl
Edward Patrick
JtmathanPuah
W. Robinson
Mis. Rita Roehr
TflnySaprito
.ynyS^no
IttSperitag
A MwnTlflany
Cot. Dante Vezzotf
,|r
-------
Exhibit 11
RESPONDENTS'OPINIONS REGARDING
REGULATION OF PHOSPHATE MINING AND
PROCESSING PENDING THE ESTABLISHMENT
OF ASSURED SAFEGUARDS THAT MAY IMPACT
ON THE ENVIRONMENT OF SARASOTA COUNTY
VIGOROUSLY OPPOSE THE PHOSPHATE
MINING AND PROCESSING ISSUE AS IT
MAY AFFECT THE ENVIRONMENT UNTIL
ASSURED SAFEGUARDS ARE
ESTABLISHED
100%
82%
BE CONCERNED WITH ISSUE TO ONLY
A MODERATE DEGREE I 13%
CONSIDER ISSUE TO BE OF ONLY _
MINOR IMPORTANCE
NO ANSWER
161
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Exhibit lO
RESPONDENTS'PERCEPTIONS OF THE
PHOSPHATE MINING AND PROCESSING
ISSUE AS HAVING AN IMPACT ON
SARASOTA COUNTY'S ENVIRONMENT
100%
VERY DETRIMENTAL
SOMEWHAT DETRIMENTAL
SLIGHTLY DETRIMENTAL
OF NO CONSEQUENCE
NO ANSWER
63%
23%
8%
5%_1 %.
162
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UNfcLSEN COMPANY
XXV
IX. Phosphate Mining And Processing Is Perceived As Being Very
Detrimental To The Environment And The Issue Should Be
Vigorously Opposed Until Assured Safeguards Are Established.
Exhibit 10 reveals that 63% view phosphate mining and
processing as having a very detrimental Impact on the
environment in Sarasota County. This composite percentage
compares with 42% among those Individuals who have lived
in Sarasota County for less than two years (Table 49).
The strong opposition to phosphate mining and processing 1s
further demonstrated in Exhibit 11, where 4 out of 5
individuals are reported to be vigorously opposed to the
Issue until such time as environmental safeguards are
established. Although still constituting a majority opinion
1n terms of vigorous opposition, the part-time dents
(73%) as well as those who have lived 1n the county for less
than two years (70%) are slightly less opposed than are the
respondents 1n composite. (Table 50)
X. Open End Comments (Table 56)
The last question 1n the survey instrument was open-ended 1n
nature. Specifically, the respondents were requested to offer
any advice or comments concerning the future of Sarasota County
which may not have been covered 1n earlier sections of the
questionnaire. Fifty-seven percent elected not to answer this
question. Among the remaining 43% who did answer, the most
Important comments are cited as follows:
163
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Sarasotans Favor Regulated Groivth, Poll Shows
JW» J 3 197)
By JOHN HEILSCHER
HeraM-Tribaae Reporter
An overwhelming majority
.or Sarasota County residents
favor a related annual r>te
of population growth, stricter
air and water pollution con-
trols and leaving the airport
at its present location, accord-
ing to a sew smtj oq local
matters.
Most people surveyed fed
living cooditinas here have de-
teriorated ow the years and
government should use taxes
to improve services for cur-
rent, and not future, residents.
The Save Our Bays Associ-
ation i SOB A) presented
4a»
tensity of local feelings on the
Issues appears stronger than
anticipated.
For example. 99 percent of
the respoodants approved
restrictions on population
growth, it percent want a
regulated growth rate, 97 per-
cent favor stricter enforce-
ment of zoning controls, 91
percent opposed development
of wetland areas and 91 per*
tCootlmed frem P*ge IA)
opinions on current and future
issues, using a five-point
"favor-oppose" scale to
measure the intensity of at-
titudes. Suggested courses
o( action lor government to
employ were also measured.
And the results show that
residents want tougher con-
trols on development, better
water services, consolidation
of some city-county services
— in a nutshell, they want the
best quality of life possible.
"Seventy-three percent are
of the opinion that living con-
ditions in general are cur-
rently less satisfying than in
the past while 5 percent of
(fee residents claim their Ur-
leg situations are better now
than formerly,'* the report
said.
Police and fire protection,
drinking water service, air
travel and sewer service were
rated as at least the same or
slightly better than before.
But parks and beaches, re-
sponsiveness of county " gov*
erament, boating conditions,
the local tax situation, bay
water quality and air pollution
were ail rated between the
same and worse than before.
Vehicle traffic was gives the
lowest rating
Most respondants want a
county wide, "pay-Us-way"
public transportation system,
the surrey indicated. Almost
19 percent said they strongly
or moderately favored county-
wide public transit, but 31 per-
cent said they might or might
not use it. It percent said they
"probably" would not use it
and i percent said they "de-
finitely" would not
Centralized control of water
and sewage disposal was pre*
tend by nearly a 3-to-l mar-
cent want tougher pollution
controls for Sarasota Bay.
Regarding phosphate min-
ing, 97 percest said they were
against it until assured of ade-
quate safeguards from pol-
lution. Only 3 percent dismis-
sed mining as of sunor con-
cern. Eighty-four percent said
they vigorously opposed phos-
phate mining »hile 13 percent
were moderately against.
gin over non-centralized con-
trol. the report showed.
"Sixty-eight percent of the
respondants believe the resi-
dents of Sarasota County
would be better served with
centralized control of drinking
water and sewage disposal
facilities,"" the survey said.
Nine out of ten voters said
the county must be concerned
with controlling present
growth patterns.
"When confronted with two
statements regarding whether
the present patterns of growth
in the county should be main-
tained or controlled, 90 per-
cent expressed their opinion
that coo trolling must be a
matter of concern," the sur-
vey said.
Nine percent said available
resources should be used to
maintain present growth
while 1 percent had bo answer.
More than three out of four
respondants said programs
and available revenues should
be used for the "maximum
satisfaction" of current rest*
dents, while only 20 percent
favored using money and pro-
grams to provide essentials for
as many residents as choose
to live here.
Phosphate mining and relat-
ed processes were perceived
as being "very detrimental"
to the environment and they
should be vigorously opposed
uaul safeguards are provided.
Sixty-three percent said phos-
phate mining was "very detri-
mental." 23 percent said it was
"somewhat detrimental," I
percent chose "slightly detri-
mental." S percent said it was
of "no consequence" and I per-
cent had no answer.
A whopping O percent
vigorously opposed mining
and processing effects until
assured protection Is estab-
And SS percent of (hose sur-
veyed prefer upgrading the
Sarasota-Bradenton Airport at
its present home with 16 per.
cent apung for relocation and
enlarging the facility. Ooe
percent gave no answer
SOW. President Fred Duls-
berg and former president
Claries Covert presented the
re*au. which are divid-
ed into as overall summary
» percent expressed
concern "only to a moderate
degree." 4 percent considered
it of "minor importance'' and
1 percent had no response.
The questionnaire also ask.
ed for ratings o* l»
which might apply Sarasota
County. Responses were based
on a one to five point Kale,
with one strongly opposed and
five strongly in favor. Some
examples and typical answers:
—Restrictions on population
growth. More than » percent
said they strongly fevored
23.1 percent moderately favor-
ed. 1.4 percent neither favored'
nor opposed, 5 2 percent mod.
erateiy opposed and 14 per-
cent strongly opposed.
-Stricter usurtnee o{ ade*
We water supftes. Almost
* percent strongly favored,
7 J percent moderately favor-
od. 1.7 percent had do opinion,
9.4 percent moderately oppos-
ed and 9.4 percent strongly
opposed.
—Consolidation of some city-
county services. Over 41 per-
cent strongly favored 25 9
percent moderately favored
I7.« percent neither favored
or opposed. » percent were
moderately against and 1.4
percent strongly opposed.
— Stricter enforcement of
awing controls. Here 73.1 per-
cent strongly suj^orted. 15.4
percent moderately favored,
7.1 percent had no comment,
1-3 percent moderately oppos-
ed and 2 percent was strongly
against
—Legislation requiring ser-
vice efficiency (water, sewer,
electricity, etc.) before new
housing projects are appro-
9d. More than IS percent
strongly favored, 13 percent
moderately favored, M per-
cent didn't feel either way, .7
percest noderatdjr opposed
of attitudes and a detailed
breakdown of the Issues to
demographic characteristics.
"The response to the survey
has been overwhelming, the
answers have been crystal
dear." Coven said.
"Until now, none of us had
the privilege of knowing what
was in the minds of the voters
of this county," he said, "ta
view of these startling results,
and 12 percent strongly op-
posed.
—Stricter air pollution con-
trols. Sixty percent were
strongly in favor. 24.S percent
moderately approved. 11 per-
cent neither favored nor op-
posed, 1.9 percent moderately
opposed and 1 percent strong-
ly opposed.
—More public beaches. More
than 33 percent strongly favor-
ed. 23.4 percent moderately
favored. 30.4 percent had no
opinion. 9.2 percent were
moderately against and 4.7
percent strongly opposed.
—Regulated annual rate of
population growth. More than
99 percent* said they strongly
favored, 29.7 percent moder-
ately favered. t»-l percent
were neither In favor nor o^
posed. 2.7 percent were mod-
erately opposed and 19 per-
cent were strongly against
—Limiting local taxes. Al-
most 41 percent strongly sup-
ported. 232 percent moder-
ately favored. 19.9 percent
bad" no opinion, II percent
were moderately opposed and
1.2 percent were strongly op-
posed.
—Limiting height of residen-
tial buildings. About 74 per-
cent strongly supported, 12.1
percent moderately favored,
9-2 percent made no choice,
11 percent were moderately
opposed and 1.7 percent were
strongly against
—County tax monies used
for the purchase of land for
environmental purposes. Here
45.C percent strongly favor-
ed, 8.1 percent moderately
favored, 13-4 percent neither
supported nor opposed. S.7 per-
cent were moderately against
and S.I percent strongly op-
posed.
—Stricter water pollution
controls aimed at making
Sarasota's bay waters suitable
for shell-fish taking. More than
77 percent strongly favored,
14.1 percent moderately favor-
ed. 9.3 percent had no feelings,
9.7 percent were moderately
against and O S percent were
strongly opposed.
Sarasota County has been
given a one-year extension to
submit its Comprehensive
Plan to the slate, which means
the document is not due until
July. 1990. County officials
already have indicated they
plan to take a hard look at the
SpSA results.
SOBA has offered to fur-
ther discuss the report with
the commission or other
county officials. Copies of the
survey wiD be at the Selby
Ubrarv for nubile Me.
there seems a real question
whether this county can con-
tinue on without a solid re-
striction on the rate of growth
and a strict enforcement of
established loning."
SOBA spent about S12.SQ0 to
have the A. C Nielson Co.,
the world's largest research
organization, compute and
analyse the responses of about
1500 residents. A question-
naire was sent out In J{ie£4»
oofrJifth, or about 20,009. of
the registered voters.
County commissioners took
no action on the report since
they bad no time to read it,
but the information could be-
come part of the developing
Comprehensive Plan for Sara-
sota County.
The qoesdocaaire sought
(Please Tarn To Pg. 14A, Cat 1)
-------
November 7, 1979
Environmental Protection Agency
401 M Street, SW
Washington, D.C. 20460
Dear Gentlemen:
This letter Is In response to the Federal Register (44 FR
54870, September 21, 1979) concerning a proposed rule to limit
particulate emissions from new, mod IfIed,annd reconstructed phos-
phate rock plants.
As you may be aware, the environmental compatibility of phos-
phate enterprises In Florida Is of deep concern to Florida Audubon
Society and of direct Interest to thousands of our members who live
In close proxiMi+ty to the central Florida phosphate producing area.
Exceptional air cleanliness Is one of the assumed natural
assets of our state. For many Florida citizens, the clean air Is
more than a pleasant amenity but Is critical to survival.
Airborne particulates are a respiratory aggravation In general;
but, even If the partlcAtats, of Itself, Inert, It may carry
carcinogenic substances the particle surface;oroth*he
Inert particle may "promote"m«iif§gagjb?y In many cells that have b
been previously "Induced" to a pre-ma11gnant or neoplastic state.
Thus, we In Florida view your Initiative to Improve particulate
aatielons rates as being In our best Interest and we urge you on.
I note with a sense of confidence that thoogfch"#e*tc«o«bltfg9"
techniques, phosphate companies can achieve high standards In this
realm of air pollution control without great duress. In fact,
containing rock dust may be to the companf's advantage: As I am
often reminded, phosphate dust escaping the crusher represents
a loss of "product1', a loss of profit potential.
Clean air will benefit all elements of society.
SIncereIy,
Archie Carr III, Ph.D. — Special Assistant to the President
06-A >'
165
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tompo boy
regional
planning
council
December 11, 1979 \ / //
9455 Koger Boulevard
St Petersburg. FL 33702
(813) 577-5151/Tampa 224-9380
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street NE
Atlanta, GA 30308
Dear Mr. Hagan:
Subject: TBRPC Clearinghouse Review No. 75-79; Duette Mine,
Manatee County
Please find enclosed a copy of the final report on the above referenced
project. I am also enclosing a copy of a transmittal letter from TBRPC
for the unsigned final report. Signed reports are not accompanied by
transmittal letters.
If you have any questions, do not hesitate to contact me.
Sincerely,
Ann M. Pytynia
A-95 Coordinator
AMP/jIs
Enclosures
Chairman Michael Ledbetter Vice-Chairman Louis Driggers Secretary/Treasurer Frederick Allen Scott D. Wilson
Commissioner, Pasco Courtly Commissioner, Manatee County Councilman, City ot Gultport Executive Director
Bradenlon • Clearwater • Dade City • Dunedm • Gultport • Largo • New Port Richey • Oldsmar • Palmetto • Pinellas Park • St Petersburg • Sarasota • Tampa • Tarpon Springs
166
Hillsborough Manatee Pasco Pinellas Counties
-------
'Z/S/77
CH Review #75-79; Duette Mine EIS, Manatee County
CUMUMSHOUSE REVIEW
The United States Environmental Protection Agency in Atlanta has submitted an Environmental
Impact Statement for the Estech General Chemical Duette Mine in Manatee County.
This document was found to be regionally significant and consistent with TBKPC goals and
objectives. The adopted Future of the Region states that it shall be one policy of the
Council to preserve and restore natural lands. The EIS was also found to be consistent
with the Council's criteria described in the Areawide Water Quality Management Plan and
the Development of Regional Impact report compiled by the Council in November, 1978.
Estech Corporation should be commended for committals expressed in terms of current
technological alternatives in the areas of reclamation. There are no objections to the
EIS.
Committee adopted November 26, 1979.
Clearinghouse Review Committee
Elease note: Unless otherwise notified, action by Clearinghouse Review Committee is
final. Append copy to application to indicate compliance with clearinghouse requirements
Comments constitute compliance with OMB Circular A-95 only.
Local Comments
Manatee County Planning Department: No comment as of November 21, 1979.
Council Comments and Recommendations
tompo bay regioftpl planning council
9455 Koger Boulevard St. Petersburg, FL 33702 (813) 577-5151/Tampa 224-9380
-------
November 14, 1979
Mr. John E. Hagan III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
Subject: TBKPC Clearinghouse Review NO. 75-79; Duette Mine,
Manatee County
Please find enclosed a copy of the unsigned final report on the
above referenced project. This project will be reviewed by the
Council's A-95 Clearinghouse Review Committee at 8t30 a.m.,
November 26, 1979 at the Council offices.
If you should have any questions, do not hesitate to contact ne.
Sincerely,
Ann M. Pytynia
A-95 Coordinator
AMP/pfcv
Enclosure
168
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FERTILIZERS & AGRICULTURAL CHEMICALS
RONALD L. JONES
Corporate General Counsel
December 7, 1979
Mr. John E. Hagan III
Chief, EIS Branch
United States Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
Please find and consider the attached comment from the Royster Company
with respect to the Draft Environmental Impact Statement referenced above.
Since Royster intends to be a joint venturer in the Duette Mine project so
that we can replace our existing source of phosphate rock due to expire in 1983, we have
a vital interest in a favorable Environmental Impact Statement.
Please contact Mr. Robert W. Heinz at our Mulberry, Florida plant or m©
if we may be of assistance.
RE: EPA 904/7-79-044. NPDES Application Number: FL 00366O9
Draft Environmental Impact, Statement for Proposed Issuance
of a New Source National Pollutant Discharge Elimination
System Permit to Esteoh General Chemicals Corporation
Duette Mine, Manatee County, Florida '
y— *-¦'
RLJ/aft
Enclosure
169
-------
TO: United States Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
FROM: Royster Company
P. O. Drawer 1940
Norfolk, Virginia 23501
COMMENTS RE: EPA 904/7-79-044. NPDES Application Number: FL 0036609
Draft Environmental Impact Statement for Proposed Issuance
of a New Source National Pollutant Discharge Elimination
System Permit to Estech General Chemicals Corporation,
Duette Mine, Manatee County, Florida
Royster Company emphatically supports the Draft Environmental Impact Statement
published in October 1979 by the Federal EPA which was favorable to the proposed
Estech Chemicals Corporation's Duette Mine project to be located in Manatee
County, Florida. In our opinion, the proposed mining and reclamation plans contain
creative and effective environmental safeguards which enhance the short and long-
term socio-economic, agricultural and natural vegetation impact.
For more than forty years, Royster has maintained a significant investment in land
and people in the phosphate industry in Florida. The Duette Mine project, In which
Royster intends to participate as a joint venturer, is essential to the replacement of
our company's current source of phosphate rock which expires July 1, 1983. This
replacement will act to maintain the net capability of the U.S. phosphate industry,
thereby helping to ensure a stable supply of one essential crop nutrient so that the
United States will not need to rely upon imports from overseas. Indeed, this phos-
phate production and the resulting food crops are essential contributors toward a
favorable balance of payments for the United States.
170
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RESPONSES TO WRITTEN COMMENTS
RESPONSE W-l
This comment is certainly correct when energy is viewed from
a strictly domestic perspective, and the current national energy
situation provides considerable incentive to adopt such a per-
spective. However, due to the complexity of existing inter-
national agreements and trade arrangements between the United
States and other countries, especially allies such as Japan,
it becomes practically impossible to divorce the domestic and
world energy issues. Even viewed from a worfd energy perspec-
tive, more energy is consumed to dry the rock than is consumed
to ship the moisture in the wet rock. On the other hand, if
the rock is dried at the final destination, the energy consumed
in drying the rock is added to the energy consumed in shipping
the moisture, resulting in the greatest overall world energy
consumpt ion .
Although the dryer capacity and resulting emissions are projected
for the total output of the proposed mine, Estech will, in fact,
send wet rock to those customers which can accept it. Estech
will dry rock for customers requiring dry rock at the final
destination, a procedure which is more efficient from a world
energy perspective than drying rock at the final destination.
RESPONSE W-2
This point is well taken. The Central Florida Phosphate Industry
Areawide EIS does not present economic considerations or market
conditions as possible justifications for permitting new rock
dryers. The important fact which should, more correctly, have
been emphasized in the Estech DEIS is that the Areawide EIS
reconmendation concerning rock drying was mitigated by more
recent developments. The recorrmendation to eliminate rock drying
was premised on the then existing allowable source emission rates
which were significantly greater than rates now permitted by
EPA's PSD Regulations. The deciding issue now is that the dry
rock production can be achieved in compliance with appropriate
171
-------
regulations regarding maintenance of air quality. Discussion
relevant to this point may be found on pages 169 and 170 of the
DEIS and on pages 3 and 4 of the Air Quality Resource Document.
RESPONSE W-3
The arguments presented for postponing the Final Environmental
Impact Statement (FEIS) until after the local land use issue
is resolved have received serious consideration. However, EPA
feels that the publication of a FEIS can and should provide
useful information that can be used by appropriate state and
local officials in their decision making process. Certainly
EPA's actions cannot supersede or preclude actions by other
jurisdictional entities including local government. Regarding
the practicalities of the situation if the project is altered
in a substantial way, a supplement to the FEIS can be prepared.
Before EPA issues the NPDES permit, a permit hearing will be
held and state certification under Section 401 must be obtained.
EPA will assure that the action it takes on the NPDES permit
does not undermine the integrity of local land use decision
process .
RESPONSE W-f
See Response W-2.
RESPONSE W-5
See Response W-1.
RESPONSE W-6
The U.S. EPA Office of Planning and Management recently investi-
gated availability of low sulfur fuel oil, and while cost
differentials between high and low sulfur fuel are expected,
there is no indication of a shortage of low sulfur fuel oil pro-
jected through the Winter of 1980 - 1981. In fact, slight
increases in supply and concomitant reductions in use have
Increased the availability of low sulfur fuel to the extent that
prices actually decreased sdmewhat in early 1980. Iranian
172
-------
supplies were interrupted well before 1980. Consequentially,
guidance has been issued to all EPA Regions recommending
disapproval of future requests for Section 110(f) waivers (Clean
Air Act Amendments, 1977) except in the event of any major
reduction in oil supplies.
Supply requirements of low sulfur fuel oil for the referenced
electric utility are projected to be approximately 40 million
barrels for 1980, contrasted with a projected 0.28 million
barrels required annually by the proposed activity.
It is reasonable to expect that at times it may be difficult
to secure guaranteed commitments for the large fuel quantities
necessary for uninterrupted and legal operation of a major
electric power utility, while smaller quantities may remain
available for relatively few moderate industrial users.
Future availabilities and costs of low sulfur fuel oil were
important considerations in development of the rock dryer
pollution control system design. While the proposed operation
is presently constrained by local regulations to use low sulfur
fuel oil (1.0 percent maximum), future allocations of available
supplies of low sulfur oil to other parts of the nation was
recognized as a possibility. The manufacturer of the control
device was required to submit a system design capable of
approximately double the maximum inlet loading contributed by
1.0 percent sulfur fuel oil. Hence, the stack emission rate
of sulfur dioxide may be controlled at the present estimated
levels for fuel oils containing at least 2 percent and possibly
as great as 2.5 percent sulfur. (See also Response W-7.)
Finally, modeling analysis of source effects indicates that other
major contributors to the sulfur dioxide concentrations at
critical receptor locations were diesel powered earth moving
equipment associated with transient mining and reclamation
activities and the 100 horsepower package steam boiler. If the
component contribution from rock drying were increased by an
amount equivalent to the difference between 1.0 and 2.5 percent
173
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fuel sulfur at the control system efficiency stated in the DEIS,
the sum of concentrations contributed by all three sulfur dioxide
sources would increase only in proportion to the dryer contri-
bution and would not exceed the PSD levels of significance at
existing critical receptor locations.
RESPONSE W-7
The Air Quality Resource pocument (pp. 20, 33 6c 35) indicates
that substantial quantities of sulfur dioxide are removed in
the fluidized bed reactors (dryers) before gases enter the
control equipment. The industrial oil-fired boiler analogy is
introduced to convey that the overall removal, inherent plus
deliberate, will be equivalent to 96.5 percent. Thus, the 96.5
percent efficiency cannot be compared directly to control system
performance on steam, electric power generation boilers. Neces-
sary documentation is included in PSD Construction Permit Appli-
cations filed with the EPA, and the appp1icat ions are initially
referenced in the Air Quality Resource Document (p. 7). The
supporting documentation for sulfur dioxide consists of two
separate equipment proposals, each including the willingness
of a responsible supplier to guarantee system performance greater
than the indicated 96.5 percent removal efficiency.
The state-of-the-art of technological development in flue gas
desu1furization (FGD) has continued to progress since 1976 -
1977. The EPA Industrial Boiler FGD Survey: First Quarter 1979
(EPA 600/7-79-067b), describes a more recent state of applied
technology and indicates that several sodium hydroxide (primary
cycle) systems are effectively achieving 90 percent sulfur
dioxide removal, and some have even demonstrated removal
capabilities as great as 96+ percent (Alyeska Pipeline Company)
with relatively problem-free operation. The report also
describes several systems with design removal efficiencies in
the 94-96 percent range that were planned or were in construction
at the time the report was published (April, 1979). It is likely
that many of the existing systems would be capable of operation
at greater than 90 percent removal efficiency if it were not
174
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for the fact that current regulations do not require better
performance. It is reasonable to expect that in designing a
new, high performance system, a control system manufacturer would
not rely on designs that have resulted in poor performance, but
would instead attempt to avoid many of the mostly mechanical
pitfalls that were responsible for poor operating reliability
in the earlier control system designs. In view of the above
and the fact that the proposed control devices effectively
include two separate gas removal stages, a venturi scrubber
(capable of alkali injection) followed by a three-stage alkali
spray absorption chamber, the 96.5 percent overall removal
efficiency estimate is realistic, rather than optimistic.
Removal efficiencies for other pollutants are similarly
documented in PSD Permit Applications filed with the U.S. EPA,
and the applications are initially referenced on page 7 of the
Air Quality Resource Document in the section where estimation
methodologies are described.
RESPONSE W-8
Refer to Responses W-6 and W-7.
RESPONSE W-9
The computational (factoring) procedure utilized to generate
sulfur dioxide concentrations is a commonly practiced and
mathematically rigorous procedure and produces results identical
to those which would have resulted if the computer algorithms
(models) had been exercised directly with the sulfur dioxide
source emission data. The techique was reported to clarify the
absence of computer results in the Appendix.
RESPONSE W-10
The "relaxed" standard is a (temporary) Variance from the Florida
State Implementation Plan which expires October 18, 1981. The
variance was granted well after completion of the DEIS analysis
and will expire before the proposed project can be constructed.
It is predicted that the State Implementation Plan requirements
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will be resumed upon expiration of the Variance, and the DEIS
analysis for the proposed facility would be unchanged.
RESPONSE W-ll
It is agreed that at some location the described power generation
facility produced concentrations in excess of significance levels
as a consequence of the temporary variance discussed in Response
W-10. EPA does not specifically include "significant source"
among PSD definitions, but instead utilizes significance level
criteria to evaluate effects contributed by a proposed source.
The proposed source considered in this instance is the Estech
General Chemicals Corporation mining facility. (See also
Response W-12 .)
RESPONSE W-12
The DEIS states "other major source development in the immediate
area of the proposed mine" and refers only to new or modified
sources having substantial effects near the proposed project
property boundaries. Monitoring data suggest that the refer-
enced power generation station effects would not be substantial
at the proposed site even with the change to high sulfur fuel.
If the referenced power generation station were to undergo a
permanent modification, that change would require revision of
the State Implementation Plan and would initiate the requirement
for a complete interactive PSD review essentially similar to
that conducted for the proposed facility. At that time emissions
from the power generation facility would be constrained from
exceeding the remaining PSD increments and NAAQS.
RESPONSE W-13
Refer to Response W-10.
RESPONSE W-U
The essential input and procedural information to determine
accuracy of the analysis and approach was furnished to EPA.
Information included is that which EPA determined to be necessary
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and is presented in the Air Quality Resource Document Appendix.
Minor omissions of data were discovered and are included as
errata to the Resource Document located in the Errata Section
of the FEIS.
The interactive sources are referenced to UTM coordinates and
can be identified from NEDS or FDER listings. Each computer
run included a title relating the run to the objective or element
of PSD analysis discussed in the test. CRSTER, AQDM and PTMTP-W
input-output are decipherable by individuals with modeling
background adequate to interpret the results and are available
in User's Handbooks available from the National Technical
Information Service of the U.S. Department of Corrmerce.
Inclusion of detailed information sufficient to reconstruct the
entire air quality analysis would have involved the printing
of a cumbersomely voluminous document.
RESPONSE W-15
The alternative of using the existing dryer at Estech's Silver
City Mine was included as a part of the analysis of using an
"Existing Dryer at Remote Location". At the time the DEIS was
published, this investigation had led to the following conclu-
sion, found on page 50 of the Alternative Evaluation Resource
Document: "More significantly, there are no known existing
facilities in Central Florida with excess capacity for contract
drying three million tons per yer of phosphate rock." This
statement applied to Estech's facility as well as other
companies' facilities. The capacity of the Bartow (Silver City)
rock dryer of approximately three million tons per year was being
fully utilized, with two million tons per year coming from the
Silver City Mine and one million tons per year from the Watson
Mine. The Silver City Mine is currently nearing depletion, while
the Watson Mine will continue producing one million tons per
year until the mid 90' s. Even with the cessation of mining at
the Silver City Mine, the Silver City rock dryer operating at
full capacity could not handle the combined production of the
Watson and Duette mines.
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Since the publication of the DEIS, Estech has reduced the tonnage
of Duette rock to be dried by actively encouraging its partners
to accept wet rock. At this writing, Royster and Estech have
indicated they would take up to 990,000 tons of wet rock each
year (or about 30% of the Duette Mine production). This leaves
approximately two million tons of Duette rock to be dried. It
could, in the near future, be marginally possible for the Silver
City rock dryer to handle the combined requirements of the Watson
and Duette mines. There is no economic incentive for Estech
to adopt this as their proposed action. Operating (drying and
shipping) costs would increase by 30% and 36% respectively, if
the wet rock were either hauled by, truck or shipped by rail to
the Silver City dryer, then dried and shipped to the customer.
Nor is it advantageous from an environmental viewpoint.
Additional energy would be consumed in shipping the wet rock
to the Silver City Mine. More importantly, it would prolong
the use of the older, less efficient rock dryer, which is
currently scheduled for decreased utilization at one million
tons per year until the Watson Mine is exhausted, at which time
it will cease operation altogether. As explained previously
in response to Comment W-2, the Clean Air Act Miendments have
provided a mechanism to ensure that the new rock dryer emissions
will be a considerable improvement over those still allowable
with the existing rock dryer.
It is reasonable to expect that over the life of the project
Estech will continue efforts to reduce as much as possible the
tonnage to be dried, for several reasons: drying consumes
capital; drying consumes energy; drying does not produce a return
other than being able to meet the customer requirements of dry
rock.
RESPONSE W-16
As in the DEIS, definitive information regarding the water
quality of the waste clays at the Estech Duette Mine is not
available as wastes have not been generated at the site.
However, information regarding the water quality in a clay
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storage area of an existing mine in Hillsborough County,
Florida, has been used to attempt to provide some quantative
projections of effects on the surficial groundwater quality.
Analysis of a water sample collected from a clay settling pond
at the Hillsborough site indicates that the water meets the EPA
primary and secondary drinking water standards for all con-
stituants analyzed except iron. The chemical characteristics
of the water in the Estech clay storage area are expected to be
s imi1ar .
The chemical character of the water at the sampled clay settling
pond is similar to the samples collected from existing shallow
wells at the Estech site. It is therefore believed that the
clay storage area will not adversely affect the water quality
in the surficial deposits.
RESPONSE W-17
Reading of the explanatory paragraph irrmediately following the
quoted recommendation is pertinent to Estech's case and reveals
that Estech is, in fact, following the Areawide EIS
r ecorrmendat ion: "The mining and reclamation plan for new-source
mines should establish a method whereby the slimes (or slimes/
tailings mixture) would be used for reclamation or some other
purpose. The need for an initial aboveground storage area is
recognized - as is the need for small retaining dikes around
certain areas. If the percentage of waste clay at a mine exceeds
the proportionate amount that can be utilized, the incremental
amounts beyond that which can be handled by new slime -
dewatering methods may be placed in a holding pond for
reclamation after settling." The single ^80-acre clay settling
area is mandatory if Estech is to employ the recommended
slimes/tailings mixture technique. This area must receive all
the clay wastes generated before the sand-clay mix procedure
becomes operational. It is necessary that this initial settling
area remain active over the life of the mine to be available
to receive clay wastes in the event of a temporary breakdown
of a mechanical thickener at the plant or of some other technical
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difficulty which would temporarily halt the sand-clay mixing
procedure. Moreover, although the Duette Mine ore contains on
the average more sand than required in the sand-clay mix, in
any given mining block or at any given point in time, the waste
clay generated may exceed the amount that can be irrmediately
utilized. The initial settling area would be needed to receive
these clay wastes in excess of the sand/clay mix requirements.
RESPONSE W-18
Conventional waste clay disposal, as described in the Areawide
EIS, involves "large settling areas covering 30-60% of mined
lands requiring 5-20 years for reclamation to support agri-
cultural uses". This disposal method was discussed as a project
alternative on pages 31 and 32 of the Alternatives Evaluation
Resource Document. This option would necessitate conrmittal of
7,104 acres to 10,121 acres of the site to waste disposal,
depending on dam height. The non-conventional alternative of
mixing sand with waste clay in mined-out (incised) pits was also
discussed within the Resource Document. This sand/clay mix alter-
native, which was the reconrmended alternative of the DEIS,
involves a total of 6,754 acres and substantially reduces the
chances of a significant environmental disaster by eliminating
the need for aboveground storage except for an initial above
groundstorage area. As recognized in the EPA Areawide EIS,
an initial aboveground storage area on natural ground is
necessary at mine start-up and for some period afterward until
mined-out cuts become available for waste disposal.
RESPONSE W-19
The plan for diversion of 3 mgd from the East Fork Manatee River
will not be affected by the fact that the East Fork of the
Manatee River. The Reservoir is proposed to be located adjacent
to the floodplain of the East Fork and the intake structure will
be constructed to provide the 3 mgd from the river to the
reservoir. The Terms and Conditions of the Consumptive Use
Permit granted by the Southwest Florida Water Management District
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require that water be provided to the storage basin via with-
drawals from the East Fork. The "Terms" further r equ i re that
the applicant decrease its groundwater withdrawals by
withdrawing water from the reservoir.
RESPONSE W-20
The primary water management plan evaluated in the DEIS was based
on an order granting a permit by the Southwest Florida Water
Management District after a public hearing before the District
Governing Board. The plan encompassed a balance between ground-
water withdrawals from wells within the Floridan Aquifer and,
commencing with the fourth year of mining, diversion of surface
water from the East Fork Manatee to a surface water storage basin
constructed by Estech. (See also Response W-19.) By terms of
the permit, Estech must maintain min imum mont h 1 y flows downstream
from the diversion to "minimize the impact of the diversion and
permit the public interest to be safeguarded".
RESPONSE W-21
Biological and hydrological effects of mining activities in
wetlands were addressed in the Draft Environmental Impact
Statement (pp. 129, 131, and 180) and in the accompanying
Resource Document on Biology.
Category 2 wetlands can be contiguous to Category 1 wetlands
whereas Category 3 wetlands are isolated. It is true that
disturbing Category 2 wetlands will have a detrimental effect
on downstream Category 1 wetlands by diminishing surface flows,
lowering water quality and eliminating a portion of detrital
input to downstream systems. However, these effects will be
temporary and will decrease in magnitude with time after
reclamation. In addition, EPA has placed 25% of Category 2
Headwaters and Tributary Wetlands in Category 1. The purpose
were to provide a buffer zone between mined Category 2 areas and
unmined Category 1 areas, and to provide an established, natural
corridor for recolonization of upstream reclaimed Category 2
areas .
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RESPONSE W-22
The cited 5.k mgd reduction in flow of the East Fork Manatee
River during mining (DEIS, page 80) is an annual average. This
figure cannot be directly compared with average monthly extreme
flows (minimum-maximum) for an eight year pre-mining period
(DEIS, page 77). Post-mining flow modifications for all affected
basins are presented in comparable units on pages 80 and 81 of
the DEIS.
RESPONSE W-23
Sixty-eight percent of the sand pine scrub habitat and the entire
18-acre cypress dome will be preserved. The alteration of the
land surrounding the sand pine scrub corrmunity may lower its
wildlife value. However, the rare, threatened or endangered
species which inhabit sand pine scrubs have limited home ranges
and therefore should not be severely impacted by a loss of
surrounding habitat. A buffer zone around the preserved areas
should minimize harm to the preserved areas. Important wetland
habitats will be protected. All mainstem streams and their
floodplain swamp have been placed in Category 1, i.e., preserved.
Mining in swamps will be limited to tributaries to mainstem
streams and isolated bayheads. In addition, 25% of headwater
and tributary wetlands (Category 2) will be preserved as Category
1. (See also Response W-21.) All Category 2 swamps will be
restored after mining.
RESPONSE W-24
Species listed as rare, threatened or endangered presently make
little use of the site. With few exceptions, individuals of
these spfecies will continue to occupy those habitats which will
not be disturbed by mining operations (e.g., floodplain swamps)
or will be able to move to suitable, nearby habitats. As a
group, the listed species are not expected to show significant
population declines. Some listed species, such as alligators
and wood storks, will probably benefit from the creation of
mine-pit lakes. It is possible that bald eagles and ospreys
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(which are not known to use the site now) will be attracted to
the lakes. Gopher tortoises are coirmon on formerly mined lands
and may be expected to recover to their present population.
Please see Response W-76 for information concerning EPA's
compliance with the Federal Endangered Species Act, which has
resulted in the issuance of a "no jeopardy" Biological Opinion
by the U.S. Fish and Wildlife Service. The Endangered Species
Coordinator of the Florida Game and Fresh Water Fish Commission
has reviewed the DEIS and the proposed action for compliance
with State of Florida endangered species laws and has offered
no adverse comment. He has also participated in the Federal
consultation process.
RESPONSE W-25
The Clearing House Review Committee of the Tampa Bay Regional
Planning Council found the DEIS to be "regionally significant
and consistent with TBRPC goals and objectives" (November 26,
1979). Special protective efforts which will be undertaken by
Estech are discussed in Response W-76.
Response W-26
In compliance with Section 7 of the Endangered Species Act, the
Department of the Interior was consulted concerning the adequacy
of the biological assessment, and their Biological Opinion was
requested. See Response W-76 for full discussion.
Response W-27
Identification of unique and endangered species present on the
proposed site was carried out as part of the EIS process. $teps
being taken by Estech to protect identified species are described
in correspondence included in Response W-76.
RESPONSE W-28
It is believed that due to the expected reduction in permeability
of the sand/clay mix, relative to the existing surficial
deposits, the recharge capacity of wells located near or in
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these areas will also be reduced. The actual (quantitative)
value of this reduction will not be known until field testing
begins following the initiation of mine operations. The
consumptive-use permit (SWFVIMD, 1978), however, requires a
certain quantity (3.04 mgd) to be recharged regardless of any
changes in the permeability of the surficial materials.
The proposed Manatee County Comprehensive Plan generally calls
for long-range land uses which are predominantly "rural in
nature".
RESPONSE W-29
The fractionation of the elements of the uranium decay series
does occur within a chemical plant and this phenomenon is well
documented in the open literature. Radium-226 chemically
associates with the gypsum (CaSO^/RaSO^) due to the fact that
both are divalent cations and the uranium remains soluble in
the phosphoric acid. The Duette Mine does not include a chemical
plant, only a beneficiation plant and dryer.
The bene f i-c i at i on process is a physical separation which should
represent an extreme attempt at an aqueous leaching of the
radioactive species from the major components of the phosphatic,
matrix. Yet the published data suggest little enrichment or
leaching in any of the components: sand, clay, rock or concen-
trate. The reader is especially referred to the recent publica-
tion by Roessler, _ et_ al_, Health Physics Vol. 37, p. 269 - 277,
September, 1979.
RESPONSE W-30
As stated in the response to Coirment W-29, the benef iciat ion
process has not been shown to produce soluble uranium since the
process is physical rather than chemical. EPA's Environmental
Impact Statement on the Central Florida Phosphate Industry
considered the potential for groundwater contamination in some
detail. The data were not demonstrative of an impact of current
184
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mining; in fact, the data suggest higher radioactivity levels
in the unmined areas.
It should be re-emphasized that the radioactivity in the minable
matrix is a small fraction of the total radioactivity (uranium
and daughters) found in the Hawthorne formation. The fact that
the aquifers underlying this formation are low in radioactivity
is strong evidence for the insolubility of these radioactive
species within this type of sedimentary mineral.
RESPONSE W-31
Uranium-238 was included (page 67, Radiological Environment
Resource Document). The manner of listing was sequenced in order
of their relative contribution to the off-site dose, rather than
the usual sequencing by parent, daughter, granddaughter, etc.
Radium-226 is listed first because it is considered to be the
highest contributor to the off-site dose to man.
The corrment suggests that Pb-210 be added to the list of
radionuclides of concern, then modifies this concern by the
suggestion that it is the daughter product, Po-210, an alpha-
emitter, that may lead to serious health effects. Po-210 was
considered by the AIREM model. The beta-emitting Pb-210 will
be much less a hazard than the alpha-emitting Po-210 which was
included in the analyses.
RESPONSE W-32
The cormnent refers to the radionuclides of U-238 and Pb-210.
The potential for uptake of Ra-226 was addressed in the report.
Since Ra-226 is considered to be the most critical radionuclide
in terms of the series of parameters involved in modeling its
transport from soil to human, the many other radionuclides that
could be addressed will be subordinate to Ra-226. The limited
impact predicted for Ra-226 suggests further analyses to be
unneces sary.
The term "fertilizer production" in the cormnent again suggests
a possible concern for the total generic problem of the industry,
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including chemical plants and the end uses of fertilizer. The
Duette site will produce airborne particles and there will be
provision for an air monitoring network once the on-site dryer
goes into operation. Specific radionuclide analyses may be
performed if gross alpha/gross beta screening justifies a
potential hazard.
RESPONSE W-33
The question, as in W-29, confuses data on end-product fertilizer
with the raw material produced by the Duette complex. The
concentrate and pebble from the Duette site may be used for a
variety of purposes, including manufacture of phosphoric acid
at some other site. In any off-site chemical processing of
phosphate ore, the uranium will definitely be solubilized. The
various uranium extraction operations coming on line in Florida
are a direct result of this phenomenon. If the uranium is not
extracted from the phosphoric acid and the phosphoric acid is
utilized in any commercial end-product, such as triple
superphosphate, then that product will contain the soluble
uranium to which Spalding and Sackett refer. This problem is
generic to the entire industry and has no direct impact on the
Duette complex. As more and more of the total phosphoric acid
produced is processed for uranium extraction, the leachate off
of farmlands becomes less and less. EPA's Environmental Impact
Statement for the Central Florida Phosphate Industry recommended
a maximum utilization of this resource recovery technique.
RESPONSE W-34
As in previous corrments by the same author (W-29 through W-33),
the concern relates to the total industry and has little direct
bearing on the specific impact of mining, beneficiation and
drying of ore at the Duette site. The impact of a proposed water
standard for uranium would be most evident at a chemical plant
where the uranium is solubilized into the phosphoric acid or
in a process where phosphoric acid is utilized, i.e., triple
186
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superphosphate production. A chemical plant is not a component
of this pro j ect.
The discussion within the comment implies a drinking water
standard at 10 pCi/1 soluble uranium. The long standing Maximum
Permissible Concentration in water for soluble uranium has been
40,000 pCi/1 for the population. Justification for lowering
this established standard by over three orders of magnitude would
be a most significant undertaking. EPA is the lead agency in
setting radiation protection standards and will continue to
address this problem.
Effluent guidelines and drinking standards are, of course, not
necessarily the same. Consideration of discharge, dilution ,
dispersion, uptake, sedimentation, exchange, and removal
efficiencies by water treatment processes are typical of
transport phenomena that must be considered in an effluent
standard.
RESPONSE W-35
This discussion continues to address the question of the proposed
water standard for uranium and its ultimate distribution in bone.
As mentioned in Response W-34 and W-36, EPA1s Office of Water
Programs will consider many physical and biological factors in
establishing radiation standards in water. Among these are
intake quantities, biological transfer, transport to critical
organs, nature of the organ, dose response, biological and
physical half life of the dose radionuclide and elimination
rates.
RESPONSE W-36
It is not cost-effective to develop standards for all radio-
isotopes which may appear in drinking water, and for the present
time, there are no plans for a Pb-210 standard. Alpha emissions
from Po-210 are adequately covered under the gross alpha limit
of 15 pCi/1.
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A radon in drinking water standard is under consideration by
the EPA Office of Water Programs. If developed, it is at least
two to three years from promulgation.
RESPONSE W-37
It is agreed that the 0.020WL total exposure to radon progeny
does represent a definitive cancer risk. However, the "3,000
excess lung cancer deaths per 100,000 people" cited represents
an upper limit figure, and consequently, it may be more appro-
priate to use a 1,000 - 3,000 cancer death range per 100,000
people as stated in the referenced EPA document (EPA 520/4-78-
013).
With respect to radon progeny producing a "large increase in
skin cancer risks", the EPA/ORP position is that there is poor
evidence to support this conclusion.
RESPONSE W-38
The Spalding and Sackett reference does have a typograP^*ca*
error in the date. The exact reference should be as follows.
Roy F. Spalding and William M. Sackett, "Uranium in Ru"j**s
from the Gulf of Mexico Distributive Providence:
Concentrations", Science Vol. 175, pp. 629-631, Febru
11, 1972.
Spalding and Sackett state that "from an analysis of corn,
soybean, and alfalfa grown under varying applications of 5f
it appears that very little, if any, uptake of uranium occurs
They also calculate the total applied uranium per year in ^
area of interest divided by the annual expected runoff
that value agrees well with the measured incremental *ncreaSje
of uranium in the waterways. Thus, the paper indicates
impact of the soluble uranium other than its transfer to
pn t T3 t j OH S
waters of the Gulf of Mexico where the natural conceni
j. , thpir study
of uranium are higher than in freshwater streams ox l,lc
area.
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RESPONSE W-39
Corrment W-39 is a modification of Comment W-29. Please refer
to Response W-29 for the appropriate response.
RESPONSE W-40
This conrment is a slightly modified combination of Comments W-31
and W-32. Refer to Responses W-31 and W-32 for the appropriate
response.
RESPONSE W-41
This conrment is a modified quotation of Conrment W-33, except
that 'assumed' has been changed to 'assured' and the word 'and'
in the last sentence has been underlined for apparent emphasis.
Also 'high concentrations' in the third sentence has been changed
to 'light concentrations'. Please refer to Response W-33 for
the appropriate response.
RESPONSE W-42
Conrment W-42 is primarily a direct quote of Conrment W-3^. Please
refer to Response W-34 for the appropriate response.
RESPONSE W-f3
Corrment W-43 is primarily a direct quote of Comments W-34 and
W-35. However, the next to the last sentence should read, "For
chronic exposure, i_s the uranium distribution in human bone
similar to that of Ra-226 or that of Pu-239?" Please refer to
Responses W-34 and W-35 for the appropriate response.
RESPONSE
See Response W-36.
RESPONSE W-^5
See Response W-37.
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RESPONSE W-^6
The dryers and associated dry rock handling facilities are
projected to emit particulates at a rate not to exceed 126 tons
per year, not 1,290 tons as shown in the comment. The rate of
Rd-226 released from the two dryers is about 3.6 millicuries
(3,600,000,000 picocuri^s) per year or about 3.6 milligrams of
radium per year .
The expression "exceeds the equiva1ent radionuclides which would
be allowed by NRC from a 1,000 megawatt nuclear power plant"
is not applicable. The comparison between releases of one radio-
active species and another can not be made on a picocurie basis.
The curie unit has limited relationship to hazard. The compari-
son can only be made in terms of a transport model that leads
to an analysis of a potential radiation dose from a set of given
radionuclides to a defined population.
The document in question attempts to accomplish this analysis
by adapting a computer code designed for the nuclear industry
to the rock dryer emissions. The model incorporates emission
rate, stack height, wind speed by direction and stability class,
wind rose data by stability class, deposition, rainfall,
distance, direction, and dose conversion, factors for the
expected critical organ. Lung doses, thus calculated, were shown
to be quite low for the off-site population - on the order of
one-one thousandth of natural background rates.
For comparative purposes, the total yearly emission rate for
Ra-226 given for the dryers is about equal to the naturally
occurring Ra-226 in the first foot of a five-acre garden in a
low background area of the state. For regions where the
Hawthorne formation outcrops, the area of comparison may be less
than one acre. The atmospheric dispersion calculated by the
computer model indicates an insignificant off-site buildup of
radionuclides in the soil.
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RESPONSE W-47
The concern for uptake of radionuclides by fish and other
wildlife in reclaimed lakes is related to the question of
solubility expressed in previous comments. Responses W-29
through W-34 have attempted to address concerns such as (1) the
solubility of uranium; (2) the difference between the
mining/beneficiation/drying at the Duette Site and the production
of fertilizer; and (3) the question of uptake. Response W-38
also addressed the uptake question. The report in question,
Radiological Environment Resource Document, considers uptake
on reclaimed lands on pages 73 through 77.
One additional consideration can be added to the aforementioned
discussion. Natural systems and other activities of man have
produced exposure of the below surface, high concentrations of
radioactivity in central and west central Florida. Stream beds
intercept the leached zone, the matrix or deeper Hawthorne
strata. Dam and reservoir construction have potentially exposed
recreational and public raw water supplies to new strata with
elevated concentrations of radioactivity. Dredge and fill
operations, including canal construction, have similar
potentials. Failure of dams for clay settling areas have been
known to contaminate large stretches of stream beds for a short
period of time. All available evidence suggests that land-and-
lake reclamation can provide safe water areas for fish management
and recreational uses.
RESPONSE W-^8
The impact of the mining operation on the alteration of terres-
trial gamma radiation and the agricultural use of reclaimed land
use was discussed in the DEIS on pages 113 and 115 respectively.
As far as radiological impact is concerned, no data indicate
a permanent loss of the land to agricultural use.
RESPONSE W-49
The technology for the creation of wetlands has been the subject
of an annual conference entitled "The Restoration and Creation
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of Wetlands" sponsored by the Hillsborough Community College
Environmental Studies Center in Tampa, Florida, for the past
six years. This conference, and a number of other ones like
it throughout the country, have been the forum for presentation
of many technical papers on demonstrated wetland restoration/
creation projects. Although these conferences have dealt
primarily with coastal wetland systems, two papers were presented
at the 1979 Tampa conference on wetland reclamation technology
in the central Florida mining district. These papers have
indicated some initial success in creation of herbaceous wetland
habitat. Storing the organic surface layer of freshwater ponds,
and spreading this "seed source" in newly created depressions,
shows promise of allowing rapid revegetation of a diverse wetland
community. We share your concerns about successful restoration
of hardwood swamp wetlands. We are allowing mining in Category
2 wetlands and are requiring restoration of these areas.
Hopefully, this will generate useful data on restoration
methodologies for swamp and bayhead construction.
RESPONSE W-50
Mining will result in a complete restructuring of soil profiles
and, in many instances, significant modifications of soil
characteristics in reclaimed areas. See pages ^9, 50, 62, 63,
80 and 81 of the DEIS and page 18 of the Soils Resource Documen
regarding the projected alteration of surface drainage patterns,
surface flows and vertical recharge due to mining induced soi
structure modifications.
RESPONSE W-51
It is standard practice when reviewing a new or modifi^
' t h ©
source, such as the one Estech is proposing, to ascertain
types and numbers of emission points and the quantities of
,v conduct
pollutant emissions from each point in order to properiy
The
and/or review an ambient air quality impact analysis*
emissions inventory (computer input) and procedural informa
necessary to determine accuracy of the analysis and appro30*1
192
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were furnished to EPA. During the course of an EPA prevention
of significant deterioration (PSD) review, the New Source Review
Section of separate authorized engineering contractors
assure that both quantity and quality of pollutant emissions
are representative of the specified polluting facility. EPA's
Preliminary Determination for Estech's PSD permit is contained
in Appendix A-2 of this document.
RESPONSE W-52
Refer to Responses W-51 and W-5*f.
RESPONSE W-53
With regard to the accuracy of the input data, the reader is
referenced to Response W-51 and W-52. There is apparent
confusion exists on the part of the commentor because of the
statement which questions the reliability of the AQDM computer
model and further references a portion of the DEIS which
pertains to the PTMTP-W model.
The question does not differentiate short-term (2'f-hour) and
long-term (annual) modeling recognizes that the uncertainty
arises from addition of an uncertain background estimate to an
industrial contribution determined by modeling methods. In
general, the results of any computer model are only as reliable
as the assumptions and values of variables utilized for input
to the model. Again, such items underwent close scrutiny during
the required PSD review for the proposed source. (See Appendix
A-^2.) While the background concentrations added to the AQDM
and PTMTP-W model results may not be exact, they do appear to
be within the range of typical background measurements for the
area and time-averaging periods under consideration.
RESPONSE W-54
All external, interactive air pollution sources with valid
construction and/or operating permits within a 50 kilometer
radius were considered and treated in the total suspended
particulate modeling exercises which examined conformance with
193
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available PSD increments and NAAQS (DEIS, pp. 33, 39 & 42).
Emissions of other pollutant forms were determined to produce
effects less than the PSD (deminimis) levels of significance
and were exempt from external, interactive source modeling
analysis (DEIS, p. 42). Other proposed mining operations, or
any other future operation which has not yet filed or been
granted a permit to construct a source of air pollution, will
be similarly required by PSD regulations to examine source
interactions with all new and existing permitted facilities at
the time of application to insure that the PSD increments will
not be exceeded. The U.S. Congress established the PSD
increments as bounds on the degree of air quality deterioration
which may be considered insignificant, and as limits, which may
not be exceeded (Clean Air Act Anendments of 1977).
RESPONSE W-55
The actual design hourly consumption of electricity for the
proposed facility is approximately 51,000 kilowatts/hour. Hourly
generation capacity of the Manatee Electrical Power Generating
Station is 1,700 megawatts. Consequently, the proposed activity
nominally requires 3.0 percent of the total generation capacity
of the FP&L Manatee Power Station. If power were supplied by
the Manatee Power Station all times of the day instead of
actually deriving some off-peak energy supply from the "net
which often includes cheaper electrical power generated by
nuclear plants, the proposed activity would account f°r ^ Per
of the ground level pollutant concentrations contributed by
Manatee Station operating at maximum capacity.
An impact assessment of the Manatee Power Plant was prepared
for Florida Power and Light Company (ESE, 1976) f°r a C°n^j
of 2.5 percent sulfur fuel. Modeling results (uncalibrate
tPd to maxima
of the maximum sulfur dioxide concentrations correcte
(100 percent) capacity of 21 micrograms per cubic meter,
, +he Manatee
ESE, 1976 - A Sulfur Dioxide Impact Assessment ot 1 . ri 1,
Power Plant for Florida Power and Light Corporati°n»
1976.
194
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average, 105 micrograms per cubic meter, 3-hour average were
determined from this study. The short-term maximum effects would
occur at an approximate 24 kilometer distance from the proposed
activity, a distance where short-term contributions from the
proposed activity would be negligible. The long-term maximum
effect occurs approximately 5 kilometers east of the power
station (or 14 kilometers west of the proposed activity). For
practical purposes annual sulfur dioxide concentrations effects
of the proposed facility are nearly negligible beyond 1-2
kilometers of the source and are certainly negligible at the
point of interaction between the two sources. The induced or
secondary sulfur dioxide impacts produced by the FP&L Manatee
Power Station (maximum concentration locations) for 2.5 percent
sulfur fuel would be 0.6 micrograms per cubic meter, annual
average, 3 micrograms per cubic meter, 24-hour average, and 14
micrograms per cubic meter, 3-hour average. (For reference,
allowable PSD increments are 20 micrograms per cubic meter,
annual average, 91 micrograms per cubic meter, 24-hour average
and 512 micrograms per cubic meter, 3-hour average.) Since
construction of the proposed activity has not yet been undertaken
and the estimated construction schedule for the proposed activity
is of approximately 2 years duration, restoration of the Florida
Implementation Plan requirement for use of low sulfur fuel at
the Power Station would reduce the above projected impacts by
a factor of 2.5, or to maximum values of 0.3, 1 and 5 micro-
grams per cubic meter, respectively. The corresponding PSD
Levels of Significance are 1, 5 and 25 micrograms per cubic
meter. Therefore, the induced effects would be well below sulfur
dioxide significance levels for either 1.0 or 2.5 percent sulfur
fuel oil.
RESPONSE W-56
The intermediate term impact of a hypothetical embankment failure
on the ability of the Manatee County Water Plant to treat and
dispose of the increased suspended solids load was re-evaluated
based on a more accurate estimate of the suspended solids
195
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concentration at the plant intake and the results of recent jar
tests conducted by the Manatee County Utilities Department.
The percent removed of the estimated 730 mi 11igrams/1iter (mg/1)
of total suspended solids (TSS) entering the reservoir following
a hypothetical accident was recomputed using the average particle
size distribution and specific gravity of waste clays from
*
Florida phosphate mines . Revised computations indicated that
all particles greater than 2.2 micron size would settle to the
bottom of the reservoir prior to reaching the water plant intake
structure. From the particle size distribution curve, it was
estimated that 42 percent of the suspended matter would be
removed. Hence, the remaining 58 percent or a maximum of 425
mg/1 could be expected to enter the lowermost intake structure
at 15.25 feet (Mean Sea Level) elevation.
Results of jar tests conducted by the Manatee County Utilities
Department (Conservation Consultants, Inc., 1980) indicated that
approximately a 61% increase in the normal alum dosage would
be necessary to effectively remove 425 mg/1 of suspended solids.
The expansion of the treatment plant from 30 to 50 million
gallons per day scheduled for completion in May 1981 will
mitigate the impact of a sudden increase in TSS loading. Never-
theless, the sludge handling system of the facility would be
potentially stressed by the increased mass of solids. To protect
the sedimentation basin scraper assembly from possible damage,
some increase in the frequency of basin blowdown would probably
be necessary. The resulting increase in the volume of sludge
would likely exceed the planned capacity of the drying bed and
lagooning system. Proper disposal of the excess sludge would
require either modifications to the existing facility or
transportation of the wet sludge to another disposal site. If
a satisfactory method for disposing of excess sludge were
developed, no reduction in the water production capacity of the
plant would be necessary.
*
Lamont, W. E., J. T. McLendon, L. W. Clements, Jr., and I. L.
Feld (1975), "Characterization Studies of Florida Phosphate
Slimes," U.S. Department of Interior, Bureau of Mines Report
of Investigations, RI 8089.
196
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Shutdown of the treatment plant or reduction in operating
capacity would probably be necessary for a short period following
a hypothetical embankment failure. If provisions for disposing
of the increased sludge volume were made expeditiously, it is
possible that the plant could continue operating without a
significant reduction in capacity.
Comprehensive analysis of the several effects of a hypothetical
embankment failure on the water plant made by engineers
thoroughly acquainted with the design and operation of the plant
would be necessary to accurately determine the cost to return
the plant to operating condition and the increased cost of
operation. Anong the factors contributing the total cost would
be duration of shutdown period, availability and cost of treated
water from other systems, amounts of additional chemicals
(coagu1 ants/flocculants) required, percent moisture and volume
of excess sludge and cost of alternative disposal methods.
RESPONSE W-57
The prediction of mixed concentrations of various constituents
in Lake Manatee following the hypothetical release of the entire
1,000 acre feet of clear water from the proposed clay settling
area was made to provide a conservative estimate of resultant
concentrations at the reservoir dam - the location of the intake
structure to the Manatee County Water Plant. It is not
unrealistic to approximate the maximum concentration of a given
soluble constituent at the dam by assuming that water, hypothe-
tically released from the clay settling area, mixed completely
with the water inventory of the reservoir. Water entering the
head of the reservoir must travel a distance of over 5 miles to
the dam thereby providing the opportunity for thorough mixing.
Additional time for dispersion of dissolved constituents would
be provided during the minimum one-week plant shutdown which
would follow an accidental embankment failure. (See Response
W-56.)
197
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The assumption that mixing would be instantaneous is not
realistic nor is it necessary to support the above prediction.
The estimates were conservative in that the dilution of water
released from the settling area by the inventory in the ten-mile
stretch of river between the point of embankment failure and
the reservoir was neglected in the computation.
RESPONSE W-58
Results of a re-evaluation of the impact of a hypothetical clay
settling area embankment failure on the ability of the Manatee
County Water Plant to treat and dispose of the additional
suspended solids load were discussed in detail in Response W-56.
To sunrmarize this response, recent tests conducted by Manatee
County Utilities Department indicated that raw water with
suspended solids concentration at the level expected in the event
of a clay settling area dam failure was treatable by the present
facility. The primary operational problem during a period of
elevated TSS loading would be accomodating the greater than
normal rate of sludge production. If sludge disposal were
limited to available (and planned) on-site facilities, some
reduction in plant capacity would be necessary, but the reservoi
dould remain operational. If a satisfactory method for disposi g
of excess sludge were developed, no reduction in capacity would
necessarily be required.
Available evidence does not indicate that the reservoir would
be rendered inoperative in the long term or that the in
term expense of additional treatment would be proh it>1 * 1 ve *
Comprehensive analysis of the several effects of a hypothet
. iv acquainted
spill on plant operations made by engineers thorougniy
with the design and operating features of the plant would ^
necessary to accurately determine the impact on operating
RESPONSE W-59
, la intake
The projected concentration of suspended solids at Tnc:
«tical clay
to the Manatee County Water Plant following a hypotn
settling area embankment failure was re-tevaluated based o
198
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waste clay particle size distribution more representative of the
clays expected from the proposed Duette Mine. (See Response
W-56.) A maximum suspended solids concentration was predicted
in the event of an embankment failure. The basis for the
projection is described in errata to Appendix F of the Surface
Water Quality Resource Document.
Since radium-226 is predominantly associated with suspended
solids, the projected radium-226 level at the intake structure
was similarly revised to <1.2 picocur ies/1 iter (pCi/I). This
satisfies the State standard of 5.0 pCi/1 for Class I-A waters.
The basis for computation of the radium-226 level is given on
page 119 of the Surface Water Quality Resource Document and in
errata thereto.
RESPONSE W-60
The Consumptive Use Permit (SWFWWD, 1978) requires the recharge
of approximately three million gallons of water per day to the
Floridan Aquifer through a system of connector wells. At the
present time, Estech, through its consulting hydro logists, is
conducting intensive recharge investigations on the project site
aimed at providing additional data for further determining both
the quantity and quality impacts that will result from the
proposed recharge program.
As a condition of the Consumptive Use Permit, all data collected
during these investigations, including radiation studies, will
be evaluated by the SWFVHMD, and the proposed design and location
of permanent recharge wells must be approved by the SWFWMD staff
in advance of construction permitting. It is believed that the
data developed during the recharge investigations when related
to the conditions in the Consumptive Use Permit will prevent
the degradation of the quality of water in the Florida Aquifer.
The "Terms and Conditions" relating directly to the recharge
of water to the Florida Aquifer are presented in Items 10.h.
through 10. j. of the Consumptive Use Permit as follows:
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shall, within the time limits hereinafter
forth, complete the following items, and if
App 1 i cant
set
app1i cant
then this
void.
fails to complete them by the specified date,
Permit shall automatically become null and
Within one (1) year of the data of issuance of this
permit, the permittee will begin to construct a system
of connector wells for the purpose of recharging
3,024,000 gallons per day (average annual) from the
unconfined surficial aquifer and/or secondary artesian
aquifer to the Florida Aquifer. Construction of this
system of connector wells will be completed prior to
the start of withdrawals as permitted herewith and
shall be operated in such a manner as to maximize the
amount of recharge. The design(s) and locations of
these wells must be proposed in writing to the District
Staff within 8 months of the date of issuance of this
permit and must be approved in writing by the District
Staff in advance of construction permitting.
Flow measurements must be performed on each of the
connector wells immediately upon completion of
construction and then once a month thereafter unless
otherwise approved in writing by the District Staff.
Flow measurements are to be submitted in writing to
the District on April 15, July 15, October 15 and
January 15, for each preceding calendar quarter.
Water quality analysis will be performed on the water
moving in the Florida Aquifer through the system of
connector wells. All wells will be sampled immediately
following completion of construction and each month
thereafter. The water quality analysis will include,
but need not be limited to the following constituents.
(a)
(b)
(c)
(d)
(e)
(f)
(g)
(h)
Tota 1
Feca 1
Gros s
(if greater
analyze for
r ad i um)
I r on
Fluor ide
Phosphorus
Su1 fate
Pest icides
co1i form count
co1i form count
alpha radiat ion
than 15 pCi/liter
radium 226, total
(i) Organ ic Carbon
(j) Speci f i c
Conductance
(k) Nitrate
(1) Phosphates
(ortho, total)
(m) Total dissolved
so 1 ids
(n) Total suspended
solids
(o) Turbidity
The sampling procedure and list of constituents may
be modified by District Staff when deemed necessary
to monitor the conditions of the water resources of
the area. The analysis shall be performed by standard
method procedures. At least quarterly, the analysis
shall be performed by an independent testing
laboratory. A written report of the analytical results
must be forwarded monthly to the District.
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Should the water quality analyses lead the District
Staff to conclude that the connector well system is
degrading the quality of the receiving waters so as
to be significantly harmful to the water resources
of the area, it may, following written notice to
Permittee, take the matter to the Board, who, after
a public hearing thereon, may take appropriate action
to protect the resource, including modification of
the terms and conditions of this Permit.
RESPONSE W-61
The flow direction and flow rate of water in the artesian ground-
water system is governed by a series of well-known and experi-
mentally-proven principles and equations. Chief among them is
Darcy's Law (Darcy, 1856). Numerous other formulae have been
developed but all comply with Darcy's Law. Simply stated, this
law requires that water move from a point of higher potential
to one of lower potential at a rate depending on the difference
in the two potentials and the hydraulic character of the medium
within which it flows.
The present regional flow-rate within the artesian system in
the area of the proposed Estech mine is about 60 feet per year.
By withdrawing water from the artesian system, groundwater
gradients within the local area are changed, thereby effectively
capturing about 67% of the artificially-recharged water from the
duration of withdrawals. When withdrawals cease, all of the
artificially-recharged water not physically removed from the
aquifer by the wells will begin following the regiona1 -f1ow
direction. At a flow rate of 60 feet per year it would take
about 90 years to travel 1 mile. During that 90 years an
estimated 66,000,000,000 gallons of water will be recharged
naturally on the area underlain by artificially-recharged water.
The total quantity of art ificially-recharged water during the
life of the mine will be about 22,000,000,000 gallons - a
dillution of 3 to 1. These estimates are based on no dispersion
or mixing taking place with the estimated 900,000,000,000 gallons
of water stored in the potable zones of the aquifer directly
underlying the mine site.
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The permit acquired by Estech (SWFWMD, 1978) is designed to
preclude the artificial recharge of water which does not meet
strict water quality standards. It is believed that these
standards are sufficient to protect the artesian groundwater
system from degradation.
RESPONSE W-62
The method by which sand and clays are mixed has not been
determined and continues to be a subject of research and
investigation. The use of flocculants in the sand-clay disposal
system is just one of several methodologies under consideration.
Should flocculation be employed in the sand-clay mix technique,
it is not expected to deteriorate the groundwater for the
following reasons;
a) Flocculants have been and continue to be deemed safe for use
in potable water treatment facilities. The type of
flocculants (polyelectrolytes) generally used in industrial
and municipal water treatment are similar to those that would
be used by Estech, should this method be utilized.
k) Flocculants inherently have a severe affinity to particles
and provide an anchoring effect with the available solids.
This is evidenced by the fact that 80 to 99% of the floccu-
lant exits with the affected solids and remains attached.
c) Due to the high cost of flocculants and their effective-
ness, concentrations are typically kept around two parts
per mi 1 1 ion .
Contaminants which enter the recirculation water system from
the ore beneficiation process will rapidly bind to suspended
clay particles and may ultimately be deposited in the clay
settling area. The minimal seepage which is expected to occur
the clay settling area and various circuits in the
recircu1 ation system will have essentially the same quality as
the treated effluent discharged from the clay settling area,
^"he quality of the discharged water is discussed in the DEIS
and in greater detail in the Water Quality Resource Document.
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Loss of the recycled water will generally be confined to the
surficial aquifer in the immediate area of the seepage.
As stated in the Water Quality Resource Document, the flota-
tion reagents have preferential affinities for clay wastes and
exit the water circulation route adhered to these solids.
Reagent use is strictly limited to levels not appreciably
exceeding the quantities that adhere to the material leaving the
flotation circuit. Any residual reagent is afforded further
opportunity for attachment by additional contact with waters
containing clay from other plant operations.
The movement of water within the surficial aquifer has been
determined to be very limited due to the permeability of the
wastes in the clay storage areas (Bromwell, 1976). This fact,
coupled with the sealing of the storage areas which typically
accompanies clay disposal, will confine the water quality effects
to the vicinity of the waste clay storage facility.
RESPONSE W-63
Thousands of acres of native vegetation have been stripped in
central Florida for phosphate mining, agriculture and other
purposes without documented effect on local climates. There
is nothing in the proposed actions to suggest that such effects
will now be exhibited. Mining will take place, parcel by parcel,
over a period of 30 years. As a result, no large blocks of land
will be stripped of vegetation at any given time. The larger
drainages will be preserved. Small drainageways feeding these
larger ones will be created in the reclaimed land. These
drainages will be designed and vegetated in a way so as to
maximize water quality benefits and flood control, as was
discussed in the Draft Environmental Impact Statement.
RESPONSE W-64
The entire Duette Mine site is subject to permitting at numerous
regulatory levels. In addition to the environmental considerations
tions considered during the NPDES/EIS process, runoff is specifically
203
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addressed and regulated through State of Florida Dredge and Fill
permitting procedures and storrrwater control review. As discussed
in the DEIS, runoff from active mining and reclamation areas,
roadways and beneficiation plant area will be collected in
drainage ditches and routed to the recirculation system for
treatment, thereby reducing the potential for non-point source
pol1ut ion .
RESPONSE W-65
Mining of minor tributary streams and bayheads adjacent to major
streams will unavoidably contribute to water quality degradation.
This was one purpose for preserving 25% of Category 2 tributary
and headwater wetlands. Also, safeguards have been built into
the mining plan so as to prevent water quality parameters from
dropping below the minimum threshhOld values specified by
Pertinent regulatory agencies. (See Response W-21.)
RESPONSE W-66
The average rate of discharge to the North Fork of the Manatee
River during times of discharge will be 1,231 gallons/minute
ar>d not the 35 ,700 gallons/minute incorrectly specified in
Cormment W-66.
No ambient water quality standards applicable to the receiving
waters are expected to be exceeded under any of the examined
conditions of stream and effluent discharge rates. Under
conditions of average minimum stream flow and maximum effluent
fluoride loading, the fluoride concentration in the North Fork
may be expected to increase to 5.7 mg/1 at the point of mixing.
This projected fluoride concentration is less than 60 percent
of the state fluoride standard of 10 mg/1 applicable to Class
* 11 fresh waters.
Pointed out in Section 4.3 of the Surface Water Quality
Resource Document, under the extremely infrequent condition of
Minimum stream flow coincident with maximum allowable effluent
fluoride discharges from P.O.D. 002 and 003, the resultant
204
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fluoride concentration at the head of Lake Manatee (Station 10)
would be approximately 1.7 mg/1. This level of dilution (from
10 mg/1 to 1.7 mg/1) would be accomplished with runoff from
approximately 80 square miles or 65 percent of the entire Lake
Manatee watershed, i.e., all of the watershed upstream of Station
10 (U.S.G.S. Gauging Station No. 23000). Taking into account
runoff from the remaining 43 square miles of the watershed
between Gauging Station 23000 and the Lake Manatee dam, fluoride
concentrations at the Manatee County Water Plant intake would
be further diluted to a level well below the state fluoride
standard of 1.56 mg/1 for Class I-A waters.
RESPONSE W-67
The hydrogeo1ogic system which exists in this area of the state
is basically a two-layer leaky-artesian/water-table system. This
means that water from the water table leaks downward into the
artesian system. "When withdrawal from the artesian system
commences, a cone of depression is formed which grows until
sufficient water is captured within the flow network it forms
to satisfy the withdrawal rate. In a leaky-artesian system,
cessation in growth of the cone (steady-state condition) is a
result of the capture of additional recharge. Thus, of the 10
mgd withdrawn, only about 6 mgd will be supplied by recharge
within the flow net of the withdrawals; the remaining 4 mgd will
be captured from the regional flow system. At a distance of
about 5 to 6 miles down-gradient of the mine, the potentiometric
contours are unaffected by the Estech withdrawals, indicating
that the regional flow pattern has been reestablished and that
losses resulting from of the withdrawal are negligible. The
4 mgd of regional flow captured by the withdrawal have been
replaced by additional recharge not captured in the flow net.
The DEIS (p. 78) described a "worst case" approach to evaluating
the impact on the freshwater/sa1twater interface. This
volumetric approach assumes no recharge of any amount nor the
capture of regional flow. Even with these severe constraints,
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the movement of the interface is estimated to be only 102
feet/year (1 mile in 52 years).
The USGS (1979) indicates that rural groundwater use in Manatee
and Sarasota Counties in 1977 was (6.48 + 6.987) 13.46 mgd.
The self-supplied industrial withdrawal was (3.35 + 2.92) 6.27
mgd for citrus and food processing. Irrigation withdrawal was
(40.98 + 22.73) 63.35 mgd, primarily for truck farming, citrus
and pasture. The 1977 reported withdrawal by Sarasota County
was 9.5 mgd, primarily for the City of Sarasota from the Verna
Well Field. The pumpage of these existing uses, the vast
majority of which lie coastward of the Estech property, would
undoubtedly have more impact than the proposed project on the
movement of the interface
RESPONSE W-6S
It is generally assumed that vegetation is controlled to a large
extent by soil parameters and that any given vegetation typ
is restricted to a given soil type or several related soil
types. Agricultural crops (or at least yields) definitely show
such relationships. Serpentine soils are often cited for their
remarkably distinct indigenous floras, as compared to those
floras of adjacent, non-serpentine soils.
In Florida, the often close relationship between soil type and
vegetation is not seen, or where it is observed, notable
except ions are cornnon. For example, see the article by C. I.
Coultas, A. F. CI ewe 11, and E. M. Taylor, Jr., "An Aberrant
Toposequence of Soils Through a Titi Swamp", published in the
journal of the <¦>
-------
the influence of the vegetation and not v i ce versa. Also one
might argue that near-surficial limestone or argillic horizons
change the character of the soil. Such soils are often more
fertile and support a greater species composition, but the basic
corrmunities are generally the same as in similar habitats
containing deeper sterile sands.
Second, the absence of significant topographic relief and the
rather uniform warm wet climate contribute to uniform development
of soils in Florida.
Two major environmental factors control the vegetation in
virtually all habitats in Florida: the soil moisture regime
and the frequency and intensity of fire. Soil parameters, other
than soil moisture, collectively constitute a distant third set
of factors influencing the vegetation. Some vegetation types
correlate well with certain soil types in Florida and can be
mapped within the same mapping unit. Such correlations, though,
do not necessarily infer a direct influence of soil over the
vegetation. Usually the soil and the vegetation have developed
independently in resppnse to a particular surface hydrology.
In addition, there is usually at least some interaction between
soils and vegetation, each influencing the development of the
other .
In phosphate strip mine reclamation, the soil type is not nearly
as important to know as the soil moisture regime and the texture
of the surficial horizon. Plant response can be predicted
adequately from this information, even if it is rather general.
If the standard terminology for soil nomenclature were applied
to the reclaimed sites, only the more generalized, higher
categories in the current system of soil taxonomy could be used.
More specific soils series are not applicable because they
pertain only to soils with well developed profiles. The soils
of recently reclaimed sites consist merely of parent materials
which will take decades of development before the characteristic
soil horizons of recognized soils series become evident.
207
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RESPONSE W-69 .
Native soils are relatively sterile sands. Reclaimed lands that
contain a higher proportion of clay potentially will be more
fertile and will have better moisture retention than nat.ve
soils. Within a few years after mining, the reclaimed areas
should be at leas, as heavily vegetated as they were before
min ing.
RESPONSE W-70 .
rpnu i res that reclaimed phosphate
The Florida Administrative Code requires in
j • Ji,+0|v This practice minimizes tne
mines be revegetated irtmediat y. ,a + ^r
possibility of sheet erosion and thereby protects receivingw ter
bodies from turbidity, siltation and possibly undesira y i
levels of available nutrients. Wind erosion is also reduced,
. . j,,e+ Planting any cover crop
thereby minimizing fugitive dus . .
* ,+ Rah i a erass is conrmonly used as a
requires an energy output. Bah g
.. l;ii t« low cost, low maintenance
cover crop because of its avail y>
and raDid and effective
(and thus low energy requirement), eil(~h
ability to form a dense sod. The ability of turf gr
as bahia to form a topsoil is well known. In the abse^
, . inr a Biven parcel of reclaimed land,
any particular land use for g . • t
_ : c i r ab le from the standpoint
the establishment of bahia grass
°f topsoil development.
T. . to initially reclaim for pasture grass
The applicant's proposal to mi y , t
is assumably largely In response to miniimum reqU!urements^of ,ta
and local land reclamation requirements. P an ing *
Of pasture grass provides compliance with state aw r ng
estab 1 i shment of ground cover after reclamation for er on
contro,. The local (Manatee County) mining
squires that the rural areas where mining occurs be erned
agricultural uses upon completion of mining a
Pasture also meets this requirement. It should be noted
the mining operation is viewed to be a temporary '»"d
the ultimate, long-term land uses " this t ime
subsequent land owners. It cannot be deter oasture
if +u i lareelv reclaim lands to pasture
the applicant's proposal to larg j
208
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grasses is a long-term commitment to an engery-intensive
agricultural practice.
RESPONSE W-71
The comment is correct in so far as the soil microbiota has not
been subject to study on mined lands in Florida. The corrment
also extends to virtually all soils of natural plant communities
in Florida. Microrhizal fungi are prominent in most natural
communities and are known to improve the colonization of plants
on reclaimed strip mines elsewhere in the United States.
The chief explanation for the negligible reco1 onization of
indigenous upland vegetation (i.e., of flatwoods, scrub, palmetto
prairie) is not necessarily the absence of particular soil
microflora. It is more likely the unavailability of seeds and
other propagules. An examination of previously mined lands which
have been allowed to revegetate without interference from man
shows that a particular assemblage of species typically becomes
established and persists indefinitely. Normal plant succession,
as it is usually described in ecology tests, is arrested by these
persistent plants which are sufficiently competitive to exclude
the invasion of dominant species that occupied these lands before
mining. The persistent species tend to be weedy or brushy, many
of them having been introduced from the tropics and naturalized.
A more desirable mixture of native forest species develops
typically only adjacent to undisturbed stream-side forests which
serve as a seed source. This was the rationale for preserving
some Category 2 Tributary and Headwater wetlands.
RESPONSE W-7 2
You are correct in pointing out that soil biology has been
generally neglected in the Estech and other EIS's. However,
it is hoped that reclamation can proceed and be successful
without a detailed knowledge of soil biota. Experience has shown
that self-maintaining vegetational recolonization is generally
unavoidable following land disturbance and soil redistribution.
However, the quality of the se1f-maintaining, living communities
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is what an acceptable reclamation plan must address. Species
diversity and indigenousness have been considered in the Estech
reclamation, and large scale efforts are an integral part of the
methodologies. (See Reclamation Methodology Resource Document.)
These efforts must prove successful as required by State and
Local reclamation plan approvals.
RESPONSE W-73
A withdrawal schedule of 13 mgd for the first three years -
decreasing thereafter to 10 mgd for the rest of the 1 He of the
mine - is mandated by the Consumptive Use Permit d guidelines published by the Administration or any
Federal or state agency responsible for promulgation of ru e
^r the protection of employees. No worker protection measur
specifically aimed at preventing radiation exposure have. been
Planned by Estech for implementation at the propose
Mir»e. As the writer pointed out, epidemiological
210
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presently underway investigating a possible association between
lung cancer and working in the phosphate industry. Estech is
participating in one such study which is being conducted industry-
wide by the University of North Carolina at Chapel Hill. If
the results of these studies indicate that protective measures
are needed for employees, it is expected that they will be made
mandatory by state and Federal regulations. Estech will be
required at that time to implement the applicable protective
measures. In the meantime, certain aspects of the working
conditions associated with any particular job at the mine or
beneficiation plant may provide de facto protection from
radiation exposure. For example:
1) The dragline crew is protected by the fact that they work on
a machine which is totally enclosed. The operator's cab
is air-conditioned, and the machinery decks are highly
ventilated with filtered air in order to cool the electric
motors. In addition, the crew is located some 50-250 feet
from the mine pit.
2) The crews responsible for the slurrying of the matrix for
transport to the washer also work inside air-conditioned
hydraulic gun sleds. It is not necessary for them to be
in continuous contact with any material.
3) The washer, feed preparation and sizing sections are all
open-air structures, the operators again do not handle
material for any great length of time, and no dust evolves
due to the fact the material is separated by washing with
water.
4) The flotation plant is enclosed because of the type of
equipment used. However, the crew room is air-conditioned.
The crew does not inhale dust, because the material is still
being processed wet. The Flotation Building is adequately
ventilated, because the first floor is some 10 feet above
grade and the floor is grated. The building is only enclosed
from the top and sides. Adequate air circulation is
maintained to prevent any build-up of harmful gasses or
f ume s .
5) The personnel who work in the dry rock area are protected
from exposure by proper ventilation, pollution control
equipment and masks while working near dry rock loading
stations and silos, and by the fact there is only limited
contact with the material.
211
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RESPONSE W-75
Because what constitutes either a safe working level or excessive
occupational exposure for tunnel workers has not yet been
established, Estech has not planned monitoring of the tunnels.
Depending on the outcome of the ongoing studies mentioned in
the preceding response, it is expected that a safe working level
will be established and Federal and state regulations will
require it be maintained and monitored. At that time, the
precise type of monitoring equipment required and an appropriate
monitoring program can be determined. In addition, Estech has
advised EPA that it will install an appropriate monitor for radon
gas unless the study results prove it unnecessary.
RESPONSE W-76
Consultation with the Department of the Interior was officially
initiated by EPA on February 14, 1980. The reconnmendat ions pre-
sented in the Department's Biological Opinion will be imposed
as conditions of the proposed NPDES permit. Copies of all
°fficial corresondence documenting the consultation process are
Presented herein. Also presented are letters indicating Estech's
1 n i t i a 1 steps to comply with the Department's recommendations.
RESPONSE W-77
Several points in combination address the concern expressed for
the Myakka River Basin. First, it should be emphasized that,
as the writer was aware, the proposed mine is not in the Myakka
River Basin and would have no direct or secondary effects on
that basin. Secondly, the DEIS is clearly and deliberately a
site specific" EIS and accordingly has limited application to
any other site. The Estech DEIS was the first site specific EIS
to be based upon the information and recommendations developed
ln the generic EIS - the Central Florida Phosphate Industry
Areawide EIS - published by EPA in 1978. The Areawide EIS does
recorrmend certain mining and reclamation practices for all new
mines in Central Florida and could certainly be considered
Precedent setting in a general sense. However, any new source
212
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February 14 1930
REF- 4SA--EIS
JTenneth E. Black
Regional Director
D. S. Flah and Wildlife Service
Region IV
Richard B. Russell Federal Building
75 Spring Street S- W.
Atlanta, Georgia 30303
Dear Mr. Black*
The Fstech General Chemical Corporation (formerly Swift) proposes to develop a
new phosphate mine in Manatee County. Florida, The raining operation would re
quire a new source NPDES permit and is therefore subject to the requireaents
of NFPA. The DEIS for the Estech proposal was published in October of 1979
A copy was provided to IT. fi. F, W. S, for camraent in accordance with the Fish and
Wildlife Coordination Act: however this Agency has not previously initiated
consultation procedures pursuant to Section 7 of the Endangered Species Act.
Please consider this letter a formal request from EPA foil consultation in
accordance with the provisions of the Act.
A list of threatened and endangered species that may be found in the project
area has previously been requested and received by the consultant preparing
the EIS on behalf of EPA. We would Appreciate confirmation of the accuracy
of that information as contained in the DEIS. Further,Section 7 (c) of the
Endangered Species Act provides that the required biological assessment may
be undertaken as part of a Federal agency's compliance with NPTA. as would be
the case with the Fstech EIS. Therefore. please advise us as to the adequacy
of the biological assessment contained in the DEIS and Biology and Ecology
Resource Document. Lastly if the assessment Is adequate then we require a
letter stating the Service's biological opinion pertaining to the action pro-
posed in the DEIS.
To expedite matters. I am sending the Estech DEIS and the Biology and Ecology
Resource Document directly to Mr. David Peterson in the U.S.F.V.S. office in
Jacksonville. Florida. In future handling of the Central Florida phosphate
EIS's we will begin coordination with Mr. Peterson during the scoping process
so that consultation procedures if necessary can be initiated at a such
earlier time.
Sincerely.
A. Jean Tolman
cc- David Peterson
JTolman/ar/2-14-80
213
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
75 SPRING STREET, S.W.
ATLANTA, GEORGIA 30303
WAR2 71980
Ms. A. Jean Tolman
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
Dear Ms. Tolman:
We have received your February 14 letter regarding consultation on a
permit for a phosphate mine in Manatee County, Florida. In future
correspondence, please refer to our fog number on this project, 4-1-80-A-152.
Our Jacksonville Area Office has the draft impact statement and the
Ecology Resource Document under review, and will soon determine if the
information is adequate to prepare a biological opinion, and if the
species list is accurate. If the list and information are satisfactory,
a Biological Opinion will be issued. Should more information be required,
we will contact you soon.
We concur with your determination to begin project coordination with
the Area Office. In our effort to reduce paperwork and save time,
we are now asking federal agencies to request the list of sPe^|?
directly from the Area Office, rather than from the Regional Office.
Thank you for your interest and support of the endangered species
Program.
Sincerely yours
Regional Director
214
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
75 SPRING STREET, S.W.
ATLANTA, GEORGIA 30303
Ms. A. Jean Tolman
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
Dear Ms. Tolman:
This presents the U. S. Fish and Wildlife Service's Biological Opinion
regarding Estech General Chemical Corporation's proposed development of
a new phosphate mine in Manatee County, Florida (Log No. 4-1-80-A-152)
and Its potential Impact on threatened and endangered species. We
concur with the list of species that was presented in the Draft Environmental
Impact Statement (DEIS). They were bald eagle, red-cockaded woodpecker,
American alligator, Eastern Indigo snake, and Florida panther. We have
determined that the bald eagle, Florida panther, and red-cockaded
woodpecker will not be affected by this project. The two threatened
species that were Identified as being adversely impacted by the mining
operation were the American alligator and Eastern indigo snake. Consultation
was initiated on February 14, 1980. The phosphate mine and beneflclatlon
facility will be located 1n northeastern Manatee County. The proposed
complex encompasses 10,394 acres of which approximately 6,600 acres are
suitable for mining.
As indicated in the DEIS, the alligator "will decline somewhat during
the mining operation but will Increase above present levels with the
addition of 384 acres of lakes and a 15 percent increase 1n other wetlands
when reclamation is completed. The Eastern indigo snake will decline In
numbers with the destruction of swamps during the mining operation, but
should recoup their former numbers after reclamation 1s completed."
Insofar as the Indigo snake is concerned, this 1s partially true.
However, the upland habitat which 1s also utilized by this species, will
be altered with resultant loss of some animals during the mining operation.
The DEIS indicated that, with the exception of a 100-acre area, all land
disturbed by the operation will be restructured and/or backfilled with
waste material, and revegetated either by natural succession or by
artificial planting. It appears that the reclamation effort for the
lakes and wetlands will be appropriate for the alligator.
Therefore, after reviewing the information provided 1n the DEIS, it 1s
our opinion that the above action 1s not likely to jeopardize the continued
existence of the American alligator or Eastern indigo snake and will
only temporarily modify habitat essential for their continued existence
In that specific area. An administrative record of this consultation 1s
on file in our Jacksonville Area Office.
215
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Due to the possibility that Eastern indigo snakes will be destroyed
during the mining operation, we strongly recommend that Estech Chemical
contract with a qualified individual, holding a permit, to recover
indigo snakes from the work area for relocation. For further information
regarding qualified individuals and possible relocation sites, please
contact Mr. Don A. Wood, Endangered Species Coordinator, Florida Game and
Fresh Water Fish Commission, 620 South Meridian Street, Tallahassee,
Florida 32301.
It may also be beneficial for individuals who will work in the field to
view a slide program describing the Eastern fndigo snake and comparing
it to other species of snakes that may be encountered in the mining
area. This may result in a number of Eastern indigo snakes being saved
from destruction.
After reviewing the available information on this project, it appears that
cumulative effects do not apply in this instance. However, if modifications
are made in the project or if additional information becomes available
regarding threatened and endangered species and potential impacts, then
consultation should be reinitiated. This Biological Opinion is intended
to assist the Environmental Protection Agency in meeting its responsibility
under Section 7 of the Endangered Species Act, as amended.
Sincerely yours,
Regional Director
216
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Estech General Chemicals Corporation
May 13, 1980
Nr. Don A. Mood
Endangered- Species Coordinator
Florida Game * Presh Hater. Fish Commission
620 South Meridian Street
Tallahassee, Florida 32301
Dear Mr. Wood:
The U. S. .Fish and wildlife Service has issued a "no jeopardy"
Biological Opinion regarding the proposed Estech Duette Mine.
Due to the possibility that Eastern Indigo Snakes will be
destroyed during the mining operation, it was recommended that
Estech contact a qualified individual who would be able to recover
the Indigo Snakes for relocation. I was advised to write you
and ask for names of such qualified individuals and any relocation
sites that might be available.
I must tell you that our actual mining operation is still 3-4
years away. Therefore, there is no great emergency to proceed
with this item. My only reason for writing at this time is to
get something in the file as to names and addresses and possible
location sites.
I look forward to hearing froe you.
Very truly yours
ESTECH GENERAL CHEMICALS
Joseph E. Davis
Manager of Projects
JED/nal
Enc.
cc: Ms. A. Jean Tolraan
w/o Attachment
217
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Florida Game and Fresh Water Fish Commission
CECIL C BAILEY
Chairman, Jacksonville
THOMAS L. HIRES SR
Vice Chairman, Tampa
DONALD G. RHODES D D 3
West Eau Gallie
R BERNARD PARRISH JR
Tallahassee
C TOM RAINEY DVM
Miami
ROBERT M. BRANTLY, Executive Director
H E WALLACE, Assistant Executive Director
FARRIS BRYANT BUILDING
620 South Meridian Street
Tallahassee, Florida 32301
May 22, 1980
Mr. Joseph E. Davis
Manager of Projects
Estech General Chemicals Corporation
First Commercial Bank Building
A10 Cortez Road, West
Bradenton, Florida 33507
Mr. Davis:
Thank you for your May 13 letter regarding relocating indigo snakes.
Upon any and all encounters with indigos during your mining operations,
you should contact Mr. Paul E. Moler, Florida Game and Fresh Water Fish
Commission, 4005 South Main Street, Gainesville, Florida 32601, 904/376-6481.
You may contact me (904/488-3831) should Mr. Moler be unavailable. By
copy of this letter I am asking Mr. Moler to contact you and provide
guidance as to how any encountered indigos should be handled and stored
until one of us can retrieve them.
Cordially
Don A. Wood
Endangered Species Coordinator
7766/mms4/33
CCJ Paul Moler
218
-------
mine proposed for the Myakka Basin would also require a site
specific EIS, and full consideration would be given at that
time to any river designated, or being considered for
designation, as a Wild and Scenic River. Furthermore, EPA's
obligation to coordinate with the Department of the Interior
is clearly established by law, under the Wild and Scenic River
Act, and by EPA's own implementing procedures on NEPA (40CFR
Par t 6) .
RESPONSE W-78
EPA has complied fully with 36 CFR Part 800 and 36 CFR Part 63;
documentation of this compliance is presented on the following
pages. The Parrish Mounds are not on the subject property and
will not be affected by the proposed project. Although the
Keeper of the National Register has not yet made a determination
of eligibility for the Carruthers Mound, EPA has, in accordance
with Section 63.2 of 36 CFR, proceeded on the assumption of its
eligibility in order to obtain conrments from the Advisory Council
of Historic Preservation. fn brief, the Carruthers Mound will
be preserved from mining and any associated disturbances, and
both the Advisory Council and the State Historic Preservation
Officer are satisfied with the steps being taken to assure
preservat ion.
Lastely, as stated in this agency's July 10, 1980 letter to the
Advisory Council, EPA is in the process of securing the addition-
ai information needed by the Keeper of the Register to make the
eligibility determination. Additional archaeological field work
also performed during July 19-25, 1980 and a report of that
investigation will shortly be submitted to the Keeper of the
Nat ional Register.
RESPONSE W-79
The proposed clay settling area embankments will be designed
and constructed of earthen materials in accordance with the
stringent safety standards required by Chapter 17-9 of the Rules
of the Department of Environmental Regulation. Similarly
219
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April 29, 1980
REP: 4SA-EIS
Mr. L. Ross Morrell, Director
Division of Archives, History and Records Management
and State Historic Preservation Officer
Florida Department of State
401 Bast Gaines Street
Tallahassee, Florida 32304
Dear Mr. Morrell:
, , . -..kn-hed a Draft Environmental Impact Statement
In October of 1979, this agency publ • - (phosphate) Mine in Manatee County
for the Estech Chemicals Corporat f h Sunfnary Document and a copy
Florida. A copy SsoT^cument are provided
of the Archeological and Historical Fr p
for your review.
the Department of the I»t«ior th.
VB». Y« attention 1. r.^rc.» were per-
The referenced evaluations of archeolog purpose of this letter
forned for EPA by tM EM third petty r^^ri^r^tlon Officer In
is to carry out consultation "ijh t ^ che identification of resources,
accordance with 36 CFR Section ± the National Register and deter-
determination of eligibility for illusion In {aa^mtly by EPA
mination of effect. All three wlth the State Historic Preservation
in preparing the DEIS; however, consultation witn
Officer wa8 inadvertently omitted.
. . .u. National Register was consulted
Briefly, as the enclosed ^ect area included in the National
to identify any properties inthe J* all properties possessing historical,
Register; none were identified. Se?!"^'viltte located within the proposed
architectural, archeological, orvcuiC""i T^iter Criteria set forth in
project area were
subjected to the N.tlon.1 „,!<* appear.
Section 800.10. The DEIS Identified a .ltej^*"™ ^ ^ of
to meet the significance ceitetia ont g preliminary determination
regional archeological importance^the Document. (The Parrish
J» 1» the enclosed Archeologlcal K»°ur ^ propert5, ^
Mounds, also mentioned in the DOI letter, are not
are not affected by the proposed project.;
if an Agency Official determines that a
Section 800.4(a) (2) requires that if an Agen y mBt in writing, an
Property appears to meet thcCriteri. re8peCting the property's ellgl-
opinion from the Secretary of the p - attached forms have been
Hlity for inclusion in the National R g ctlon 63>3 set8 forth procedures
filled out for that purpose. FurtherHistoric Preservation Officer agree
to be applied when the Agency and the , , the forms is meant to
a property la eligible. The EPA f d.acrlbed in Section 63.3.
®atisfv the requirement for the statement
-------
-2-
If, in fact, you do agree that the Carruthers Mound is eligible, then please
forward the forms and supporting materials to the Keeper of the National
Register along with a statement of your opinion.
Thirdly, the Criteria of Effect and Criteria of Adverse Effect, set forth
in 36 CFR Sections 800.8 and 800.9, respectively, were applied to determine
if the proposed project would have an adverse effect on the Carruthers Mound.
We have made a preliminary determination that the site would be adversely
affected due to "isolation fwom or alteration of its surrounding environment."
Please advise us as soon as possible if you concur with this determination and
with the mitigative measures proposed in the DEIS. Those mitigative measures
could form the basis for a Memorandum of Understanding between this agency,
the State Historic Preservation Officer, and the Advisory Council on Historic
Preservation.
If I ipaad Section 800.4 correctly, it is my responsibility to request comments
from the Advisory Council after the determination of adverse effect has been
made. I would like to do that as soon as. possible to avoid causing a costly
delay for the applicant. Any help or adviee you can offer in this process would
be greatly appreciated.
Sincerely,
Original Signed By
A. Jean Tolman
EIS Project Officer
Enclosures
JTolman/ar/4-29-80
221
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{
rg ai jitet*
STATE OF FLORIDA
THE CAPITOL
TALLAHASSEE 32304
(904) 48Q-Q47E
George Firestone
May 15, 1980 In reply refer to:
SECRETARY OF STATE
Mr. Louis Tesar
Historic Sites Specialist
(904) 487-2333
Ms. A. Jean Tolman
EIS Project Officer
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
Re: April 29, 1980 letter and attachments
Review of Cultural Resource Assessment
Survey Report of Duette Phosphate Mine
and National Register of Historic Places
Inventory -- Nomination Form for
Carruthers Mound (8Mall9),
Manatee County, Florida
Dear Ms. Tolman:
In accordance with the procedures conatined in 36 CFR
Part 63 and 36 CFR Part 800, we have reviewed(1) the above
referenced project for possible impact to archaeological and
historic sites and properties listed, or eligible for listing,
in the National Register of Historic^ Places, and (2) t
National Register o± Historic Places Inventory - Nomination
Form for the Carruthers Mound (8Mall9) in Manatee County,
Florida. The authorities for these procedures are the National
Historic Preservation Act of 1966 Law 89-665) as 94
amended by P.L. 91-243, P.L9 3"54> P ^"4J£' 0!£ctiin* and
45 8, and Presidential Executive Order 11593 ( Protection
Enhancement of the Cultural Environment ).
We have reviewed the "Cultural Resources Resource Document
Draft Environmental Impact Statement, Swift Agricultural Chemicals
Corporation Duette Mine Site, Manfee c°unty, Fiorida (19?9)
by J. Raymond Williams and Roger T. Grange. We have a
"Viewed the b?Ca?f " McMurray
for EcoImpacry oHhe basis of these two documents particularly
the latte? we concur with the determination that the Carruthers
Mound (Mai 19) appears to satisfy the criteria for nomination
FLOHIPA - STATE OF THE ARTS
009
-------
Ms. A. Jean Tolman
May 15, 1980
Page Two
to the National Register of Historic Places, and have signed
item 12 of the nomination form.
If you have any questions about our comments, plaese do
not hesitate to call or write.
On behalf of Secretary of State, George Firestone, I
would like to thank you for your interest and cooperation
in helping to protect and preserve Florida's historic
resources.
State Histoj^fc Preservation
Officer
LRM:Tlt
Enclosure (1)
cc: Carol D. Shull
223
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May 15, 1980
REF: 4SA-EIS
The Keeper of the National Register
National Register of Historic Places
Heritage Conservation and Recreation Service
Department of the Interior
440 G Street, N. W.
Washington, D. C. 20243
Dear Sir:
The Environmental Protection Agency is preparing a Final Impact Statement
for the £8tech General Chemlc#ls Corporation Daette Phosphate Mine in
Manatee County, Florida in consideration of issuing a naw source NPDES
permit for the mine operation. Accordingly, we are in the process of
complying with 36 CFR Part 800 and 36 CFR Part 63, including consultation
with the State Historic Preservation Officer for Florida. This agency is
in agreement with the State Historic Preservation Officer that the
Carrnthers Mound, located on the proposed site and described in the
attached documents, meets the National Register Criteria set forth in
Section 800.10 and is eligible for inclusion in the National Register.
This statement of agreement is intended to meet the requirement of Section
63.3, thus qualifying this agency and the State Historic Preservation
Officer to receive your written determination within ten working days of
receipt of this letter. Since we will not publish the FEIS until we have
fully complied with Parts 63 and 800, your timely response will be greatly
appreciated.
Sincerely,
Original Signed By
oJR/iscn
A. Jean Tolman
2IS Project Officer
Enclosures
JT°lman/ar/4--30-80
224
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CONSERVATION CONSULTANTS, INC
POST OFFICE BOX 35 • PALMETTO, FLORIDA 33561
TELEPHONE 813-722-6668
Consultants in Environmental Biology and Engineering
June 6, 1980
Ms. Jean Tolman
Project Officer, EIS Branch
ENVIRONMENTAL PROTECTION AGENCY
345 Courtland Street, NE
Atlanta, Georgia 30308
Dear Ms. Tolman:
Pursuant to your request and in accordance with the applicable procedures of
36CFR regarding preservation of archaeological and historic sites, Conservation
Consultants, Inc. has specifically (±100') located the Carruther's Mound
(8-Ma-l19) on the attached 1" = 1000' aerial photograph of the Duette Mine
site. The mound falls well within an area of the mine site that will not
be mined. The limits of mining lies 2,150 feet to the west of the mound,
1,020 feet to the south and 620 feet to the north. To the east and south
of the mound lies the north fork of the Manatee River and its floodplain
which is to be preserved.
The dragline corridor, pipeline and road right-of-ways occur 620 feet to the
northeast of the mound at the closest point. No buildings, roadways, pipelines»
excavations or ground disturbance will take place within 400 feet of the mound.
Should fencing of the mound be determined to be an appropriate method for
preservation of the Carruther's Mound, Estech has agreed (personal communication
February 3, 1980) to fence the area in accordance with negotiated specifications'
If you have any questions regarding this matter, please feel free to give me a
cal 1.
Sincerely,
H. Clayton Robertson
Assistant Project Manager
HCR/lah
Enclosure
cc: J. Davis
R. Rhodes
Ref. No. 0100-511
J
-------
'«( p,to^
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET onri,c
ATLANTA, GEORGf A S3§68 30365
m\rr
June 12, 1980
JUN 1* I960
JUN 16 1980
.
Kmm-mzm izmh
DIVISION OF ARCHIVES
History & Records
- Management
REF: 4SA-EIS
L. Ross Morrell
State Historic Preservation Officer
Division of Archives, History and Records Management
Florida Department of State
The Capitol
Tallahassee, Florida 32301
Dear Mr. Morrell:
* w 1QR0 notifying EPA that the nomination
Thank you for your letter of May , J and forwarded to the Keeper
forms for the Carruthers Hound h received a determination
of the National Register. Although we *e^th the requlred consul-
Of eligibility from the Keeper, we are p pliBibie.
tation under the assumption that the s
t -i A*i-aA Anril 29 1980, concerning the proposed Duette Mine
In ray letter to you dated April » EpA had appiied the Criteria of
in Manatee County, Florida, n cfc cFR Sections 800.8 and 800.9)
Effect and the Criteria of Adverse preliminary determination
to the proposed project. As a result EP<1 «de <. p ^ ^
that, although the Carruthers to "isolation from or
project would have an adverse etre ^ Estech DEIS proposed miti-
alteration of its surrounding ^^^f„levfthe data contained in the
gation by archeological excavatio
Mound.
I subsequently discussed the situation Preservation, who
Representative of the Advisory Counc nreference for preservation when-
emphasized the Advisory Council s s o g £o we have renewed our
ever possible as opposed to exca^ati°£; preservation of the site. Under
efforts to find a means of assuring t ltatlt ^as refined the location
EPA's instructions, the EIS third party c ^ ^ associated construction
of the Mound in relation to the ProPos® „ribed in the attached letter and
activities. Its relative location is
map.
j cr.f-5 nt-pd activities can be kept well
Since it appears that all mining an as^ ^ adequateiy protected from
away from the site and that the site nrolect will have an affect on
disturbance, EPA concludes that the proposed project vu
226
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-2-
the Carruthers Mound but that the effect will not be adverse. To guarantee
protection from disturbance, the following would be imposed as conditions of
the NPDES permit:
1. Estech would be required to maintain the mining and construction
distances described in the attached letter, with absolutely no
activity approaching within 400 feet of the Mound.
2. Estech would be required to erect a clearly marked fence at a
minimum radius of 400 feet from the Mound except on the south-
eastern quadrant which is protected by the preservation of the
river and floodpJLain. Following cessation of mining and construction
activities, the fence would be removed to prevent calling attention
to the mound.
If you concur with the finding of "no adverse effect" given the imposition of
the conditions described, please indicate your concurrence by signing on the
line provided below.
Sincerely,
A. Jean Tolman
EIS Project Officer
Enclosure
00 7
-------
ED.
11593
determination of eugibiuty notification
National Register of Historic Places
Heritage Conservation and Recreation Service
Nome of property: Carruthers Mound (8-Ma-119)
Location: Bradenton, Manatee County
Request submitted by: U.S.E.P.A. A. Jean Tolman
r» . .1 Additional information received:
Date received: 5/29/80 MO°
Opinion of the State Historic Preservation Officer:
®Eligible DNot Eligible DNo Response
Comments:
State: fl
The Secretary of the Interior has
Q Eligible Applicable criteria:
Comments:
determined that this property is:
~ Not Eligible
documentation insufficient Additional materials required)
see accompanying sheet expla.n.ng add.t.ona. m
LUk
^8-265 2/79 Dal*
•"o •« 876 228
Jp/Keeper of the National Register
. Jw
-------
REQUEST FOR ADDITIONAL INFORMATION TO DETERMINE ELIGIBILITY
OF PROPERTYISI FOR INCLUSION IN THE NATIONAL REGISTER
National Register of Historic Places
Heritage Conservation and Recreation Service
Name of property: Carruthers Mound (8-Ma-119)
State: fl
Description:
Statement of significance:
After review of the documentation provided, and
consultation with SHPO staff, we have determined that there is insuffi-
cient information at the present time to' establish the eligibility of
this site. Currently, all we know is that a small test is reported
to have indicated that the mound is artificial.
(See attached sheet for continuation)
Bibliography:
Geographical data — Acreage:
UTM Reference(s):
Verbal boundary description:
Photographic coverage:
Map coverage:
Other:
Questions concerning additional information may be directed
to the National Register staff, telephone 202 343-6401.
Thank you for your attention to the above items.
FHR8-268 2/79
Keeper of the National Register
229
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Statement of Significance: We know nothing about the function age,
or cultural affiliation of the mound and therefore cannot articulate
significance on a site-specific basis of known research potential.
We understand that there are not many intact sites of any kind in
this inland area, and on this basis the SHPO feels that the site
is valuable, whether the mound represents an habitation area or
that the resource has not been surricienc y
Permit evaluation of its research potential.
We would be pleased to receive a resubmission of Jhc°r
determination of eligibility * h* °"*nd bec0mes available.
c°ntent, structure, and function or
230
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United Stages Department of the Interior
HERITAGE CONSERVATION AND RECREATION SERVICE
WASHINGTON, D.C. 20240
IN REPLY REFER TO:
Ms. Jean Tolman
EIS Project Officer
U.S. Environmental
Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
Dear Ms. Tolman:
Thank you for your letter requesting a determination of eligibility
for inclusion in the National Register pursuant to Executive Order
11593 or the National Historic Preservation Act of 1966, as amended.
Our determination appears on the enclosed material.
As you understand, your request for our professional judgment consti-
tutes a part of the Federal planning process. We urge that this
information be integrated into the National Environmental Policy Act
analysis in order to bring about the best possible program decisions.
This determination does not serve in any manner as a veto to uses of
property, with or without Federal participation or assistance. Any
decision on the property in question and the responsibility for
program planning concerning such properties lie with the agency or
block grant recipient after the Advisory Council on Historic Preser-
vation has had an opportunity to comment.
We are pleased to be of assistance in the consideration of historic
resources in the planning process.
Sincerely yours,
Carol D. Shull
Acting Keeper of the National Register
Enclosure
231
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JUly 10, 1980
HBfi 4£ftHBIS
Hr. ftofcwrt M, utley
Qcecutive Director
Advisory Owncil on Historic Preservation
1522 K Street, M. w.
Washington, O. C. 20005
Attention* Mr. Don Klina
Dear Sirt
?'G»*ic«la Corporation has appLied to this agency foe an HPCBS
P*5IBit fCmental impact Statement tor
the proposed project, and in November of 1S79 received the attached
oom*ants fro® the Department of the interior* sour attention is directed to
psrssragb one of the second page tegardinsj cos^Uanoe with 36 C** Parts 63 and
900#
In acoordance with the Deportment's letter, e&k has been carrying out the
prescribed consultation procedures with the state Historic Preservation
Officer for Florida. As a result of this consultation, the WtO has submitted
to the Keeper of the Register our request for determination of eligibility
illusion in the National Register of Historic places, it* subject of the
eligibility determination request is a sits, known a* the Csrruthers *tound,
located in the proposed project area.
request for a detent
^eoawatioa with^t^"* <*«**fyin3 th£? to m*t *** «»»**•»«* of
frame was not m,h working dawTLr 8, «i®ncy to receive a written
on 15, 2980 *M AittK>mh ths rootLs*- J?*1** of the request. «iat ti«e
««• iiwuffici^ to 4ft*, a d!S5^J!SJfi*d 1811 thMt *** <**sjmentaticn
of siigibility.
— u* f' iy-4 -
ultimately obtained.
P*mU W"0"* *>"*»» to ptmunt^ til 1"
232
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publication ana suose juent permit issuance ia likely to impose an economic
hacosnip on the applicant. ITiereforu, e£torcs to expedite the Federal proces
at this (joint seem highly appropriate. In that regard, we wish to invok.
certain portions of .tie Federal regulations. 36 Cxi' Miction 800.4 Ux) (4)
provides that the Ajeicy official may Initiate a request for the Council*;
concents simultaneous! / with a request for a determination of eli^ioility whet
the A3«rcy official an i StlK) ayree that a property meets t ie Jiational rtegistev
Criteria (as is the cise in this instance). This section turther states thai
before the Council p ovides its comments, the property awst be determine,
eligible for inclusioi in the National Register. However, Section 63.3 of 3»
CFR provides tnat, "if the property has not been accurately identified ar*
evaluated, the Keeper will inform the agency anc iJrje iitate Historic
Preservation Officer within tan working days and will reccxnrena that th<
agency follow the process set forth at 63.2. Nutwithstanoiny sue'
recotanerelation, the Ffe ieral agency or the Keeper of the National Register /aa
consider the property eligible for the purpose of obtaining the Advisory
Oourcil on Historic Preservation's comments.* (Emphasis added.) EPA elect
to follow this course of action ana, based on the assumption that thi
Carruthers Mound is eligible, suimits this letter as a request for th*
advisory Council's ccs aients. Please note the concurring opinion oL the SHR),
contained in the attacied letter dated JUne 12, 1980.
EPA in consultation *ith the SHPO applied the Criteria of Effect to th<
proposed undertaking and concluded that it mi^ht have an effect on th
Carruthers iVjound. An effort was then voaam to take all mcesfaary precaution
to preserve the site and prevent any aaverse effects. The precise relation tv
the proposed mining activity is shown on the attached mop. lhe wound tall,
well within an area o; the raine site that will not be rained. The limits o;
mining lie 2,150 feet to the west of the mound, 1,020 feet to the south of th»
mound and 620 feet to the north, lb the east and south of the inound lie th
north fork of the Maratee River and its floodplain which are to Ix: preserver
undisturbed. The dragline corriaor, pipeline and road riyht-ot-jways occur 62'
feet to the northeast of the taounri at the closest point. No buildings,
roadways, pipelines, f xcavations or ground disturbance will take place withir
400 feet of the mound. The permit applicant has agreed to fence the area ii
accordance with negoti »bed specif icatons to further protect the nound.
EPA proposes to further guarantee that the mound will be protected £ro
disturbance by imposing the following as conditions of tne ;;PDBS permit;
1. £stech will be required to maintain the mning and constructici
distances fro a tne mound as described in the preceding paragraph wit;
absolutely no activity approaching within 400 feet of the mound.
2. tstech will ta required to erect a clearly market fence at a minirauu
radius of 40) feet from the mound except on the southwest quauran*
which is protected oy the preservation of the river and floodplain.
tallowing ce.< sat ion of mining and construction activities*, the fence
wiil lie reraovsd to prevent calling attention to the raourxi.
233
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-J-
Givtsn tin; i-MTOfcOsecl «im.nQ plan ami the Loposition of the described -wrrnit
conditions, KPA ana the ivaue applied the Criteria of Averse Effect to
the uruertaKing and iave concluded that:
1. Destruction or alteration of. all or part oi trie mourn.* will not occur;
2. A sufficient unaisturbod buffer area will retaain around the .ucnind
that isolation from or alteration of the ntouna' s surrounding
environment will oe prevented;
3. Ihe undi stir bed Duffer will alse maintain the character ana seutirvj
of tne laouu i;
4. Deterioration or destruction will not result fro;- tnouixi is situated.
Please review at /o\x earliest convenience the docuiaentation provioe^_i^ this,
submission and rioti ty tiiis agency if we have satisfied our Sect ¦->*-
responsibilities.
Sincerely,
A. Jean Tolitan
a IS Project Officer
Attacimients
cc; irtoas <>
-------
Advisory
Council On
Historic
Preservation
1522 K Street, NW
Washington, DC 20005
July 18, 1980
Ms. A. Jean Tolmari
EIS Project Officer
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, GA 30308
Dear Ms. Tolman:
On July 17, 1980, the Council received your determination that the issuance
of a new source National Pollutant Discharge Elimination System (NPDES)
permit for Estech General Chemicals Corporation's Duette Phosphate Mine,
Manatee County, Florida, would not adversely affect the Carruthers Mound,
a property which may be eligible for the National Register of Historic
Places, if certain conditions were placed on the permit (see enclosed EPA
letter, dated July 10, 1980). We understand that EPA, in consultation with
the Florida State Historic Preservation Officer, has requested the comments
of the Council, as provided for under 36 CFR Part 1204.3 (formerly Part
63.3) and the Council's regulations, despite the fact that the Keeper of
the National Register has requested additional information in order to make
a determination on the eligibility of the mound. In accordance with Section
800.6(a) of the Council's regulations (36 CFR Part 800), the Executive
Director does not object to your determination.
As provided in Section 800.9 of the Council's regulations, a copy of your
conditioned determination of no adverse effect, along with supporting
documentation and this concurrence, should be included in any further
assessment or statement prepared for this undertaking in compliance with
the National Environmental Policy Act and should be kept in your records as
evidence of your compliance with Section 106 of the National Historic
Preservation Act and the Council's regulations. Please keep us informed of
any further actions that are taken to provide enough information to the
Keeper of the National Register for a determination of the eligibility of
the Carruthers Mound.
Thank you for your cooperation.
(Jo
flordan E. Tannenbaum
Chief, Eastern Division of
Project Review
A
-------
constructed modern earthen dams used for water retention have
a very low annual risk of failure of approximately 1 in 10,000.
The probability of the proposed embankment was estimated to be
a factor of 10 lower or 1 in 100,000 because of essentially zero
probability of overtopping (the most corrmon cause of dam
failures) or earthquakes and because of the strong foundation
soils. Waste clays contained in the settling area contribute
further to the low risk of failure by sealing the bottom and
sides of the settling area, thereby reducing the chances of
piping failure.
Typical uranium mill tailings dams'are constructed in an
altogether different manner and utilize waste tailings for the
embankments themselves. Because of substantial differences in
construction methods, the risks of failure of the proposed
embankment and uranium mill tailings dams are not comparable.
RESPONSE W-80
The hydrogeology of the area of the proposed project is basically
a 2-layer leaky-artesian system. The Hawthorne/Tampa formations
are the semi-confining unit between the upper, or water-table
system and the lower, or artesian system. The leakance
coefficient of this unit has been estimated to average about
.00005 gpd/ft^ (Guyton 1976). The annual average head diffe
*7 9 \ hpj*6by
between the two systems is 90 feet (DEIS Figure ^•'~
suggesting a natural recharge of about 0.13 mgd/square mi
This recharge rate is significant over the mine area
are about 2.1 mgd being recharged naturally.
RESPONSE W-81
The casing length of 150 feet indicated in the DEIS was ta ^
from Guyton (1978). This figure according to Guyton Per
v a as a minim""1
communications, 1980) was a preliminary value usea «
* -ndicates tnat
for permitting purposes. A letter from Guyton inu
* 'on IV of f *Ce >
Referenced letter is on file atT the U.S. EPA, ^e^eorgia
EIS Branch, 3^5 Courtland Street, N.E., Atlanta,
30365.
236
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the first well will be constructed through the confining unit
into the limestones of the Tampa formation. As Dr. Guyton states
in his letter, the recharge of water which does not meet the
water qua 1 i ty standards of the Consumptive Use Permit (SWFWVID,
1978) or the FDER is not being planned.
RESPONSE W-82
Each of these concerns are addressed in the Consumptive Use
Permit. Water quality records are to be provided to the District
(SWFWVD, 1978) on a monthly basis. The terms and conditions
of this permit prohibit the recharge of water exceeding strict
waterquality standards. If violations of the permit are noted,
the District may "take appropriate action to protect the
resource, including modification of the terms and conditions
of this permit." The schedule, location and type of monitoring
are included as conditions to the permit.
RESPONSE W-83
Map is provided on following page.
RESPONSE W-84
The two statements may be misleading when not reviewed in
perspective. Water levels throughout the area provide proof
that there is leakage from the water table to the artesian
aquifer. An estimate of the leakance coefficient based on
pumping tests and geology is .00005 gpd/ft (Guyton, 1978).
Using this value, and the annual average head drive across the
unit of 90 feet, an annual average leakance of 0.13 mgd per
square mile is calculated (2.1 mgd over the mine area). This
is, however, relatively low in comparison to other areas in the
state. The recharge amount is about 2.6 inches per year or about
5% of the annual rainfall. Therefore, with regard to the
question of these wetlands being prime natural recharge areas,
there is no evidence to suggest that these wetlands are locations
where surface water and groundwater are significantly
interconnected.
237
-------
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RESPONSE W-83
REGIONAL DRAINAGE PATTERN
DUETTE MINE
MINE
SWIFT AGRICULTURAL CHEMICALS CORPORATION
MANATEE COUNTV , FLORIDA
north
o , a 3
8CALS IN M(L£&
ANDAMAN AND ASSOC,. INC.
SOURCE : U.S.O S.
238
-------
The prime factor controlling natural recharge rates is the
character of the Tampa/Hawthorne Formation. As long as the
integrity of the Tampa/Hawthorne Formation remains and the head
drive across it is maintained, the impact of the reclamation
project on the natural recharge of the area will be
i ns ign i f i cant .
RESPONSE W- 85
Section 7 Consultation has been accomplished. For full
documentation and details, see Response W-76.
RESPONSE W- 86
See Response W-78.
RESPONSE W-87
Agreed
RESPONSE W-88
The comment is well taken. Pasture is only one of several land
uses that would be compatible with the reclaimed environment.
This, however, is the land use proposed by the applicant and
was accordingly assessed. The possibility of engineering surface
soils that are friable, properly drained and fertile is well
within the economic potential of reclamation technology.
Converting some lands into forestry land, particularly in light
of the favorable climatic conditions of the region, would
minimize or negate adverse impacts due to loss of timber value.
RESPONSE W-89
An economic analysis of timber vs. cattle production was not
included within the scope of the impact assessment due to the
flexibility of the land use following mining and reclamation.
The future land owner may employ the reclaimed land for a variety
of different agricultural uses which could include farming,
timber production, dairying, ranching, etc. The return of the
239
-------
existing pine flatwoods to pasture does not preclude the use
of this land froin t imber production.
A present-day economic comparison of the various agricultural
uses at this time would not be applicable at the time the land
would be available for such use, some twenty years hence.
RESPONSE W-90
Public hunting is not allowed on the property at present, and
no plans have been made for public hunting in the future. Most
of the riverbottom vegetation with its relatively high wildlife
values will be preserved from mining. The increase of aquatic
habitats after reclamation will be beneficial to wildlife,
including game species. It is doubtful, however, that specific
reclamation for wildlife purposes would be less costly to reclaim
than what is now planned. In all cases of upland reclamation,
the land is first backfilled and/or graded to final desired
topography, then seeded to various pasture grasses for soil
stabilization purposes. All tree plantings, forage grass
plantings, etc., for wildlife purposes would be additive in
cost .
RESPONSE W-91
The described inconsistency resulted from a computational erro
in the data reduction process. The error was discovered wi
a short time after publication of the DEIS, has been corrects
and appears in an Errata, Section to the Final EIS.
RESPONSE W-92
Estech has indicated it will cooperate fully with in
. includiriS
relocating any geodetic control survey monuments,
providing at least 90 days notice before relocation would
¦a for relocating
required for any monument. The funding required i
the monuments will be provided by Estech, and this finane
u NP^ES Per
Responsibility will be imposed by conditioning t"e
accord ingly.
240
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RESPONSE W-93
The concerns expressed in this comment were confirmed in the
report published in November 1979 by the General Accounting
Office and entitled "Phosphates: A Case Study of a Valuable
Depleting Mineral in America." This report found that, "As
presently-mined, high-grade phosphate deposits are being
depleted, there is a pressing public need that long-term
availability be assured in order to maintain adequate food
production... The changing phosphate supply conditions call
for a review of Government activities affecting possible new
sources of development, potential reduction in national
consumption and export policy." The report r ecorrmended, as a
prerequisite to a national policy and planning process for
phosphates, that the Department of the Interior make a thorough
review of the Nation's long-range phosphate position and report
to Congress on the future availability of phosphates. This
review, to be submitted to the Congress by December 1981, would
include a comprehensive assessment of the Nation's phosphate
reserves, a determination of the extent to which non-economic
constraints limit development, a review and evaluation of
alternatives to import dependency and a determination of
projected phosphate needs. In its official response to the GAO
report, EPA supported the conclusions and recommendations and
expressed strong interest in participation in the recorrmended
Interior-led revie.v. On March 27, 1980, the Secretary of the
Interior responded to Congress with a request that the report
date be extended to December 31, 1982. That letter is reproduced
on the following page.
RESPONSE W-9
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
Honorable Jack Brooks
Chairman, Committee on
Government Operations
House of Representatives „ 9 r- v.'-'
Washington, D.C. 20515 *
Dear Mr. Chairman:
We are submitting this letter in accordance with section 236 of the
Legislative Reorganization Act of 1970, which requires the head of a
Federal agency to submit a written statement of action taken on recommendations
made by the Comptroller General. The following recommendations were
made in the Comptroller General's Report to the Congress, "Phosphates: A
Case Study of a Valuable, Depleting Mineral 1n America," EMD-80-21,
November 30, 1979, pages 49 and 50:
...that the Secretary of the Interior make a thorough review of the
Nation's long-range phosphate position, and report to the Congress
on Its future availability, and if appropriate, to suggest legislative
actions needed to ensure supply. Such a review should be submitted
to the Congress by December 1981 and Include the following:
1. A comprehensive assessment of the phosphate
reserves of the Nation and the world. To the extent toa*
this 1s based on unverified data, the Secretary snouia
judge the reliability of such data and the neeo, if any»
for Government verification of proprietary (source;
records.
2. A determination of the extent to which non®c0J?m^c1an
-------
-2-
1977 with an intensive study of the Florida phosphate deposits. It is
being followed by additional resource, engineering, and recovery cost
studies for all other domestic deposits. When this is completed, the
Department will be seeking similar information on all foreign deposits.
All of this information will be carefully analyzed and incorporated into
the Bureau of Mines' Minerals Availability System (MAS). I would also
note that this process for studying phosphates resources is being utilized
for 33 other critical minerals. It was initiated in 1975 and it is our
objective to complete these evaluations for all these minerals by the
end of fiscal year 1985.
We also recognize the inexactness of any reserve or resource estimates
and cope daily with the problems associated with company, other government,
and private data on mineral reserves and resources. However, we believe
the statement that the "Bureau of Mines relies too heavily on unverified
proprietary data without judging its reliability" is not a complete
presentation of the practices of the Bureau's commodity specialists, and
Is misleading about the general usefulness of the Bureau 's commodity
Information and the MAS. We are constantly trying to find ways to
Improve the quality of our mineral information. However, in some cases
we will have to continue to rely on information that cannot be fully
verified. In such cases, we will continue to use the best means possible
to reduce the risks of using this information. It is important to
recognize that there is no mandatory reporting for phosphate and certain
proprietary data cannot be verified. In all cases, however, the general
reliability of the sources providing the data can and will be assessed.
Second, concerning the review of the impacts of environmental and land-
use decisions on phosphate development, I would call your attention to
the recent study completed by the National Research Council in accordance
with Sect.on 709 of the Surface Mining Control and Reclamation Act of
1977. The Council established a special task force to study these and
other phosphate-related issues. With this study as the primary source,
the Council on Environmental Quality will be making a report to the
President and the Congress. This Department 1s working very closely
with CEQ on this report and any legislative recommendations It might
make.
Third, on the issue of a review and evaluation of alternatives to dependency
on Imports and assessment of their costs, the report states that "given
the projected demand and supply for the next 20 years there is no
projected phosphate shortage." This is consistent with the Department's
most recent estimate that the United States will continue to be a net
exporter of phosphate until at least the year 2000. Additionally, just
as long-range forecasting of projected scarcities Is at best uncertain
(6A0 report, pages 13-14), so are long-range estimates of their alternatives
and costs.
243
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-3-
The report discusses one significant alternative, which is the development
of lower grade phosphate resources. While the costs of developing these
deposits are at best estimates, it should be noted that they are based
on existing technologies, which in all probability will improve considerably
during the next 20 years. As they improve, there is reason to believe
that some of the existing lower grade deposits could be mined economically,
which, when combined with higher prices, 1s likely to extend our net
exporting position well beyond the current 20-year projection. Nonetheless,
the issue of costs and alternatives to import dependency needs to be
better understood and the Bureau of Mines is scheduled to begin to look
at these issues 1n January 1981 as part of an analysis of the country's
long-range phosphate position. This analysis will utilize the Information
by the MAS.
Fourth, on the issue of estimated phosphate needs for agricultural
production and alternatives to depending on foreign fertilizer sources,
we will soon make a repuest to the Department of Agriculture for such a
report.
In response to other Issues, I would like to make the following comments.
You can be assured that we will work closely with other departments and
agencies. It is our view that no new legislation is necessary to ensure
a continued and reliable supply of phosphate for all of our domestic
needs. However, regarding the recommendation that the Department's
comprehensive assessment of phosphate reserves be completed and submitted
to the Congress by December 1981, we would ask for an extension. We are
currently scheduled to complete our assessment of foreign deposits 1n
fiscal year 1981. Thereafter, it is critical that we carefully an-lyze
all our domestic and foreign data to determine what Federal action*
should be considered to ensure an adequate supply of this mineral.
Accelerating these planned activities would reduce our capacity to
conduct similar studies for higher priority minerals such as aluminum,
chromium, cobalt, and copper where we have varying degrees of foreign
dependency. Since there is no projected shortage of domestic phosphate,
we would recommend that a report to the Congress be submitted by December
31, 1982, rather than 1981 as recommended by 6A0.
I hope this Information 1s helpful. If you have any questions, please
do not hesitate to let me know.
Sincerely,
' ^ D. MriB
SECRETARY
244
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provisions of this permit will effectively eliminate concern
about degradation of water quality within the Floridan aquifer.
RESPONSE W-95
The applicant proposed to control total project sulfur dioxide
emissions to less than 50 ton per year, a level which has been
determined to produce receptor concentrations less than PSD
levels of significance. In the course of PSD regulation
development, each criterion has effectively been an incentive
for the application of innovative pollution control methods and
equipment. In this instance, an extra level of control is
undertaken at an increased capital and operating cost that can
be justified by the 3.0 million ton per year mining rate.
Disadvantages accompanying a 1.5 million ton per year mining
rate would suggest an expenditure for a less costly pollution
control system adequate to satisfy the same 50 ton per year
emi ssion-based incentive.
RESPONSE W-96
The segment of the East Fork Manatee River proposed by Estech
for mining was found to be a Category 1 wetland (DEIS, p. 176),
i.e., not to be mined. The agency felt all Category 1 wetlands
should be preserved as these streams and associated wetlands
provide an essential synergistic support to the regional
ecosystem and that mining in such areas would ha/e an unaccept-
able adverse impact. The Case 2 plan, however, excluded all
forested swamps from mining regardless of Category or ecological
significance. Total and complete preservation of all other
forested wetlands, regardless of Category, would have led to
a significant loss of nonrenewable phosphate resources although
impact mitigation through adequate restoration was a viable
option. Therefore, the optimum resource recovery alternative
was found to be between Case 1 and Case 2 as reflected by the
proposed agency action.
We are willing to allow Estech to restore Category 2 wetlands
and will critically evaluate the results of their attempts.
245
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RESPONSE W-97
See Responses W-l, W-2, and W-1 5.
RESPONSE W-98
The concern for "ambient radiation" is not well defined in the
comment. The expression was probably meant to imply the increase
in "ambient" gamma radiation exposure rates due to the near
surface radionuclides after reclamation and return of the land
to a productive and habitable use. The "ambient" gamma radiation
levels on the undisturbed site have been measured and reported.
The various reclamation techniques will most certainly increase
the "ambient" gamma radiation exposure rate. The radioactive
series responsible for this elevated rate do have long half lifes
(or parents with long half lifes) in excess of 1000 years.
The report, Radiological Environment, attempted to estimate the
expected increases in gamma exposure rates. The average
terrestrial ganrma radiation for the site, before mining, would
produce a background rate of about 5.1 jj R/hr or 45 mrem/year for
an individual remaining on the site 24 hours per day. This is
lower than the national average of 84 mrem/year.
After reclamation, the site average will increase to about 8.8
yR/hr without any credit for the low activity overburden expected
to be used as the final reclamation layer. The added increment
should actually be much less than 32 mrem/year for an individual
standing outside for 24-hours per day. The total exposure
potential (baseline pills increment) will be less than 77
mrem/year or about 93% of the national average background.
Residence time outside, shielding by concrete slabs, roads and
driveways, and other environmental parameters will tend to
decrease the added increment.
By comparison, the single most important man-made radiation
exposure to the population of the United States is by medical
diagnostic procedures. This exposure has tended to increase
each year with the current level expected to be in excess of
72 mrem/year .
246
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RESPONSE W-99
It is very likely true that follow-up studies of possible health
effects on phosphate workers are more difficult, both
logistically and statistically, in the case of temporary
employees as opposed to regular employees. However, we know
of no evidence to suggest that Estech or any other phosphate
company makes it a practice to hire temporary employees for
hazardous jobs. The phosphate industry in general does not staff
to handle anything other than routine maintenance and operating
requirements. Outside firms are hired during major maintenance
outages. As periods of peak production or shipping occur,
temporary workers are hired to relieve manpower shortages. These
workers would not be subject to any more hazards than are regular
company employees.
RESPONSE W-100
Controlled particulate emissions from the proposed phosphate
rock drying and handling operations are expected to contain less
than two percent of particles greater than 2.0 micrometers
aerodynamic diameter. Wet scrubbing collection systems rely
on aerodynamic properties of both the particle and water droplet
collection media to achieve removal, and selectivity of removal
is greatest for the largest diameter particles present in the
gas stream.
At the conclusion of the mining/beneficiation operation, the
pebble rock and concentrate products are finally separated from
water which has been used as a means to transport the material.
Upon separation from the water slurry, the liquid contains most
of the non-adhering fine particulate matter. In fact, this
fine particulate is exceedingly difficult to remove from the
liquid and results in the need for sedimentation facilities to
recover recycle process water. Subsequent mechanical handling
of wet rock (13 plus percent moisture) produces some attrition
of the product prior to introduction as feed into the fluidized
bed rock dryers. In the dryer the product is supported by heated
247
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gas flow and is in a fluid-like state which tends to minimize
further fragmentation and abrasion.
A vigorous sieve size analysis was performed on dried pilot plant
•feed rock from the Duette site and the test results suggest that
concentrate, the greatest portion of the proposed production,
could be expected to produce relatively little fine particulate
below 40 micrometers diameter in the rock drying process.
However, a small balance of the product, pebble rock, includes
clay which is difficult to remove in the beneficiation
(mechanical agitation) process. In the drying (heating) process,
included clay is embrittled and fragmented into very fine parti-
culate matter. Therefore, major components of the controlled
emissions from the dryers would be a mixture of natural
sedimentary clay/sand and phosphate fines mixed with fine ash
from the fuel combustion process. Predominating substances
originating in the mine matrix, are characterized in the DEIS
radiological section (p. 112, Table 4.11-3) and would be expected
to exhibit Radium-226 activity levels comparable to or less than
values listed for concentrate and pebble rock. Components o.*
the matrix are otherwise relatively inert chemical species.
RESPONSE W-101
Environmental Impact Analysis must document impacts and examine
environmental effects of the proposed activity. The analysis
of effects is typically in relation to existing environmental
regulations which are based on extensive scientific and/or
recent technical information which has received general accep-
tance by the scientific community. The existing NAAQS were
designed, in principle, to protect the more susceptible
population from effects of more harmful industrial suspended
particulate substances. An assessment based upon differenceS
between industrial effects, or some adjustment to the appli03'3*1'
ambient air quality standards based upon generic industrial
effects, is not within the scope of the EIS process. Whether
or not available morbidity and mortality investigations have
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conclusively established a need to develop generic source
standards is not clear at this time.
RESPONSE W-102
Refer to Response W-55.
RESPONSE W-103
Refer to Response W-6.
RESPONSE W-1CH
The exact concern that Comment W-104 was intended to express
is difficult to interpret. The resource document defines which
of the 13 daughters of U-238 are alpha, beta and gamma emitters.
The document did not attempt to define these emissions since
their characteristics are readily available in the literature.
Garrma radiation is the more penetrating and was therefore
discussed under the headings of "Terrestrial Garrma Radiation"
and "Alteration of Terrestrial Garrma Radiation".
The terms "alpha emi ssions...is soluble" and "ore...emi ssion"
used in the comment, have limited applicability. The alpha
particle has an extremely limited range, effectively shielded
by a sheet of paper. After its energy is dissipated, it becomes
a normal helium form which is soluble in water to a limited
degree. Exposure rates to humans from "uncovered ore" is
i ns i gn if i cant.
RESPONSE W- 105
The comment is correct in that the complete recurrence of a
"natural" vegetation association on reclaimed mined land is
highly improbable. As also stated, it is probable that re-
stored of hardwood swamps will take 50 or more years to mature.
The technology is being developed to establish selected plant
communities on mined land that would, with time, approximate
natural associations in function, even though species composition
may not be exactly the same.
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RESPONSE W-106
Regarding EPA's policy for handling hazardous wastes produced
by the phosphate industry, on May 19, 1980, EPA's Hazardous Waste
and Consolidated Permit Regulations, 40CFR Part 260 through Part
26 5, were published in the Federal Register (Vol. 45, No. 98).
In these regulations, the only phosphate industry waste excluded
from listing as a hazardous waste is "mining overburden returned
to the mine site". Other phosphate industry wastes, including
slimes from phosphate ore beneficiation, leach zone overburden
and discarded phosphate ore from surface mining, are proposed
to be listed as hazardous wastes in additional regulations
scheduled for promulgation this fall. In the meantime, the
phosphate company must determine if its clay slimes or other
phosphate wastes are a hazardous waste by testing the waste
according to the methods set forth in Subpart C of 40CFR Part
261, Characteristics of Hazardous Waste. (The characteristics
Identified are ignitabi 1 ity, corrosivity, reactivity and
toxicity.) If a waste is listed or otherwise identified as
hazardous, the Hazardous Waste and Consolidated Permit
Regulations will provide for its "cradle to grave management".
RESPONSE W- 107
The design, construction and maintenance of the proposed clay
settling area embankments will be in accordance with the high
standards of safety required by Chapter 17-9 of the Rules of
the Florida Department of Environmental Regulation. Since 1972
when the revision to Chapter 17-9 was promulgated, no settling
area embankment has developed a serious problem.
Historical evidence indicates that northeastern Manatee County
is not a sinkhole prone area. In that the planned drawdown
created by the water supply system is a decrease in artesian
pressure and not a dewatering of the aquifer, the withdrawals
will not make the area more prone to collapse. The drawdown
caused by the withdrawal will be small in comparison to the
existing normal fluctuations of the water levels in the Floridan
Aqu i fer .
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RESPONSE W-108
The maximum possible precipitation from a storm event on the
area in question is 31 inches (NOAA, 1956). One inch of rainfall
on the Duette site would result in an increase in the level of
the settling area of slightly more than one inch (Appendix D,
Water Quality Resource Document). In view of the fact that the
settling area will be designed so that a minimum freeboard of
5 feet will be maintained, the probability that the settling
area will be overtopped is essentially zero.
The effect of a clay settling area dam failure on fluoride levels
in Lake Manatee was addressed in Section 5.3 of the Surface Water
Quality Resource Document. In summary, the 1,000 acre-feet of
clear water initially released from the clay settling area in
the event of a dam failure would contain enough fluoride to raise
the fluoride concentration in Lake Manatee from an average of
0.45 mg/1 to approximately 1.0 mg/1. In the long-term, fluoride
would be gradually expelled from clays deposited in the Lake
at a rate sufficient to raise the mean fluoride level in the
Lake by more than 0.004 mg/1.
While some dilute sulfuric acid will be used in the beneficiation
process, its influence on the pH of waters in the plant
recirculation system will be offset by the simultaneous use of
sodium hydroxide. The net results will be that waters discharged
from the clay settling afea - either scheduled or as a result
of a dam break - will generally be alkaline or at most slightly
acidic. Mean pH levels measured in the North and East Forks
of the Manatee River (Table 2-1, Surface Water Quality Baseline
Resource Document) ranged from 6.3 to 6.6 compared to a minimum
pH of 6.4 measured in the Estech Silver City Mine effluent
between June, 1976 and June, 1978 (Table 2-B, Surface Water
Quality Impact Resource Document).
RESPONSE W-109
State permit applications and additional Federal permit
applications for activities at the proposed Duette Mine are in
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various stages of development and are expected to be completed
by October, 1980. With regard to local land use and zoning
matters, Estech is involved in ongoing proceedings relating to
state requirements for local review and approval of a
"development of regional impact" (DRI). In November, 1978, the
Tampa Bay Regional Planning Council reconrmended approval of
Estech's application for development approval subject tb: specif ic'
conditions. In February, 1979, the Manatee CoUrityI?! ann i ng
Commission reconrmended approval of the DRI app 1i cat i on subject
to conditions and of the application for special zoning exception
filed by Estech. In August, 1979, the Board of County
Coirrni s s i oner s of Manatee County refused to grant :the special
exception under its zoning law and, on the basik; of this refusal*,
denied Estech's application for development approvaI. 1 Estech
is currently pursuing judicial and admi h i str !at i ve rferned i es' to
set aside this decision and to obtain necessary 'local govert-nme-nt
approval for the project.
RESPONSE W-110
The cumulative effect of the phosphate mining industry has a'l so
been recognized by EPA as a very important consideration.
Regulations for implementing the National €nv4rbtimefvtctJ'"'P°HcV
Act provide a mechanism for assessing the effects of a number
of related actions on a geographic area (40CFR Sect ion 1502'. "¦) •
EPA employed that procedure when it began in 1976 the preparation
of the Central Florida Phosphate Industry Areawide EIS. Its
purpose was "to analyze the cumulative, interrelated impacts
of the present and proposed phosphate development in central
Florida.... through a comprehensive regional environmental
assessment and impact statement...." The Areawide FElS was
published in 1978. Subsequent site specific EIS's, of wfo'icn
Estech is the first published, are based upon and take full
consideration of the information developed in the Areawide ElS,
including the cumulative effects of all projected mines. Th£
Areawide EIS may be obtained by ordering frdtfn the National
Technical Information Service, Input Branch, 528-5 Port Roy3'
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Road, Springfield, Virginia 22161. Cumulative effects of the
phosphate industry are addressed in Volume I, and page 2.5 of
Volume I discusses the relationship between the Areawide EIS
and site specific EIS's.
RESPONSE W-111
The standard concerning limitations on conflict of interest,
as well as full disclosure pertaining to tine contractor's stake
in the outcome of the project, is imposed under subsection
1506.5(c) of the CEQ Regulations. Before initiating the Estech
DEIS preparation, EPA conducted a careful inquiry into CCI's
qualifications and satisfied itself that CCI was a qualified
and objective consultant for the purpose of preparing the third
party EIS. No information has been brought to light since that
time which causes EPA to revise its determination as to CCI's
qualifications and objectivity.
RESPONSE W-112
The DEIS public hearing is an obligation EPA must fulfill in
carrying out the requirements of the NEPA and is distinct from
the State of Florida Development of Regional Impact process.
The latter, incidentally, is not a judicial process as was
stated, but rather is an administrative process instituted by
the State of Florida.
RESPONSE W-113
Please refer to Response W-2 concerning rock drying and Response
W-ll concerning the elimination of above-ground slime disposal
areas.
RESPONSE W-114
The DEIS is correct in stating that the operation will be "self-
sufficient" in terms of corrmunity services and facilities.
Estech has no direct call for services to be provided by tax
supported public service institutions. Estech will not be
internally equipped to provide emergency protection against
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catastrophic occurrences. In the rare event that an ernergency
of the magnitude that occurred at IMC chemical plant should take
place at the Estech mining and beneficiation site, it is expected
that the annual ad valorem tax (approximately $1.98 million)
should be adequate to prevent additional tax money expenditures.
RESPONSE W-115
Please see Response W-93. The cited C,AO report also recognizes
the potential for an OPEC-type phosphate cartel, and EPA is on
record in support of that report. We are also in agreement with
the comment that the future export-import situation of this
country should be a matter for consideration as well, when
examining actions which are currently favorable to the Nation's
balance of payments.
RESPONSE W-116
iZstech General Chemicals Corporation is required by Florida
statute and further has agreed to strict inspection and
monitoring of dam design and construction.
Construction of the embankment for the initial settling area
will be inspected on a daily basis by a representative of the
design engineer. The design engineer will be in close contact
with the construction, and prior to the reservoir being put into
operation, the engineer will make a thorough inspection of the
embankment and the spillway structures to determine that they
meet the design specifications.
Prior to using the settling area, monitoring stations will be
installed around the perimeter of the embankment. These
monitoring stations will consist of clusters of piezometers to
measure the seepage pattern within the embankment and through
the foundation. Furthermore, the quantity of seepage discharge
from the drainage system will be monitored to detect any abrupt
changes in the quantity of seepage.
While the settling area is in operation, the design engineer
will review the results of the monitoring program and the
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inspection reports prepared by the Estech personnel who will
be responsible for weekly inspections of the embankments and
spillway structures. These inspection personnel will be
instructed and trained by the design engineer. At least once
per year and probably several times during the first year of
operation, the engineer will make periodic inspections of the
embankments to detect any evidence of uncontrolled seepage,
sloughing, or erosion which would indicate that the embankments
are not performing as designed.
Estech's dam protection procedure includes:
o Testing prior to storing clay by filling it with clear
water. This will allow engineers to assess the character
of the dam and determine any corrections that might be
required in the design.
o Inspections every shift (8 hrs.) by the operating crews.
o Inspections by the Area Superintendent each day.
o Inspections by the Company Engineer each week.
o Inspections by the Design Engineer at least once each three
mo n t h s .
o All people who have responsibility for dam inspection will
attend classes given by the Design Engineer.
RESPONSE W-117
The comment with regard to the meaning of "wilderness" is
correct. The use of the term "wilderness" is used to convey
the thought that the area will likely afford isolated nesting
and roosting habitat for herons, egrets and other birds which
frequently utilize similar abandoned mine-pit lakes with spoil
rows in the region.
With regard to habitat restoration efforts proposed by the
applicant, please refer to Responses W-68, W-71, W-105, W-123
and W-12&.
RESPONSE W-118
Please see Response W-106. The hazardous waste regulations to
be promulgated this fall are expected to address the radioactive
as well as chemical nature of phosphate industry wastes.
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RESPONSE W- 119
Many techniques for improved dewatering of clays have been tested
and evaluated in order to develop methods of waste disposal that
would eliminate conventional "slime" ponds and enhance rapid
land reclamation at or near original ground level.
Three methods were developed that provided effective dewatering.
Phosphate companies have continued to test these methods and
develop plans for their implementation. One of the methods, the
sand-spray technique developed by Brewster Phosphates, encoun-
tered operational problems and has not been used by any other
company. The other two methods, termed flocculant-thickener
and dredge-mix, have been extensively evaluated in pilot plant
and semi-works scale testing. At least eight mining companies
are proposing to use one of these methods, which represent the
best available technology for disposal of this type of waste
ma t e r i a 1.
Estech plans to use the flocculant-thickener method of clay
dewatering. The flocculant-thickener process lacks several
adverse aspects of the sand-spray process, which was developed
by Brewster Phosphates and has encountered operational diffi-
culties. In the operation of the sand-spray process (Brewster),
dilute clays from the plant are placed into mined-out areas for
initial settling. After a period of several months, when the
clay has reached a solids content of 12 - 15%, a floating
pipeline equipped with spray nozzles is used to sprinkle tailings
sand over the clay. As the sand rains down over a large area,
it slowly settles through the pre-thickened clay, resulting in
substantial additional release of water.
Although the sand-spray method has proven very effective in
dewatering the clays, allowing land reclamation to restore the
approximately original ground contours, several operational
problems appear to be inevitable with the method. First, the
timing is very critical in order for the method to succeed.
Unless the clays are at the right consistency, the sand spraying
will be ineffective. If the clays are too dilute, the sand will
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fall through to the bottom, resulting in little dewatering and
not producing a sand-clay mixture. If the clays are too thick,
the sand will build up on top until failure results, causing
the raft of sand to end up somewhere within the clay, but again
resulting in little dewatering or sand-clay mixing.
As mining proceeds and the types of clays vary, it becomes very
difficult to use past experience to project just when will be
the right time to spray sand on the clays. And, since the plant
is producing sand tailings on a continuous basis, they need to
be sprayed on a continuous basis, whether the clays are ready
or not .
Second, unless the ore body is very uniform, it becomes
increasingly difficult as mining proceeds to leave mine cuts
that are the proper size and shape for uniform distribution of
the sand by spraying. Areas that are not reached by the sand
remain as soft layers of clay, difficult to reclaim.
Third, because the clay solids content that is produced by
natural settling varies with depth, it is generally not possible
to have an entire profile of settled clay that is at the right
consistency for spraying. If the middle third of the profile
is in the right solids concentration range, then the bottom third
will be too thick and the top third will be too dilute. What
this means is that the sand will be retained in the middle third
of the profile, with little sand-clay mixture in the top or
bottom thirds. The lack of sand in the top third results in
less dewatering of this material. The thin clay layer at the
top, which may be 10 feet or more in thickness, will be more
difficult to reclaim than a sand-clay mixture.
The flocculant-thickener method to be used by Estech, dilute
clay slimes at approximately 3% solids are pumped from the
beneficiation plant to mechanical thickeners where a chemical
flocculant is added and the clays rapidly dewater to 15 - 18%
solids. Sand tailings from the plant are added to the thickened
clay, either directly at the thickener or alternatively at a
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downstream mixing station. A homogeneous mixture of sand and
clay results. This mixture at about 35 - 40% total solids
content is pumped to mined-out areas for backfill. If the clays
are within the specified solids content range, the mixture does
not separate and a uniform sandy clay soil results. The mixture
continues to consolidate under self-weight for several years
in the mine cuts.
In order to achieve reclamation at or near original ground level,
the sand-clay mix must be placed initially at some height above
original ground, so as to allow for subsidence that will occur
as it consolidates. Refilling of an area after some
consolidation occurs may be desirable in order to limit the
height to which material must be placed. The height to which
the mixture must be placed depends upon several factors,
including the depth of the mine cut, the rate at which it is
filled, the permeability and compressibility of the clay, the
ratio of sand to clay in the mixture and the number of refills
that the area can receive.
All of these parameters can be put into computer programs which
have been developed to simulate the filling and subsequent
consolidation of the sand-clay mix. For the Estech Duette Mine
site, the results obtained indicate that the mixture will
consolidate back to original ground if it is placed initially
to a height of about 18 feet aboveground and refilled twice
during the five-year reclamation cycle. Temporary retaining
dikes will be placed around each reclamation unit and
subsequently leveled as part of final grading prior to
revegetation. (See also the Supplemental Analyses Section,
Evaluation of Sand-Clay Disposal Height, this document).
The f locculant-thickener method of clay dewatering has several
advantages. It is a controlled process that can be easily
monitored and adapted to changing conditions. It produces a
consistent homogeneous sand/clay mixture at an optimum solids
content. The ratio of sand to clay can be controlled as desired
The mixture can be pumped, without segregating, to any desired
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point where it is placed into mine cuts as backfill for rapid
land reclamation. Along with the dredge-mix technique, it
represents the best available present technology for phosphatic
clay waste disposal.
Response W-120
The only emissions of concern with the proposed project for which
there are existing standards are sulfur oxides and particulate
matter. The existing standards are based on criteria developed
by the U.S. Department of Health, Education and Welfare - Public
Health Service and Consumer Protection and Environmental Health
Service and published in January 1969. The criteria, in turn,
were established as a result of a number of studies and tests
of the effects of these pollutants on materials, vegetation,
animals and man. The studies, fully described in the documents,
"Air Quality Criteria for Particulate Matter" and "Air Quality
Criteria for Sulfur Oxides," considered health effects on
different age groups including schoolchildren and the elderly
(National Air Pollution Control Administrative Publications,
Nos. AP-49 and AP-50). The emission standards which were
subsequently adopted were set at levels to protect the most
sensitive element of the population.
RESPONSE W-121
Mining occurs at an average depth of 50 feet and a maximum depth
of 100 feet below the surface (page 56, DEIS). The surficial
soils (0' - 20') and the upper part (approximately 60') of the
Hawthorne/Tampa formation will be restructured. The remaining
240 feet of the Hawthorne/Tampa formation will not be disturbed.
The reclamation program calls for the use of a sand-clay mix
which is hydrau1ica11y similar to the upper layers of the
Hawthorne formation, thus, in effect, replacing the disturbed
portion. Vertical recharge and water holding characteristics
of the shallow groundwater system is expected to return to
baseline conditions after reclamation are complete due to the
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fact that the vertical permeability of the Hawthorne/Tampa
formations is the controlling factor.
RESPONSE W-122
The impact of mine pit dewatering was mentioned on pages 130-131
in the DEIS, and elsewhere in the baseline documents. It was
concluded that the impact would be negligible or at least short-
term with regard to the natural conrmun i t ies. The buffer zone
between the mine pits and the wetlands that are to be preserved
will be wide enough so that the water table will not be lowered
substantially in those wetlands. Only one side of a stream will
be mined at one time, thereby maintaining the continuity of the
groundwater aquifer on at least one side of the stream at any
g i ven t ime .
RESPONSE W-123
The comment correctly points out that steep-sided lakes are not
as desirable as those with productive shallow areas. However,
"The lakes on the Swift (now Estech) site will be contoured to
provide shallow shelves (less than six feet deep) along their
margins and around islands within the lakes. The shallow areas
will occupy approximately 20 percent of the surface area of the
lakes and are expected to be colonized by emergent vegetation.
These areas will provide habitat for many species of birds...
Small fishes and invertebrates will find refuge among the
emergent vegetation, and amphibians nearby will breed there."
Steep-sided phosphate pits are often productive sport fishing
lakes. Because of the lack of shallows, phytophankton forms
the basis of food webs in these systems. The additional habitat
created around the margin of lakes at the Estech mine promises
to provide excellent, productive fishing lakes. Water hyacinths
should not be a problem unless introduced into these lakes.
For further information see:
E. Crittenden, 1965. Florida Phosphate Pits for Managed
Public Fishing Areas. Proc. 17th Arm. Meeting Southeaster
Assoc. Game and Freshwater Fish Corrm. , 1963.
G. W. Bennett, 1970. Management of Lakes and Ponds. Secon
Ed. Van Nostrumel Ranhold Co., N.Y.
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RESPONSE W-124
If the mine were to be abandoned without reclamation, as was
generally the case before mandatory reclamation, then the comment
may be correct. The reclamation procedures proposed by Estech
will prevent such an occurrence on nearly all parcels of the
property after mining. One exception is the "wilderness" area
at the mine-pit lake on the north end of the property.
RESPONSE W-125
Subsequent to the promulgation of the DEIS and the November 1979,
public hearing several elements of the documents have received
expanded discussions. In preparation of the final EIS responses
to comments regarding soils, timber production, land use and
other agriculturally related issues (W-68, W-69, W-87, W-88 and
W-89) have been developed which may be helpful to the
agricultural community.
RESPONSE W-126
Personalized and direct exchanges were an integral part of DEIS
preparation throughout various stages of data development. Local
and regional agencies were consulted in developing information
on land and water, forestry, economics and roads as well as other
elements. In addition to these inputs during the preparatory
stages, numerous local and regional agencies were asked to
comment on the DEIS and its Resource Documents. (See the Public
Participation Section of the FEIS.)
RESPONSE W-127
Whether or not there remains any question concerning the accuracy
of work performed by the preparer on unrelated activity, the
work performed in this study was subjected to independent
engineering review by EPA and approved engineering contractors
and found acceptable. Here again, as stated in Response W-51
and W-52, the PSD review procedure assures the accuracy and
completeness of the EIS air quality analysis.
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With regard to the referenced document or Recorrmended Order to
the Secretary of the Florida Department of Environmental
Regulation by the State of Florida Division of Administrative
Hearings (March 5, 1979), the computations were viewed from the
perspective of technical information that was not generally
available to the scientific community until after the Agr ico
Construction Permit Applications were filed.
The questionable emissions were not omitted from consideration,
but were aggregated into a single estimate, much in the same
manner that the supporting research was conducted and the
resulting data were used to develop an estimatation methodology
for generic storage pile operations in the EPA compilation of
emission factors (AP-42).
Expert witnesses from the Florida Department of Environmental
Regulation testified that the estimated emissions were reasonable
after a re-examination which included a field visit and visual
observation of material being handled at the originating seaport.
RESPONSE W-128
See Response W-3.
RESPONSE W-129
Note is taken of the comment letter from Mr. Joseph E. Davis,
Estech General Chemicals Corporation.
RESPONSE W-130
Placing a moratorium on phosphate mining and processing
operations is outside the regulatory authority of EPA. Also,
see Responses W-110 and W-93 concerning cumulative effects and
phosphate resource protection, respectively.
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5.2 HEARING TRANSCRIPT AND RESPONSES TO TRANSCRIPT COMMENTS
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UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
«
A Public Hearing: :
DRAFT ENVIRONMENTAL IMPACT STATEMENT :
ESTECH GENERAL CHEMICALS CORPORATION :
DUETTE MINE
MANATEE COUNTY, FLORIDA
e
------------------------X
7:30 p.m.
November 28, 1979
Manatee Junior College
Bradenton, Florida
-oOo-
Time:
Date:
Location:
BAY PARK REPORTING COMPANY
COURT REPORTING
33 FOURTH STREET NORTH
ST. PETERSBURG. FLORIDA 33701
(813) 823- 8388
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APPEARANCES:
THE CHAIRMAN:
CHARLES PERRY
Regional Counsel
Environmental Protection Agency
Atlanta, Georgia
THE PANEL:
JEAN TOLMAN
Project Officer
Atlanta, Georgia
ROBERT HOWARD
Chief of EIS Preparation Section
Atlanta, Georgia
JOHN HAGAN
Chief of EIS Branch
Atlanta, Georgia
MICKEY BRYANT
Environmental Administrator,
NPDES Section
Florida Department of Environmental
Regulation
Tallahassee, Florida
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SPEAKERS PAGE
Joe Davis 9
William Hamilton 12
Richard Nelson 32
Jeffry Lincer 37
Robert Lyman 54
Fred Duisberg 58
Mary Jelkes 61
Mrs. C.G. Fernald 64
James Hunter^ 66
Mrs. Gloria C. Rains 68
Mary P. Greer 85
Archie E. Brumfeld 87
Hilda E. Quy 88
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PROCEEDINGS
(Whereupon, at 7:35 p.m. the
hearing was called to order)
MR. PERRY: The meeting will come to order, plea.e.
M\ name is Charles Perry, and I'm the Regional
Counsel ior the Environmental Protection Agency, Region
IV, in Atlanta, Georgia.
The Regional Administrator of EPA, Region IV, Mr,
John White, has designated me to conduct this hearing
tonight. It is, as the Notice states, a hearing for an
NPDES permit, pursuant to the Clean Water Act of 1977, for
Estech at their mine, their Duette phosphate mine.
I'd like to introduce the members of the panel
here with me tonight.
On my far left is Ms. Jean Tolman who, I understand
this is her first day with EPA, and she will be a Projeci:
Officer oxt projects such as this in the future.
To my immediate left is Mr. Robert Howard, who is
the Chief of the EIS Preparation Section for Region IV, ^nd
to my right is Mr. John Hagan, who is Chief of the EIS
Branch, and to my far right is Mr. Mickey Bryant, who is
with the Florida Department of Environmental Regulation.
Tonight's hearing is concerned with the possible
action by EPA with respect to the Duette phosphate mine, i
new facility proposed by Estech General Chemicals Corporation.
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Estech has applied for a National Pollutant Discharge
Elimination System permit for this facility, and throughout
the night this will probably be referred to as an NPDES
permit.
The issuance of this permit for a new source mine
is a federal act requiring compliance -with the provisions
of the National Environmental Policy Act of 1969.
This act requires a federal agency to prepare an
Environmental Impact Statement whenever the agency proposes
to take a major federal action significantly affecting the
quality of the human environment.,
Accordingly, EPA has commissioned the preparation
of an Environmental Impact Statement for this facility.
The draft of this statement has been prepared, and notice
of its availability was published in the Federal Register.
This hearing is for the purpose of receiving comments
on the Draft Environmental Impact Statement for the proposed
issuance of a National Pollutant Discharge Elimination
System permit and consideration for state certification of tha
permit. Under Section 401 of the Clean Water Act, the State
of Florida will be requested to certify that the proposed
NPDES permit will not cause a violation of the Florida Water
Quality Standards, and we have the presence of Mr. Bryant
from the State here tonight.
Although no decision has yet been made, EPA tentatively
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proposes to issue an NPDES permit. The proposed permit
contains limitations on the amount of pollutants that
will be allowed to be discharged into waters of the
United States and was drafted in accordance with the
provisions of the 1977 amendments to the Federal Water
Pollution Control Act, which is now commonly known as
the Clean Water Act, and other lawful standards and
regulations.
This statute created, or its predecessor created,
the National Pollutant Discharge Elimination System. It s
a national permitting program to control the discharge
of pollutants into the nation's waters.
The exclusive goal of the Act is the elimination
of discharge of pollutants by the year 1985. To achieve
this goal, EPA, or the states if they have received auth-
ority from EPA to administer the NPDES permit, will issue
permits to every waste water discharger setting limit-
ations and controls on the discharge of pollutants.
This Act requires very strict limits to be imposed
for new sources, such as the Duette Mine, and further the
permit requires compliance with these limits on the
initiation of the discharge.
Let me emphasize at this point that the NPDES permit
is the basic enforcement tool for the control of water
pollution, and the NPDES permit imposes strict legally-
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enforceable limitations on the discharger. Once the
permit is issued, the discharger is legally bound to meet
the requirements of the permit, and any violation can
subject the permittee to criminal or civil penalties.
The pollutant limitations and other conditions of
the draft permit are tentative and are open to comment at
the hearing here tonight.
We have made available for reviewing here this
evening a copy of the Draft EIS, which was at the
front desk when you registered. Copies nay also be
obtained by leaving your name with one of us, and we
will mail you a copy when we return to Atlanta.
The Draft EIS, as well as the other relevant
documentation and all comments received here tonight
or submitted in writing within approximately two weeks
of tonight, will be a part of the administrative record
concerning the permitting of the Duette Mine.
The information in the record will be used to
determine the environmental compatibility of the
permit issuance and to prepare a final NPDES permit.
This permit would be included in the final impact
statement.
In addition, you should be aware that all the
substantive comments from the public on the Duette Mine
and the Draft EIS, whether received here tonight or
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transcribed for the record and received on a Later date,
will be summarized and addressed in the final impact
statement.
As I stated, to my far right is Mr. Mickey Bryant
of the Florida Department of Environmental Regulation. I
would ask at this time if he'd care to make any opening
statements
MR,, BRYANT: Nothing, other than I'd like to
welcome everybody here on behalf of Secretary Varn of the
department
I'n here to listen, listen to your concerns or
listen to anything that you may feel are shortcomings in
the EIS, to listen to anything the public might want to
present that might affect our certification or considera-
tion on the. certification of this project.
MR. PERRY: Thank you, Mr. Bryant.
Wich that, sort of to set the stage for what we're,
here for tonight, I would like to turn the program over
to Mr. John Hagan, who is the Chief of Region IV's EIS
Branch, and allow him to give you a brief recitation of
what the permit is all about and what the EIS is all about;.
John?
MRo HAGAN: Thank you, Charlie.
At this time, without making any particular opening
remarks, I would like to call on Mr. Joe Davis, who is th ;
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Manager of Projects for Estech General Chemicals, and Mr.
Davis will give us a brief description of the proposed
action as proposed by Estech.
Joe, would you come up to the podium, please, sir?
MR. DAVIS: Distinguished panel members and ladies
and gentlemen of the audience, my name is Joe Davis, Manager
of Projects for Estech General Chemicals Corporation.
Until relatively recently, our company was named
Swift Agricultural Chemicals Corporation. There has been
a change in name only. For convenience, I'll refer to
Estech throughout this discussion.
During the mid 1960's, Estech carried out a pros-
pecting and land acquisition program in Manatee County,
Florida.
This resulted in the purchase of 10,394 acres of
property located in northwestern, or, northeastern Manatee
County.
Estech proposes to carry out phosphate rock mining
and processing operations on approximately 6,600 acres of
this property.
We propose to use proven equipment, design and
process technology generally used by current mining and
processing operations.
Two large electric draglines would excavate the matrixj
which is composed of phosphate ore, sand and clay, and the
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matrix will then be mixed with water, aid the resulting slurry
will be pumpfed to the proposed processiig plant.
Pebbles-size phosphate ore will >e removed by a
washing and screening process. The smaller, sand-like
particles of phosphate ore, referred to as concentrate,
will be removed by a flotation process that is described
in more detail in the Draft Environmental Impact Statement
and resource documents.
Estech also proposes the construction of two
phosphate rock dryers to remove most of the moisture
content of the phosphate product prior to shipping to
our customers.
The proposed phosphate rock mine and processing
facilities should generate a nominal production rate of
3 million tons per year for 21 years after start-up.
Estech currently owns and operates the Watson
Mine and Silver City Mine, located in Polk County, Florida.
The proposed new phosphate rock mine that is the
subject of tonight's public hearing will be a replacement
for the old Polk County mines after they are mined out.
Water will flow through proposed mining and proces-
sing operations that I have described. A very large per-
centage of this water will be recycled and recirculated
through the system as a result of the industry's continuing
water conservation efforts.
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In Florida, however, most of the rainfall during
any particular year is concentrated into a few months.
During this wet season, it may become necessary to
release some of the water in the mining and processing
system into waters of the United States,.
Any discharge of water will have been treated
through long-term settlement to remove the clay particles
extracted from the matrix during the processing of the
phosphate rock.
This settlement process has been recognized by
the United States Environmental Protection Agency as
the best available demonstrated control technology for
the control of discharges from phosphate rock mining
and processing facilities.
Because the proposed Estech project will involve
periodic discharges of treated water into the waters of
the United States, the Federal Clean Water Act requires
that Estech obtain a National Pollutant Discharge
Elimination System, or NPDES, permit.
In addition, EPA has determined that the proposed
Estech mine and processing plant would be a new source
discharge under the Clean Water Act.
The issuance of an NPDES permit to a new source is
a type of federal action that triggers the environmental
review requirements of the National Environmental
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Policy Act of 1969 or NEPA.
After consultation with EPA, Estech decided to
comply with the Environmental Impact Statement require-
ments of NEPA through the use of the third-party pro-
cedure .
Under this procedure, an independent, private
consultant prepared the Draft Environmental Impact
Statement for EPA.
The expense of the EIS preparation was paid by
Estech, but the independent consultant served solely at
the direction and under the control of EPA.
The purpose of this public hearing is to receive
comments on the Draft Environmental Impact Statement and
proposed issuance of an NPDES permit for Estech's pro-
posed project.
As a vitally concerned and affected member of the
public, Estech will be providing written comments on the
Draft EIS and proposed NPDES permit before the end of
the public comment period.
Thank you.
MR. HAGAN: Thank you, Joe.
At this time I'd like to call on Mr. Bill Hamilton,
President of Conservation Consultants, Incorporated, from
Palmetto, who was the third-party EIS consultant for this
project.
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Bill?
A VOICE FROM THE AUDIENCE : The other speaker was
not being heard too well. Perhaps the microphone
MR. HAMILTON: I certainly had to lower it.
(Laughter)
MR. HAMILTON: As noted, Conservation Consultants,
Incorporated, was selected as the prime contractor under
the third-party procedure to assist EPA in the develop-
ment of the Draft Environmental Impact Statement regarding
the proposed Estech phosphate mine named the Duette Mine
in Manatee County, Florida.
As sort of an abbreviated history of our work,
the first part of the EIS development process was the
formulation of a plan of study.
This involved some extensive coordination between
my firm, CCI, Conservation Consultants, Incorporated, and
EPA's EIS Branch and all EPA technical support services-
The draft phosphate area-wide EIS was used to
provide a focus on the issues that would be incorporated
into the EIS through the plan of study.
The intent of the plan was to provide for a full
identification and discussion of significant environmental
impacts and provide an evaluation of alternatives, which
would avoid or minimize adverse impacts in the Applicant s
proposal.
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The plan of study for the Estech EIS was reviewed
for adequacy by the US Army Corps of Engineers and the
Florida Department of Environmental Regulation as part
of the plan formulation.
The first step in the actual Draft Environmental
Impact Statement preparation effort was assimilation of
background data. As several major baseline investigations
have been performed by consultants for Estech in prepar-
ation of their development of regional impact application,
this information served as a major source of data.
Another major source of data for the impact statement at
hand was the phosphate area-wide EIS.
In addition to these rather large studies, several
site-specific studies for the EIS were conducted in the
areas of radiation, air quality, archaeology, dam failure,
water quality, and aquatic biology.
All the DRI studies and the additional studies
performed by the third-party consultant were reviewed
for adequacy by the EPA. In many instances, the EPA
technical personnel made field inspections as part of
the adequacy review.
During the entire Draft Environmental Impact
Statement development process, there was this constant
EPA and CCI interface.
Preparation of all draft, baseline and assessment
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reports was coordinated directly with the EIS Branch and
the appropriate EPA technical staff members. At each stage,
all documents were provided to EPA for their technical
specialists to review for their concurrence and for changes
and/or additions where necessary.
EPA had the sole responsibility for final approval
of all the Draft Environmental Impact Statement elements.
To give you a little bit about the draft itself
that was available up front, it consists of several major
sections. The introduction and description of the pro-
posed activity are provided in the impact statement.
Mr. Davis ably presented the description of the
proposed activity. Section 2 is an alternatives evalu-
ation. Section 4 is a description of the baseline,
impact, and mitigating measures concerning the natural
environment. Section 5 is a description of the baseline,
impact and mitigating measures of the man-made environ-
ment, and Section 6 consists of a comparison of the
proposed activity with the area-wide phosphate EIS
recommendations. Section 7 of the Draft EIS are the
proposed agency actions.
A summary also precedes the main body of the docu~
ment.
What I'd like to do now is to step to Section 5
of the EIS and highlight the alternatives that were
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evaluated as part of the Draft Environmental Impact
Statement.
Fourteen areas were selected to be investigated
for alternatives. These included plant site locations,
production rates, resource recovery methods, mining
methods, ore transportation methods, beneficiation
processes, process water sources, waste disposal and
reclamation methods, discharge points, rock drying or
shipping wet rock, product transportation modes, energy
sources, and the no-action alternative.
Within these areas specific alternatives were
studied for a total consideration of over 50 options.
Alternatives were evaluated on the basis of technical
feasibility, environmental impact and economic impact.
The proposed activities by the Applicant were
generally found to be the optimum alternatives. Some
alternatives investigated were, however, found to be
acceptable and, in some cases, better than those proposed
by Estech.
The alternatives that fall in these categories
included the resource recovery alternative where three
options were evaluated.
The first option evaluated was the mining, total
mining of all phosphate reserves found on the site, re-
gardless of the land cover, whether it be wetland, forest
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or vAiatever.
The second option was no mining wherever there
were wetlands on the site, and the third option evaluated
was the Swift proposal that Mr. Davis described, which
included some mining of wetlands and some preservation
of wetlands.
Based on the assessment of the evaluations done
in the Draft EIS, the optimum alternative seems to be
somewhere between the proposed plan of Estech and the
exclusion of all fresh water swamps, primarily due to
environmental implications.
For the mining method alternatives, the proposed
dragline was found to be preferred due to proven tech-
nology, although dredge mining appeared to be acceptable.
Eight surface water discharge point alternatives
were found acceptable. Two alternatives naximized water
efficiency and minimized discharge.
The proposed discharge arrangement of Estech,
however, offered a discharge flexibility resulting in
additional operational effectiveness.
With regard to the wet phosphate rock versus
drying, shipping wet phosphate rock was the best en-
vironmental choice if, and only if, the rock is not dried
in less efficient and less-effectively controlled equipinent
the destination. From a standpoint of phosphate rock customej
a
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requirements, this option was necessarily excluded as
a viable alternative as the intended customers of the
product do not currently have drying facilities.
Drying the rock at the proposed site was an en-
vironmentally-acceptable action given the fact that the
new facility can satisfy current air quality regulations
and in some cases with considerable margin.
In the no-action alternative, most, if not all,
adverse environmental impacts associated with the mining
would not occur.
The considerable projected economic benefit as-
sociated with mining would also not be accrued.
As a summary of impacts, as presented in Sections
4 and 5 of the EIS, significant impacts are as follows:
Overall, 85 percent of the native upland vegetation will
be replaced with improved pasture. Mining will destroy
at least 476 acres of fresh water swamps and 364 acres
of fresh water marshes.
Reclamation is proposed to restore these acreages
and actually contribute a net gain of 15 percent in wet-
land vegetation on site.
The direct impact of mining will be the destruction
of 417 acres of ephimeral feeder streams and their
flood plains.
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Mining will create several lakes on the site,
however, which are a significant beneficial expansion
of the aquatic environment.
Proposed mining will disturb the existing soils
on approximately 75 percent of the site and will result
in three new typqs of surface soils. These are clay,
sand/clay, and overburden.
The average annual ground-water withdrawals would
be limited to 13 million gallons a day less recharge at
3 mgd for a net consumption of 10 mgd.
During the fourth year of mining, approximately
2.88 million gallons a day of surface water will be used
in the process.
The primary effect of these withdrawals from the
deep ground-water system is the lowering of potentio-
metric surface within the area of influence of the wells.
This effect was found to be extremely small in comparison
to the large natural seasonal fluctuations in the
vicinity of the site.
The primary effect of mining on the shallow
ground-water system is a short-term lowering of the water
table in the vicinity of the mine cuts.
During active mining, stream flow into Lake
Manatee will decrease by approximately 9 percent.
After reclamation, the average flows of the East and
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the North Forks cf the Manatee River, which traverse
the site, will be reduced approximately .7 million
gallons a day and .6 million gallons a day, respec-
tively .
Discharges from the plant water system may
be necessary due to the temporal variations in rain-
fall that Mr. Davis indicated.
It is anticipated that approximately 1.9
million gallons a day will be discharged in the East
Fork of the Manatee River during August and September
of an average rainfall year.
Effluent will be discharged into the North
Fork at a rate of 1.8 million gallons a day during
August, September and October.
In an investigation of the plant discharge
and ambient water quality standards, six parameters
were evaluated because of their potential effect on the
downstream water supply.
All parameters fell well within the ambient
water quality standards after a period of reasonable
mixing.
The proposed mining operation will contribute
to both primary and secondary air quality effects.
Primary effects will be contributed by the operation
of the two phosphate dryers, the storage of materials,
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materials handling and shipping, as well as fugitive
dust from land clearing and reclamation activities.
The proposed sources will not violate air
quality standards nor significantly degrade air quality.
The SC>2 and particulate matter emissions will satisfy
the New Source Performance Standards and the Best
Available Control Technology requirements. The
proposed fugitive dust control on dryer emissions
would also limit off-site transport of airborne
radioactivity to the point where the annual dose
could not be measured within the statistical variation
of natural background.
Regarding the potential future residential de-
velopment of the site, the predicted indoor radon
progeny levels indicate only the reclaimed settling
area may produce levels requiring remedial action.
If the clay settling areas are excluded for
structural reasons or a topsoil replacement occurs,
no reclaimed lands are predicted to produce homes
with radon progeny levels near the remedial action
leve1.
The socioeconomic impact of the proposed mining
will exhibit a generally-beneficial effect. Operation
of the mine will directly require 324 workers, many of
which are expected to be relocated employees of the
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Applicant. The direct economic effects of the. mine
are favorable, producing approximate annual yields of
$382,400 in sales tax, $1.92 million in severance tax,
and $1,982 million in Ad Valorem tax.
Regional economy effects derived through stan-
dard multipliers indicate an annual indirect impact
of $35.4 million and an annual induced impact of
$118.4 million.
Estimated employment associated with the activity
is similarly projected to be 235 through indirect
impact and 1,425 through induced impact.
The mine will exert no directly discernable
effects on existing community services and facilities.
Long-term land use patterns would not be ad-
versely impacted by the mining activity.
This site is proposed for agricultural uses
in the Manatee County Comprehensive Plan. The planned
mine reclamation program is designed to return the site
to land forms amenable to a variety of agricultural
uses.
On the short-term, the proposed mine site is
located between two approved phosphate mines and there-
fore should not disrupt near-future land use trends in
the area.
As a sort of a summary and ending statement,
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I have briefly described the results of some evaluations
made during the Draft EIS process. The draft summary
EIS document, of course, contains considerably more
detail.
The summary draft document itself, in most
instances, is in turn a condensation of the compre-
hensive evaluation contained in thirteen resource
documents that supplement the Draft EIS.
I believe all that material is available for
review through the EPA.
Thank you.
MR. HAGAN: Thank you, Bill.
It is not customary for one sitting on the
panel to make a statement in regard to this hearing.
However, because of a turnover in personnel during the
course of the development of this EIS, it has fallen
my lot to see this particular project through to this
point, and because of that I would like to read a
statement of EPA's conclusions up to this point as a
result of this EIS process.
The Environmental Protection Agency has develope
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proposal deviated from those recommendations in oily
two points.
One was the construction of a rock dryer, an 1 the
other is the mining of a segment of the East Fork of
the Manatee River.
The area-wide EIS provided for exceptions to the
no-new rock dryers recommendation based on a case-by-
case determination if energy determinations indicated
that it was more efficient to dry the rock than t >
transport the moisture and provided air quality could
be protected.
The Estech EIS has determined that more energy is
required to dry the rock than to transport the mo stur
even when you're transporting that moisture to Far
Eastern markets some 10,000 miles away.
However, many of Estech's customers are not pre-
pared to handle the wet rock. Indeed, the conver? ion
of the entire industry generally to wet rock proctss in
is not expected for many years.
It is customary in the industry now to process
dry rock. Thus, the market conditions under whicl:
Estech works dictate that they market dry rock.
With respect to air pollution, the analysis c one
in connection with the EIS indicates that sulfur
dioxide concentrations at the point of maximum imi act
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will be less than 1 microgram per cubic meter on an
annual average and about 2.3 micrograms per cubic
meter on a maximum 24-hour concentration.
These levels are far below the ambient air qual:.
standards and also far below the allowable PSD incre-
ment .
For total suspended particulates, the annual
average at the point of maximum effect would be 1.4
micrograms per cubic meter or about 8 percent of the
allowable PSD increment.
The cumulative impacts of all suspended particul-
ate sources in the area, including Estech, if they
were all combined at their maximum impact as if it
occurred simultaneously and at the same point, which
is an extremely remote possibility, but if that ever
could possibly occur, it would be less than 50 percent
of the ambient air standards.
For the 24-hour average, the suspended particular
impact was projected to be 37 micrograms per cubic
meter or about 35 percent of the allowable 24-hour
increment.
So in summary, while the EIS points out that ther<
will be some increase in the air pollution emissions,
the EIS analysis indicates that the equipment proposed
will meet the New Source Performance Standards and the
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Best Available Control Technology requirements and
that the ambient air standards will be met.
Based on this, it is proposed that EPA will issi_e
a PSD permit application subject to a full and fiial
review of that application by the Region IV, air
quality staff.
Now, with respect to the wetlands, after an ex-
tensive study of the biological systems of the East
Fork Manatee River, it has been concluded by EPA ihat
the area proposed for mining is a Category 1 wetland
within the meaning of the area-wide EIS.
In translating from the general recommendations
of the area-wide to the specific conditions of this
proposed mine, more specific criteria for the categor-
izing of wetlands were developed, and I will refei
those of you who have copies to page 176, 177 and 178
of the Draft EIS where those criteria are specified.
Based on these criteria and the biological evalu
ation of the East Fork, the Environmental Protection
Agency has recommended that the area not be permitted
for mining.
Finally, EPA does propose to issue an NPDES perm
pursuant to the provisions of the Clean Water Act.
The permit will contain as conditions those recommmda
tiois of the area-wide EIS which pertain to mining,
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except the recommendation concerning rock dryers as
previously discussed.
Water retention facilities are to be designed tc
contain or treat the ten-year, 24-hour precipitation
event. Any discharges are subject to limits on total
suspended solids of 30 milligrams per liter as a daily
average with a 60 milligram per liter daily maximum
and limits on fluoride of 10 milligrams per liter as a
daily average and also the same limit as a daily maxi-
mum.
MR„ PERRY: Thank you.
I don't believe that there are any other federal
or state officials here at the present, but if there are,
they are welcome to make a statement at this time.
(No response)
At this time I would like to recognize Mr. Louis
Driggers, who is a Manatee County Commissioner. He did
not indicate that he would like to speak, but we welcome
you here tonight, Mr. Driggers.
Are there any other elected representatives that
would like to be recognized and speak at this time?
(No response)
All right. If not, I'd like to make just a few
statements as to the conduct of the heariqg„ We have
now completed the presentation of the governmental
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agencies and of the proposed permittee, and we would
like to proceed with what is the real purpose of the
hearing here tonight, and that is to receive comments
from the public.
It is an expressed goal of both the Clean Water
Act and the National Environmental Policy Act to en-
courage and to provide for public participation and
input into determinations made pursuant to those
statutes.
The Draft Environmental Impact Statement and
NPDES permit are therefore being discussed in an
open public forum to encourage full public partici-
pation in the decis ion-making process and to develop
greater responsiveness of the governmental action to
the public interest, further to develop and to improve
the public's understanding of the Duette Mine permit
and the action that this agency has proposed to take
with respect to this proposed facility.
This hearing is being conducted pursuant to
federal regulations, and it should represent to you
an opportunity to make your views known with regard to
the project to the governmental agency responsible for
permitting it.
Notice of the public hearing was published in
local newspapers. In addition, copies of the public
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notice were mailed to each of those individuals or
organizations that are on the EPA mailing list, as
well as to other governmental agencies.
Before I proceed farther, I would like to
ask everyone who has not already done so to register.
I believe there were some cards left out at the front
table.
On the bottom of those cards, there is a place
where you can indicate whether or not you would like
to speak. If you would like to fill one of those cards
out, those of you who haven't, and if you would like to
speak, I would ask you to bring them up and just put
them on the edge of the stage there, and we'll pick
them up.
The hearing will be conducted very informally.
The formal rules of evidence, as would be applied in a
court, are not applicable here. Both oral and written
comments will be accepted.
Any and all persons present desiring to make an
oral statement or to submit written comments will be
afforded the opportunity to do so.
If you have a written statement that accompanies
your presentation, I would ask that we be given a copy of
that statement prior to your beginning to make it.
If you have a lengthy written statement, I would
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ask that your oral statement be a summary of that, if
at all possible.
The oral presentations, I would like to have
them limited, if possible, to between five and seven
minutes, and I may interrupt and cut the presentations
a bit short if necessary if you proceed too much over
those limitations.
This is done to accommodate all those people
who would like to speak and to give them an oppor-
tunity to say what they think.
Members of this panel may ask questions of
any person presenting an oral comment wherein it's
found necessary to clarify the nature or the substance
of that comment.
However, I would like to emphasize that the
audience will not be permitted to ask questions of
those persons commenting for the record.
As we proceed with the agenda, I would like to
ask each person making a statement to step to the
microphone, which is over here, and state his or her
name and the interest or organization that you repre-
sent.
This is a hearing being recorded by a court
reporter, the young lady sitting down front here, for
future transcription for the record; in addition to
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that, all or^l or written statements submitted here
tonight.
The comment period for the Draft Environmental
Impact Statement will remain open for approximately
two weeks. That will allow for the submission of
other comments.
We will hold the written record open in the
Atlanta office of EPA. I believe that record will
be held open until December 14th, 1979.
At this time I would like to recognize Dr.
Jeffry Lincer, who is an Environmental Specialist
with Sarasota County.
MR, SABA: Well, Mr. Perry, I rise, not to be
recognized as an elected official, but to make the
statement that not knowing exactly what the procedure
was that you were following and hearing the comment
that all governmental entities had been heard from,
to let you know that Sarasota County is here to pre-
sent comments that don't necessarily agree with the
comments that have been made so far, and I'm John Saba
from Sarasota County, and Dr. Lincer will be making a
presentation and also Attorney Nelson.
DR. LINCER: With your permission, I'd like
Attorney Nelson to make some preliminary remarks before
I get into the technical side of the issue.
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MR. PERRY: Well, be that the case, if there
are representatives of the county here that would
like to speak, you may do so at this time. I'm sorry
that you were not recognized, but I notice that, Mr.
Nelson, you were the last person to register, and I'm
sorry I did not have your card; sorry, sir, I didn't
catch your name; no slight intended.
MR. NELSON: My name's Richard Nelson, appearing
here tonight on behalf of Sarasota County. I'll make
a few brief opening comments. Dr. Lincer will make
the primary presentation on behalf of Sarasota County.
Needless to say, Sarasota County has and con-
tinues to be strongly opposed to this mining project.
Let me say that there's no question in anybody's mind,
in EPA's or the Conservation Consultants, Inc.'s or
anybody who has done an analysis of phosphate mining,
that this project, like any other phosphate mining
project, will substantially increase air and water
pollution, and of course that is one of the reasons
why we're all here tonight, and it's not a question of
whether or not it will increase air and water pollution.
It's a question of whether or not that increase in
pollution is such as should be permitted under local
environmental regulations, state environmental regu-
lations and EPA regulations.
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I As I understand, the purpose of this hearing is
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to examine and to react to the Environmental Impact
Statement prepared by Conservation Consultants, Inc.
Permit me to say that I know there has been
some question as to the total objectivity of that
firm. My own personal reaction is that the last time
I saw that firm, they were appearing as expert wit-
nesses against Sarasota County in a phosphate mining
project case.
They have traditionally represented the phos-
phate industry. They're oriented toward the phos-
phate industry, and we feel a little uncomfortable
with regard to their selection as the contractors to
perform an Environmental Impact Statement, which sup-
posedly was to be totally impartial.from the public's
standpoint., Nevertheless, we want to give them the
benefit of the doubt.
However, in this particular instance we find
significant fault with the statement, which they have
prepared. We do not feel that the statement complies
with the fundamental requirements of federal law.
It does not examine, with any degree of thor-
oughness at all, the alternatives. I heard Mr. Hamilton
speak about the many alternatives that they examined .
However, when you really read carefully the EIS, which
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they have prepared, you'll find that it's more of an
attempt to justify deviations from the area-wide EIS.
As you know, the federal government spent a
million or so dollars on an area-wide EIS to determine
what ought to be done with regard to the tremendous
havoc that the phosphate industry caused to the en-
vironment in the State of Florida.
It was determined that some of the things that
shouldn't be done were: the creation of slime ponds
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above grade. Now, does this project have slime ponds l~
above grade? Yes, it does. And the EIS, prepared by
Conservation Consultants, attempts to justify that.
One of the other requirements or suggestions
that the federal government obtained in the area-wide
EIS with regard to preventing damage from phosphate *
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mining was not to use rock dryers. Does this project
have a rock dryer? Indeed it does, and a considerable
amount of time is devoted in this EIS to justifying
the use of that rock dryer.
We know, as does Swift know, that they have a
rock dryer presently in operation that could be util-
ized in an adjacent area for the drying of this rock
if it is in fact necessary to use a rock dryer rather
than ship it wet. That alternative has not been ex-
amined with any degree of thoroughness whatsoever. ll
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"Therefore, it doesn't comply with the requirements
of the federal law.
Lastly, as you have pointed out, Mr. Hagan, the
EIS or the project proposes to extensively mine wetlands.
Now, I understand that your recommendation is going to be
that they eliminate one of the areas of wetlands, but
they're still in a very critical wetland area. They are
in the Manatee River Basin, which is one of the sources,
the primary sburce, of water to Lake Manatee, which is
a source of water, important source of water, to Manatee
County and Sarasota County, and we all know that phos-
phate mines discharge pollutants, and we all know that
pollutants flow downstream, and when it flows downstream
where is it going to go? Into Lake Manatee.
So we are very much opposed and concerned about
this project, and we urge you to at least withhold making
a decision on the matter, and it doesn't sound as though
that's going to be possible from the comments I've heard
already this evening, but we would urge you as a matter A
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of policy and a matter of practicality to withhold making
a decision on this matter at least until the local land
use decision question has been resolved.
Until the local land use decision has been resolved,
you really don't know what this project's going to look
like, because the local and state governments may attach
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conditions and stipulations which conceivably could
correct many of the very flagrant violations of air
and water pollution standards in this area.
Now, one other point that I'd like to make,
and that's one on radiation, and I'm no expert in
radiation, and I know that Mr. Hamilton's no expert
in radiation, and I also know that there were only
six borings made in this entire 10,000 acres to de-
termine the amount of radiation material, and that
is totally inadequate. i-
We all know that phosphate mining has associ-
ated with it significant increases in radiation. It
uncovers and brings to the surface radiation, radio-
active material that's covered, so we know that this
project will many hundreds of times increase the
amount of existing radiation that there is at the
surface.
Now, what you're saying is, "Well, it may still
be within limits," but that's not the point we're con-
cerned with* We have a relatively clean environment
in this area, and we'd like to keep it that way. We
don't care whether or not the rest of the country has
pollution. They're not as dependent upon retirement
and recreation as we are, so what we're saying is we
know that there's going to be a significant increase,
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for example, in radiation at the surface due to the
uncovering of the radioactive material.
We ought to make an effort, a conscientious,
thorough effort, to determine by how much, and six
borings in 10,000 acres is not going to get it.
Those are the preliminary comments that I
have to make. Dr. Lincer will speak to you on a
little more academic level than I have.
Thank you very much.
(Applause)
DR. LINCER: My name is Jeffry L. Lincer. I
am the County Environmental Specialist for Sarasota
County. This (presenting) is a copy of a report that
I will try to summarize as briefly as possible.
Thank you very much for this opportunity to
present Sarasota County's concerns relating to Estech's
proposed Duette Mine.
Without further ado, I will get right into what
we consider the inadequacies of this Draft Environmental
Impact Statement. A more detailed discussion of these
various points, and some additional ones, can be found
in a report that Mr. Klier, Director of Pollution Control,
for Sarasota County, and I co-authored entitled, "Estech's,
formerly Swift, Draft Environmental Impact Statement,
Proposed Duette Mine, Phosphate Mine Beneficiation Plant,
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and Rock Dryer," dated November 27, 1979.
I'd like to first address the air pollution
problem. If there are any questions relating to
that particular section, I will redirect them to
tori Klier, because^-of his. extensive background in
this area.
With respect to the manner in which the air
quality analysis was carried out, there are several !
problems. First of all, the analysis is based on the
presumption that fuel oil to be fired in the facility
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would contain a maximum of 1 percent sulfur by weight.
Due to recent international developments, this
1 percent sulfur fuel oil is not available on a reli-
able basis, and a relaxation of the 1 percent standard
has resulted in FP&L, Florida Power and Light, being
allowed to burn 2.5 percent sulfur fuel, for instance.
Clearly, the air quality analysis should be re-
evaluated based on a more realistic fuel oil of at
least 2.5 percent sulfur fuel.
Secondly, to assume that 96.5 percent of the
sulfur dioxide will be removed by wet scrubbers is
overly optimistic. It was poorly documented in the
report, and it's far in excess of what is considered
state of the art.
According to a recent EPA review of sulfur
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dioxide removal by scrubbers in this country, which
Mr. Klier participated in, a 90 percent removal was
the maximum that could be achieved on a reliable basis.
Thirdly, and as indicated by the resource docu-
ment on air quality, the Draft EIS assumed that the
sulfur dioxide emission rate would not be very great
and therefore a detailed modeling analysis would not be
warranted.
Because of the above two points, a more detailed
major source analysis of sulfur dioxide should be per-
formed. Along these lines, the approach that was used,
that of factoring the nitrogen oxide concentrations by ®
(-
the ratio of sulfur dioxide to nitrogen oxide emission
rates, is an unjustified short cut, considering the
fact that the sulfur dioxide analysis should be done
independently as a major source.
In addition, critical information, like the
timing when the Florida Power and Light Manatee plant
was subject to a 1 percent sulfur fuel regulation and
the resultant increase in S0^, which the plant would c
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emit with subsequent higher sulfur fuel, were omitted •"
in the air quality analysis.
The air quality documents were presented in a
manner that made review of the actual input computer
data very difficult. For example, the interactive J
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sources that were actually inputted to the computer were
not cross-referenced. The various computer runs were
not indexed or properly identified, and the input codes
used were inadequately explained.
As if EPA's area-wide EIS had never been written,
Estech has proposed a new rock dryer. The area-wide
EIS, one, was predicated on the fact that there would
be no additional rock dryers; and two, clearly recom-
mended the elimination of the rock drying process at
the beneficic.tion plant.
With the above points in mind, the alternative
of using an existing rock dryer at a remote location
becomes far more logical. The apparent problems of
using "older, less-effectively controlled equipment
located in areas marginal with respect to air quality
standards" is, in fact, an opportunity for a double
benef it.
By choosing this alternative, the industry has
the opportunity to retrofit these existing facilities
with adequate environmental protection equipment. This
would result in no or little increase in air pollution
in Manatee County and likely, in fact, to reduce the
existing pollution being emitted by the rock dryers in
Polk County.
I'd like next to address three topics, and since
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they are interrelated, I would like to discuss them as
a unit. These are soils, hydrology, and water quality.
There are important, but often ignored, inter-
relationships between soils, the water contained therein
and the quantity and quality of receiving stream water.
Mining will disturb soils on 7,600 acres approxi-
mately and totally alter the nature of those soils on
approximately 6,600 of those acres.
Existing soil profiles in mining areas will be
destroyed, and in general the surface horizons will be
buried under layers of either subsurface overburden or
waste materials. As indicated in the Draft EIS, the
use of mined-out pits for storage areas for clay wastes
and tailing sands will have an effect on the water
quality in the shallow system, but the nature of these
changes will depend upon the nature of the materials
placed in these pits.
According to that text, the lack of reliable data
on the water quality of waste clay prevents projection eg
of this impact. It can't be categorized. b
During the rainy season, close to 4 million gallons
per day will be discharged from the operation to the East
and North Forks of the Manatee River. There will be
radical changes in water quality.
When, as indicated in the Draft EIS, there will be at lead
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a doubling of radium-226 concentration in surface
waters; whei, as indicated on Tables 4.10c and D
of the Draft EIS, there will be up to a tenfold
increase in phosphorus concentration and mass load-
ings in the North and East Forks of the Manatee River;
when there will be as much as an eighteenfold increase
in fluoride; when there will be a doubling of bio-
logical oxygen demand; when there will be up to a
fivefold increase in suspended solids; and when
there will be an increased contribution to these
rivers of over 14,000 pounds of total dissolved solids
per day, even during minimal flow coaditions, can we
in all good conscience conclude that the impact on
water quality will be acceptable?
In view of the above perturbations, it is easy
to understand Manatee County's reluctance to allow this
kind of land use, especially upstream from what is
perhaps their most valuable asset.
The sections of this Draft EIS relating to soils,
hydrology and water quality should be reassessed using
an holistic approach in an earnest attempt to clearly
identify impacts that are unavoidable and/or without
mitigation so that intelligent policy decisions can
be made with respect to the desirability of trade-off
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options.
As the text now stands, important data are
subordinated under apparently unrelated sections with
little effort to indicate cause and effect relationships
in a straightforward manner.
Now, what about the slime pond? The Draft EIS
proposes a 480-acre conventional above-ground slime
pond, which^will remain active throughout the entire
life of the mine to receive clay waste.
By the end of the mine life, the area will be
filled to about 25 feet above grade. This proposal
is diametrically opposed to the recommendations and
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the intent of the area--wide EIS, which states, i
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"eliminate conventional above-ground slime disposal
areas
It is also contrary to the best interests of
Manatee County. As indicated by Mr. Randall, Pollution
Control Director for Manatee County, on February 15,
1979, at a public hearing on this proposed mine,
"The best way to protect Manatee's most valuable asset,
that is, its water, is to have a below-grade settling
pond."
We were glad to see the Applicant choose to
devote an entire section to the hypothetical failure
of the clay settling area embankment. Apparently, the
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Applicant is almost as concerned about this subject as
those whose potable water source would be affected by
such a catastrophe.
As indicated in the Draft EIS, should the dam
fail, suspended solids over a two-month period would
deposit in the reservoir approximately a 60-acre feet
of the suspended solids, and total radium-226 would
exceed the State's standard for Class 1-A waters upon
entering Mam tee's reservoir.
The eEfect of the solids on the Manatee River
floodplain would be to kill most trees and severely
stress many of those that do survive.
It would also result in the destruction of
aquatic fauna of the river with few, if any, organisms
surviving.
Although it is apparently financially un-
attractive to the industry to comply with the area-
wide EIS recommendation relating to slime ponds, no
alternatives to the conventional above-ground slime
pond are even discussed.
A conscientious attempt should be made to in-
vestigate and honestly discuss partially or totally
incised slime ponds, thereby significantly decreasing
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that of FP&L's facility in the Okeechobee area just a
few weeks ago -- and this was a dam that was constructed
within approximately the last year and a half — putting
our faith in a once-a-year inspection by a Registered
Professional Engineer and his monthly review of reports
by on-site personnel is woefully inadequate considering
the above projected impacts.
The approach should not be how we manage a slime
pond once it's installed. An above-ground slime pond
should not be allowed in the first place.
I'd like now to talk about water management, and
I guess that's a natter of relativity. As indicated by
the Draft EIS, 89 percent of the total water require-
ments will be recycled water.
However, the apparently innocuous 11 percent
make-up water required to offset system losses will
average more than 16-plus million gallons a day, more
than most large cities around here.
In a rapidly growing area where potable water
needs are escalating, any reduction of potable water
availability has to be examined very carefully* ^
reduction of 7.2 million gallons a day mgd in the flow
of the North and East Forks of the Manatee River will
actually decrease the discharge of that potable water
into Manatee's reservoir by almost 10 percent.
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As bad as this is, what seems to have been lost
in the statistical manipulations presented in the Draft
EIS is that the total flow of potable water, specifically
from the North and East Forks of the Manatee, would be
reduced by 33 percent.
With this 10 percent decrease in potable water
reaching the Manatee reservoir, with a 33 percent
reduction of potable water supply to major contributors
of that reservoir, and the resulting ecological impact
of discharge reduction, as described in a couple of minutes
the entire water management program needs to be revisited.
I'm glad to see that that segment of the East Fork
of the Manatee River proposed for mining has been de-
determined to be a Category 1 wetland.
However, disturbing wetland Categories 1 and 2 --
excuse me -- 2 and 3 should be re-examined when they are
upstream of Category 1 wetlands and when that perturba-
tion can be expected to affect downstream Category 1
wetlands.
A very important consideration, which was re-
ferred to previously, is the ecological impact of water
flow reduction on separate parts of the drainage system,
which is somehow glossed over by grouping statistics.
For example, the Draft EIS indicates inflow will
occur -- a reduction in flow will occur in the East Fork
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by 5.4 mgd. A comparison with existing statistics in
the same document reveals that this 5.4 mgd exceeds the
average minimum flow during wet months as well as the
average mean and minimum flow for dry months, 5, 3 and
.8 mgd respectively.
With a vision of dried-up stream beds and a
complete annihilation of fish, aquatic, invertebrates,
and other wildlife, which are totally dependent upon
stream water for their existence, Estech's proposed
water management program is unacceptable.
What about other habitat loss? With respect to
upland communities being lost, 85 percent of native
upland vegetation will be lost as a result of the
proposed activity.
As indicated by the Draft EIS, these impacts are
largely long-term and irreversible. Perhaps the most
devastating aspect of the proposed mining reclamation
plan on upland communities is their repLacewent ^ m
cultures, like improved pasture.
For instance, there will be an increase m
improved pasture of almost 5,000 acres, an *-ncre
_~nt time.
of fourfold over that existing at the prese*
a an 18-acre
Preserving 50 acres of sand pine scrub ana
a leaving
cypress pond, while mining all around it an
oortion of the
it as a pedestal, and devastating a majoi: v
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flood plain swamps, is not a reassuring commitment to
protecting important habitats. '
Keeping in mind the policy objectives of Manatee
County and the Regional Planning Council, which refer
to desirable objectives, such as maintaining a high
quality of human life and protecting environmental and
natural resources, the anticipated overall loss of 85
percent of native upland vegetation is an unacceptable
outgrowth of the proposed mine and related activities.
Of course, we shouldn't only concern ourselves
with the habitats. We should be concerned with how
that destruction affects the denizens, the inhabitants
of that habitat, and I'd like to address now very
briefly the rare and endangered species question.
All levels of government, local, state and
federal, have recognized the importance of the medical,
scientific and aesthetic values of the endangered specie?
and the need to protect the ecosystems upon which en-
dangered species depend.
Sixteen species considered endangered, threatened,
I rare or of special concern have been observed on or
immediately adjacent to the Estech property. At least
two species will have their preferred nesting habitat
J "substantially decreased by mining" and a third "may be
able to survive in one of the disturbed scrubs, but there
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|| will be little suitable habitat after mining."
As indicated by a recent study by Layne, et al.,
of the Archbold Biological Station, other endangered
or threatened species, like the Florida panther, the
Florida bear, the Bald Eagle, and the osprey are likely
to be present on that site.
However, and as admitted by the Draft EIS, the
field techniques relating to these species may not have 0
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been extensive enough to reveal the presence of these H
important species.
Like most other Draft EIS's reviewed to date,
this one simply lists the threatened or endangered a
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species that will be affected, if not annihilate<^> an^
makes no serious effort to actually preserve these
unique gene pools *
The time is long overdue for the phospkate
industry to justifiably shoulder the responsibility
of accurately identifying the unique and endangered
species present on the proposed site and then in ap
propriate detail indicate how these resources will-
protected .
Very briefly, concerning the reclaroat*-on,
~-hat reclamation'
are foreseeable problems associated with
For instance, it is very possible that the prC>P
charge^ wells
method will reduce the effectiveness of re
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by decreasing the permeability of the property and
decreasing the bearing capacity of the new soil, an
assemblage which will limit future land use options
for that site.
If the land use is to remain rural in nature,
the limitations may not be too serious. However,
when residential development ultimately finds its way
to that site, or perhaps other kinds of development, «-
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developers may find it necessary to take extraordinary *¦
precautions in order to stabilize foundations or take
other measures that will increase the cost of de-
velopment .
Since the health implications of increased
radiation are of immense concern to most of us, we
should be quite sure that we are characterizing the
existing radiological picture accurately. Along
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these lines, one has to question whether six samples £
for radioactive substance taken on site is adequate.
Given the fact that much expert testimony in-
dicates a very possible health impact from any increase
in radiation exposure, we are more than justified in
taking a conservative approach to handling these sub-
stances .
As a bare minimum indication of concern for public
health, the Applicant should be required to remove and
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store the surface horizons of the soil in such a way
that material can be replaced on top of the more
radioactive substances below.
By way of conclusions, the Draft EIS describes
a number of installations and land uses that are in
direct conflict with EPA's area-wide EIS. The most
outstanding, of course, are the rock dryer, the above-
ground slime pond and devastation of Class 1 and
juxtaposed wetflands.
Not only is the proposed action by Estech
contrary to the recommendations of that area-wide EIS
and to Manatee County's zoning ordinances, but it s
also diametrically opposed to the region's growth
policies as stated in the Regional planning Council s
1 of '75
Future of the Region, which was adopted in *JU "
and amended recently, April of 1979.
What is particularly disconcerting about th
Draft EIS is the overall orientation. Th^t orient
jn tioris of the
is to justify exceptions to the recommence
bribing and
area-wide EIS instead of identifying, desc
rtiv the
analyzing mining methods which would compos
aoecially those
recommendations of that area-wide EIS, eSF
i me ponds, and
relating to rock dryers, above-ground sn
the protection of wetlands.
of negative
There is a consistent glossing ov
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impacts and a reluctance to spotlight problems and
tackle alternatives in a conscientious manner.
EPA in good faith cannot accept this Draft
EIS as an adequate extension of the area-wide EIS.
Unless EPA requires the third-party consultant to
revisit the above key issues that deviate significan-
tly from the recommendations of the EIS, EPA will in
fact be abandoning the area-wide EIS, which cost the
taxpayers in excess of $1 million.
EPA cannot take the action proposed on page 180
of the Draft EIS because that action is based upon a
site-specific EIS which does not conscientiously attempt
to identify, describe and analyze mining methods which
would eliminate above-ground slime ponds, not require
the proposed rock dryer, and protect wetlands and
endangered species which are vital and outstanding
local and natural resources.
Recommendations are but two --
MR. PERRY: Br iefly, plea se.
DR. LINCER: -- one, that no further agency action
be taken until the Draft EIS is re-focused so that EPA
can make an intelligent decision, as required by NEPA,
based upon a conscientious analysis of environmental
impacts identified by this report that have been glossed
over by the Draft EIS; and the second recommendation is
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that no federal permit be issued because it cannot be
justified in the absence of local approval of the
proposed Estech mining.
Thank you,
(Applause)
MR. HAGAN: I'd like to thank Jeff for his
excellent report. As always, he responds in an over-
whelming technically-competent way, and we will
make, not only his oral presentation, but his written
report a part of the record of this meeting, and we
will respond to the point-by-point discussions that
he had in our final Environmental Impact Statement.
MR. PERRY: Any other comments from the panel?
MR. BRYANT: Yes. I would like to have him
submit a copy of this study to me.
MR. HAGAN: Jeff, since we printed 600 copies
of the EIS, is it reasonable to expect that you could
give us a couple of extra copies of this?
DR. LINCER: I think I brought 1 percent of
those 600 with me.
MR. HAGAN: I appreciate it. Thank you.
MR. PERRY: Are there any other comments?
(No response)
If not, I would like at this time to see whether
or not there are any other local governmental interests
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that would like to be recognized and/or speak at this
time.
MS0 GLASS: Patricia Glass from Manatee County.
MR. HAGAN: Yes, ma'am. Thank you for being
here.
MR0 PERRY: Are there any others?
(No response)
All right. I would like to proceed, then, with
the public's participation and recognize Mr. Robert A.
Lyman.
Mr. Lyman?
MR. LYMAN: I'm Robert A. Lyman, agricultural
consultant. I have a letter to you, Mr. Hagan, which
I wish to file and which I wish to read also. (Presenting)
As I look at this crowd, I wonder how many have
been to Duette.
A VOICE FROM THE AUDIENCE: I have.
(A showing of hands)
About one in ten, almost as many here as might
be at the school house recreation Halloween night.
Duette is a growing community in agriculture.
I've watched it for thirty years grow in improved
pastures, in improved citrus groves, and I have par-
ticipated in it, and I still am, but I don't live there.
It's far away to go to Polk County, and they live
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in Lakeland, and they have their pastures and the groves
20, 30 miles away from Lakeland. This is not unusual
throughout the world.
It is a beautiful community. It is as far out
as you can get in Manatee County, green, unspoiled.
I would like to say that EPA, Mr. Hagan, CCI
consultants, Mr. Hamilton, and Mr. Davis from Estech
have a large responsibility here. I recognize that.
However, I would like to speak to you tonight
about another large responsibility, which in some ways
has been slighted. This is the agricultural responsi-
bility.
Most of the Manatee County area, 400,000 acres,
is still agricultural. One-fourth of this, over
100,000 acres, is in the hands of the phosphate people.
These are the agricultural reserves we are now needing
and which will be in great demand for the next ten years
and for which there'll be an agricultural shortage in
the next 20 years for cultivation, citrus,
pasture, cattle, dirt.
However, don't take me wrong. I'm not
the phosphate industry. I'm just speaking neutrally
what is best for the long-range agricultural use
,ild feel
this land, and I am here tonight because I
jc A6f&ult«
that if I were not here, I would be guilty 0%
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Therefore, I hope you follow my letter in good
grace.
Mr. John E. Hagan, III, Chief, EIS Branch,
Environmental Protection Agency, Region IV, 345
Courtland Street, N.E., Atlanta, Georgia 30308,
regards Environmental Impact Statement, Estech General
Chemical Corporation, Duette Mine, Manatee County,
Florida, Draft, EPA 904/9-79-044, October 1979:
Dear Mr. Hagan: The above document has been
received from Mr. John C. White, Regional Administrate*
to me as a concerned individual.
This document and the resource documents have bee
reviewed with interest. The following comment is re-
spectfully submitted.
These voluminous documents have the potential of
being good references for economic and academic u.es.
w
However, there is need for corrections, revision and 7
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more clarification in the agricultural presentations.
This is important as the highest and best use is
agricultural and will continue after mining. It Is cui
rently a high potential for the future needs of more
intensive uses and yields.
You can and should correct and improve your docu
ments by becoming involved with personalized, direct
exchanges with local agencies for basic and common |1
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information, as well as potential planning.
This includes land and water, USDA Soil
Conservation Service; forestry, Forest Service, State
of Florida; economics, Economic Research Department,
IFAS, University of Florida; roads, Manatee
County.
Manatee County also has many other departments in-
cluding a large staff in the County Extension Service.
This is ad libbed; it's not in the letter, and I
assume it's being recorded. I hope so.
This includes pages 120, 122, 123, 128, 138, 135'
157, etcetera. The subjects presented are too diverse:
and voluminous for any one individual or agency to
adequately review or present.
Thank you for this opportunity to show my conceri
Very truly yours, Robert A. Lyman. Carbon copies to
Louis E. Driggers, Manatee County Commissioners; I.H.
Stewart, District Conservationist, USDA SCS; J.
Walter Prevatt, Extension Area Economist, University
of Florida; George Montgomery, III, County Forester,
Florida Department of Agriculture; Dr. C.W. Hendry,
Chief, Bureau of Geology, Florida State DNR.
Thank you for the opportunity. When you
(Applause)
MR, PERRY: Thank you, Mr. Lyman.
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I would like at this time to recognize Mr.
Fred C. Duisberg representing Save Our Bays Association.
MR. DUISBERG: My name is Fred Duisberg. I'm
President of Save Our Bays Association. My reason for
being here is to represent the feeling, the opinions
of the ordinary citizens of this area.
Recently, this last spring, Save Our Bays As-
sociation, through A.C. Nielsen Corporation, conducted
a survey of opinion in connection with the upcoming
land use plans as mandated by the State.
Included in that survey were two questions con-
cerning phosphate; that is, the -- well, the reaction
of the people answering the survey The survey itself
was sent out It concerned Sarasota County.
It was sent out to one out of every five registered
voters of that county, a total of in excess of 20,000 people.
The response was in excess of 6,000 people, and
the two questions concerning phosphate mining, and these
were kept as simple as possible At any rate, on that
basis, A.C. Nielsen Corporation, considered the, well,
most credible corporation in the world in this field,
felt that it was an extremely credible survey. The
response was far in excess, almost double, of what they
expected.
So it indicated a high degree of concern as far
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as the citizenry of this area's concerned.
The two questions concerning phosphate: One,
do you consider mining and processing of phosphate
as having an impact on an environment?
Most of the answers were "very detrimental," and
63 percent of the persons answering said yes, phosphate
mining was very detrimental. This is based on the
information that has been available through the Draft
EIS, through newspaper reporting, and a great deal of
information that has been disseminated throughout this
entire area.
Those that said it was somewhat detrimental
were 23 percent# In other words, 86 percent of the
people, a true cross-section of the population of this
area, consider the phosphate mining and processing to
be detrimental to their best interest.
The permitting of mining and processing of phosphate
should be withheld until safeguards to protect the en-
vironment are assured.
Now, I think the safeguards have been spelled out
and they have been mentioned in this forum very much by
the Texas Instruments, EPA, Draft Environmental —
regional environmental study, which is available right
here in this school, incidentally.
At any rate, those people, then, answeting this
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qviesttonivaire who are violently opposed, and this is the
term used, to further phosphate mining without adequate
safeguards to protect the environment, 82 percent are
violently opposed. Thirteen percent are moderately
opposed. Orly 5 percent are either not concerned or
have no answer.
Now, I think this is now 95 percent of a true
cross-section of the population, of a large portion
of the population, that must be affected by this mining.
I think it's the obligation of every government
agency and of everyone employed by a government agency
to listen to the people. That's their job.
Now, this thing goes beyond the technical in-
formation that has been given here. I'm speaking simply
as a layman, but we're concerned with an irreplaceable
natural resource, a resource that is far more important
to our future than petroleum, and everybody knows the
situation this country is in today.
We're being blackmailed because we are dependent
upon foreign sources. Florida has 4 percent of the
phosphate of the world. Our phosphate will be exhausted
completely exhausted, according to the EPA, Texas Instru-
ments, studies, by the turn of the century, and we will
then be, to a large extent, at the mercy of Middle Eastei
suppliers.
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The major portion of phosphate is contained in
Morocco, some 40 percent, as compared to our 4 percent.
We are shipping out more than 40 percent of what we're
mining now, and our mining is increasing year after
year.
The major objections, that is, as far as en-
vironmental considerations are concerned and technical
points, have and will be made by other people, but I
would say this, that the important thing to consider
here is the real welfare, the real future of our own
country, our United States.
If we fail to do that, then we are actually
engaged in a criminal action. That's everyone, you
people sitting at the front and you in the audience
and all of us, because we are jeopardizing —
(Applause)
-- our entire future. Thank you very much.
(Applause)
MR. PERRY: Thank you, Mr. Duisberg.
I'd now like to recognize Mary L. Jelkes, who
is a physician. Please pardon me if I mispronounce
anyone's name. It's not my intention.
DR. JELKES: Thank you, Mr, Perry.
I'm a pediatric allergist, and I've been concerned
with the environmental effects of the phosphate industry
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on the health of our population for some time. I have
addressed some of the general attitudes that other
people have addressed here, so 1 wanted to hit just
some of the areas that have not been covered, and I
will give you my copy of what I am presenting.
Actually, one area that has not been adequately
addressed here is the radiation problem -- and I did
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I have read that there are ways of neutralizing the
acidity, which decreases some of the dispersal.
More things of this sort should be addressed.
I have gone into other areas in my letter here, but
I would like to summarize, that you should implement
the newer guidelines that have been addressed here
that have been developed by the EPA and require re-
covery of any of the uranium and fluoride from the
waste.
You should line the waste ponds with an im-
pervious material and eliminate the rock drying that
is implied by this statement, require strict compliance
with the water consumptive uses and require strict
reclamation rules.
The areas that are reclaimed should be posted
as hazardous until they are safe to the population. Avoid
conventional slime ponds and do not allow the mining of
the East Fork of the Manatee River, as the draft state-
ment had implied would be allowed.
I submit my copy here, which covers other
articles, too. (Presenting)
MR. PERRY: Thank you, Doctor.
(Applause)
I would now like to recognize Mrs. C.G. Fernald,
who is Vice-Chairnan of Save Our Bays, Incorporated.
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MRS. FERNALD: My name is C.G. Fernald, and I
represent Save Our Bays for Manatee County, but I'm
speaking to you tonight mostly as an avowed capitalist,
and I am absolutely appalled that capitalism, in the
guise of all the phosphate companies, would be wreck-
ing the economy of this area, wrecking the land, while
doing absolutely nothing for the people in the area.
We are people who live here, thousands of us.
We make our homes here, and we see capitalist companies
completely forgetting about the benefits of the United
States.
Phosphate, lasting only 20 years $ all these com-
panies have to do is block it up for 20 years and wait N
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until other people's phosphate is gone before they use H
ours, but Russian ships ship phosphate overseas. Germans
can buy phosphate cheaper than they can mine it themselvess
in their own country, and we're letting capitalist com-
panies do this to us and cut us to pieces, and here we
have a county that bases all its economy on retirees
and vacationers, and I'd like to have you people in EPA
really look into the money that comes into this county
in Social Security, the money that comes into it in
vacationers and see how it balances out when the land
is ruined and the people take their money away.
Retirees are mobile. They can decide to move
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somewhere else if they don't like the area, and this
is exactly what's going to happen in this country and
in this area, unless the companies are a little more
res pons ible. j
So I'm pleading for the capitalist companies
to really pay attention to -what's good for the
country for a change and do something about it.
I have some questions to ask. Are you making
40
any attempt to look at the way the reclamation has 2
been done in Polk County from the other mines this
company has had? Are foreign investors investing in
this company? Are we being involved with foreign
investors who want to take the phosphate out of the li
country? Have you looked into the ships that's ship-
ping out phosphate to other places in the world?
I think that the EPA and the Department of
Environmental Regulation have a lot more to look at
than just the physical aspects of this, and I plead
with you to do this.
Thank you very much.
(Applause)
MR. PERRY: Thank you, ma'am.
I would now like to recognize Mr. James L. Hunter,
who I believe represents the Manatee/Sarasota group of
the Sierra Club.
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MR. HUNTER: Members of the panel, thank you
very much.
First of all, in no way do I want to criticize
only Mr. Davis's Estech mining operation as proposed in
Manatee County.
The Sierra Club is totally opposed to any more
phosphate mining in Manatee County because it will
spread to Sarasota County.
What we're talking about is, as Mr. Davis pointed
out, when Polk County mines run out of phosphate, they
are moving to Manatee County. When those mines in
Manatee County run out of phosphate, they will be moving
elsewhere.
I want to address all the facets of the Environmental
Impact Statement, but our primary emphasis, as I said,
is going to be on the total effect of phosphate mining
in this area.
We are opposed to the diversion of the East Fork
of the Manatee River. We foresee slime spills, just as
we've seen on the Peace River, occurring on the Manatee
River.
Also we foresee very grave, great problems with the
reclamation as stated. First of all, we see that out
of the 10,000 acres that Estech owns, we're going to
be mining about 6,600 acres. Out of that, about 68 acres
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are going to be preserved, about 18 acres of cypress,
and 50 acres of pine.
This seems like a small point of gratitude.
What are we going to see after the mining is done?
First of all, I question the 100 acres that are going
to be returned to "wilderness." How is this going to
happen when we know that not native species overtake
the lands in Florida, but Melaleuca, Australian pines,
and Brazilian peppers.
We can see it now everywhere we disturb the
lands in our preserved areas from the Everglades to
our own Myakka State Park.
Lastly, I think what we're seeing here, as Mr.
Duisberg pointed out, that there is a nation-wide effort
to see a new direction in our development and industrial-
ization. The objective of this and the result of this
is to end the waste of our resources, to end the waste
of our water, air, land and non-renewable minerals,
non-metallic and metallic, from phosphate to oil,
and the result, final result, is that local govern-
ments throughout the United States and local citizens
are seeing that the nation must pay attention to this,
that we think that our local environments are worth
preserving.
Thank you very much.
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(Applause)
MR„ PERRY: Thank you, Mr. Hunter.
I would now like to recognize Mr. John Rains,
Jr., President of the Manatee Chapter of the Izaak Walton
League.
MR, RAINS: Mr. Perry, I would like to waive
my five minutes and let Mrs. Rains speak next, if I may,
and this will be a joint presentation, only it will run
a little bit longer than one person to get through, if
this is agreeable with you.
MR. PERRY: That'll be fine. Mrs. Gloria C.
Rains of the Manasota-88.
MRS. RAINS: I am Gloria C. Rains of 5314 Bay
State Road, Palmetto, here as a member of the Izaak
Walton League and as Chairman of Manasota-88.
Some of our members find this hearing at a time
when the Estech application to mine phosphate in Manatee
County has been denied by our local government and when
Y-
the matter is under litigation, incongruous and an ?
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event that could be misconstrued by some as an attempt
by the federal government to usurp the power of local
government.
Certainly, if the county's decision to deny this
firm's application is upheld, as we have every hope it
will be, this hearing is unnecessary.
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We would ask that you withhold a decision re-
garding the issuance of this permit until all litiga-
tion has ended.
We are opposed to the permitting of this Estech
facility for the following reasons:
The quantity of uranium oxides mixed with
phosphate rock exceeds the quantity extracted by the
domestic uranium industry. These radioactive substances
are redistributed and concentrated during mining. No
small matter.when you realize after mining that 48% of
total radioactivity remains with the slime ponds and
liquified clay and 12% remains in the waste sand tailings.
Therefore, I would like to bring to your atten-
tion some most serious comments regarding the separate
EIS document entitled Radiological Environment, dated
October 1979.
In this document you will find reference to
an article in Science Magazine and a reference to eg
£
Spalding. It appears these references are incorrect in
text. Therefore, it appears the assumptions through
this document may be incorrect.
Due to unavoidable problems, information I
hoped to present you from Dr. Edward A. Martell, National
Center for Atmospheric Research, Boulder, Colorado will
be mailed by Dr. Martell to both the Atlanta office and
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to the National Administrator.
However, Dr. Martell has provided information
regarding "possible groundwater contamination from
uranium contamination in the reclaimed land areas
and on the magnitude of risks due to radon progeny in
structures located on reclaimed lands."
On the top of page 57, referenced volume:
"it is assumed that ore processing does not change
the uranium to radium equilibrium.
"This assumption is unjustified and highly «
CI
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questionable. *~
"Radium-226 is similar to calcium in its
chemical properties and is highly fractionated in
phosphate wastes and waste water.
"in particular one should look at the distri-
bution of soluble uranium in the waste water and in
contaminated groundwater of reclaimed Florida phos-
phate land areas.
"Only recently the contamination of ground-
water by soluble uranium from uranium mines and
uranium mills has been recognized as a potentially
serious problem in Colorado and other uranium mining
areas."
Reference to the bottom of page 64: "For
completeness uranium-238 and Pb-210 should be added
't
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to this list.
"Both are bone seekers and the uranium-238,
as well as the polonium-210, emit alpha radiation
and contribute to the risk of bone cancer and
leukemia.
"The concentration of these isotopes should
be assessed in drinking water and in cereal grains,
other vegetable foods and dairy products in and near
*
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r ec la imed phos pha te la nd s.
"These "two isotopes also should be included
in the list of radionuclides measured in dust
par tic les
Reference page 77, paragraph 6: "Here again
it is "assured" that the uranium is present in
equilibrium with radium in the phosphate fertilizer
n
product.
"However, Spalding and Sackett showed that
uranium is readily leached from phosphate fertilizers
by water.
"Thus light concentrations of uranium isotopes
are to be expected in waste waters and groundwaters
in and downstream of phosphate production sites and
in wells and streams through reclaimed lands-,"
Reference page 78, paragraph 3: "it is stated
here that "Community water systems shall not exceed
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15 picocuries per liter of gross alpha (including
radium-226 but excluding radon and uranium).
"The combined radium-226 and radium-228 shall
not exceed 5 picocuries per liter.
"The lack of a soluble uranium standard for
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water quality here is a very serious omission. «
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Recently, Dr. W.L. Lappenbusch, EPA Office of Radiation
Programs, has proposed a water standard of 10 picocuries
per liter for soluble uranium radionuclides (mainly
uranium-238 and 234)„
"Based on current knowledge, this is not
necessarily a conservative standard. Based on studies
by Dr. Miriam P. Finkel, Argonne National Laboratory,
bone tumor risk for uranium and radium are very nearly
the same per unit of alpha activity in bone.
"Uranium also gives rise to cancer in the
kidney. The bone uptake and retention of uranium is
very much higher in young children than adults. The
relative risks for uranium and radium should take into
account both the relative uptake and retention on a
cumulative basis for chronic exposure. The distributions
in bone also may be very important.
K
"Per unit activity, plutonium-239, which is «
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highly non-uniform in bone, gives rise to a ten times
higher bone tumor risk than radium-226.
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"Chronic exposure is the uranium distribution
in human bone similar to that of radium-226. The
risk may be expected to vary.
"The need for a drinking water standard for
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Pb-210, which is a bone-seeking radionuclide, and «
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polonium-210, which emits alpha radiation, should
also be considered.
"Radon in the water supply is an added
source of indoor radon progeny for all residents in
the affected areas."
Reference page 72, lines seven through ten:
"The EPA proposed standards cited here, 0.020 working
level total exposure to radon progeny, including
background, represents a substantial risk that may
not be acceptable for public exposure when its full
cancer risks are known by the general public.
"Lifetime exposure to 0.020 working level
will give rise to about 3,000 excess lung cancer
deaths per 100,000 people.
"Actually, EPA concedes this could be as
high as 5,000 excess lung cancer deaths per 100,000.
"In addition, it is now evident that this level a
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will also give rise to a large increase in skin •"
cancer risks.
"Dr. Martell estimates that lifetime exposure
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to 0.020 working level in houses and other structures
will result in about ten times higher than the
normal incidence of skin cancer."
Additionally, one rock dryer emits 64.5 tons
per year of particulates and 2,450,000,000 picocuries
of radium-226, an amount which exceeds the equivalent
radionuclides which would be allowed by the Nuclear
Regulatory Commission from a 1,000 megawatt nuclear
power plant.
The two dryers proposed at this plant will
emit 1,290 tons of particulates and 4,900,000,000
picocuries of radium-226. These emissions can be
somewhat controlled, but not eliminated through
scrubbers.
However, scrubbers have a high rate of failure
and are only as good as their maintenance.. High
stacks to aid dispersal of these radioactive residual
particulates and pollutant gases over the county is
hardly a satisfactory resolution of this problem.
Further, disposal of radioactive residue from
these scrubbers pose another problem.
Therefore, despite scrubbers and stack dispersal,
there can be no question that significant and dangerous
to human health levels of radionuclides and particulates
will continue to be emitted into our county air by the
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proposed dryers.
Based on the latter, there can be no justi-
fication for the permitting of these rock dryers or,
for that matter, mining as it is presently done.
Particulates from routine mining operations,
transport of the rock and loading operations also
create problems.
Among other things, they cause obstructive
pulmonary changes, and alpha particulates, thought
to remain in the lungs for years, also can cause
death before cancer becomes evident.
As far as reclamation, the EIS says it will
be too expensive for Estech to follow EPA recommendations
for land cover of 3 to 4 feet of topsoil.
Actually, to date, there is no way to guarantee,
either through home design or 3 to 4 feet of "relatively"
radiation-free earth cover, freedom from adverse health
effects while living on reclaimed lands.
There can be no doubt radioactive soil in
reclaimed phosphate mining lands is a serious problem,
so serious that overburden, waste sands and clay used
for fill have been proposed for classification as
"special" hazardous waste.
It is doubtful reclaimed lands can be safely
used for housing. It is doubtful they can safely be
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used for cattle or crop production either.
The EPA Phosphate EIS and other sources state
consumption of foods (crop foods or beef) produced on
reclaimed lands provide a route for secondary radiation
impact exposures, and as Dr. Martell has pointed out,
tests for other radioactive substances need to be
done in these areas.
If this mining is permitted, we may experience
a permanent decrease in agricultural lands. In fact,
as radiological studies are made known, it may well be
that phosphate mining constitutes a permanent use of
the land.
Restoration of wetlands on this site is im-
possible because of changes in adjacent land terrain,
alteration of the local hydrologic regime and changes
in the particular constituents of the water.
To date, the creation of wetlands has never been
successfully demonstrated. o
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Marsh-type reclamation projects will not replace
the natural functions of the true marsh.
Mining, as it is proposed here, will destroy
native vegetation, natural watersheds and the natural
order of the soil's layers from toP to bottom of the
mined-out zone. Topsoils will be obliterated, breaking
up the water-holding hard pan underlying most of the
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property and will so change soil profiles and land
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contours as to irrevocably alter surface drainage pat- ,1
terns. Reclamation cannot restore these systems.
Further, we ask that the Technical Staff of cv
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EPA's Air Quality Section further check the EIS Air H
Quality report for sufficiency and accuracy which we
understand has not been done. We base this request
on information obtained from the DER/Agrico vs. Free-
port Sulphur/Sulphur Terminals Incorporated Administrative
Hearing where this same preparer was used and where
extremely serious omissions of data were found. (See
attached information).
We need to know if all emissions that could
reasonably be anticipated and all the proposed emission
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points, including the most significant ones, were in-
eluded for consideration in this EIS.
There appears to be some question that the
concentrations predicted by the Air Quality Display
Model are reliable because of the nature of the emis-
sion estimates on which they were predicated. We quote
II *
page 42 of the EIS which says, It is recognized that ^
the utility of this estimation is highly dependent
on the estimate of background concentrations. However,
consideration of available facts will suggest, etcetera,
etcetera."
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It should also be mentioned that cumulative
effects of all mining operations presently permitted
in our region plus Estech do not appear to have been
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adequately considered. Additionally, the impact of *
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the support activity, electricity generation -- in this
case, the daily generation of 73,955 KVA to supply
this facility, which will produce further deterioration
of air quality -- does not appear to have been considered.
What is listed as the hypothetical failure of
the clay settling area embankment, more commonly re-
ferred to as a slime pond break, is not so unlikely,
as we know from the recent FPL dam break.
It appears the effect of such a spill on our
reservoir as described in the EIS may be understood
and based on assumptions which appear to be questionable. •
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Also, a number of rather important facts are not dis-
cussed, such as how much it will cost to return the
reservoir to operating condition.
Predicating the short-term effects of this
hypothetical spill on the "instant mixing of the 1,000
N
acre feet of clear water discharge from the clay set- 7
tling area with the minimum of 6,920 acre feet of re-
servoir storage does not appear realistic.
Careful reading will show the water flow into
the reservoir will be reduced because of waste clay
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damming the stream involved. This will mean a reduction
of 9 to 12 million gallons a day of water flow to the
reservoir, leaving the slime to ooze in.
Considerable evidence exists to assume expen-
sive installation of new drying beds and probably new
lagoon facilities and other new equipment would be neces-
sary if this reservoir could ever operate again. The
speed with which the EIS says this area is supposed to
be revegetated again is questioned. Further, based on
the conclusion of a Tampa Bay Regional Planning Council 208
consultant, it is doubtful the reservoir could ever ea
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be used again for a potable water source. If it were •"
possible, the expense in rendering it operable would
be catastrophic.
EIS projections regarding radioactive levels,
total suspended solids, etcetera, after the spill appear
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quite optimistic. We ask EPA thoroughly to examine 7
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these projections and the basis for them.
As far as probabilities of a dam break are
concerned, we are talking about our publie-drinking
water supply upon which the overwhelming number of
people in Manatee County and many in Sarasota County
rely. It will take only one spill to put us out of
business.
While the EIS sees recharge for our groundwater
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aquifer as posing no problem, accumulated information
shows injection through connector wells of surface
aquifer water, long in contact with radioactive materials,
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into deeper zones of different and generally higher
!¦
chemical quality, prior to mining, will further con-
taminate our groundwater with radioactive materials.
Monitoring, as proposed here, has not prevented
this from happening nor have adequate remedies to pro-
tect our groundwater from this contamination been
successfully implemented in other mining areas.
As to cumulative effects, even before any mines
ate operating in Manatee County, SWFWMD staff members
estimate the amount of water from mining operations
presently injected into our Florida aquifer, which
provides water for thousands of Floridians and has been
designated by SWFWMD as the best potential source of
drinking water for Sarasota County, is already between
25 and 30 million gallons a day.
In order to protect our groundwater from fur-
ther contamination, we recommend against this proposal.
Recharge wells should not be permitted until radiation
problems are solved.
Further, based on such evidence as exists, to
intimate, as the EIS does, that contaminated ground-
V"
water will remain under the mining site for the f
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foreseeable future or will migrate only a short dis-
tance is, at best, unscientific.
Our surface water will be severely impacted
from this proposed mining. It should be noted the
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cumulative effects of more than one mining operation
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have not been considered.
The water resource regime will be changed
before mining even begins when all vegetation is
stripped from an area. This will eliminate plant
evapotranspiration, intake of water from the soil and
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the release of water from all living plant tissues. f
Small climate changes will result which can signifi-
cantly alter rainfall regime. Natural flow patterns
and storage capacities will be irretrievably altered.
Runoff patterns will be demolished as will be natural
recharge areas.
The runoff from this mining tract now contributes
11.6 percent of the total flow into the Manatee River.
Even with such reductions as are possible with controls, 2
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we can expect steady deterioration of the Lake Manatee
watershed as a result of normal discharge of phosphate
wastes.
The average runoff of 11.8 million gallons a
day from this site will be just as polluted as are
the discharges going into the Peace and Alafia Rivers.
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Mining of minor tributaries and bayheads ad-
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jacent to major streams will also further contribute U)
to water degradation.
For a minimum of two months of the year, 1.959
million gallons a day will be discharged from point two
into the East Fork of the Manatee River; three months
of the year, 1.773 million gallons a day will be dis-
charged into the North Fork. This means Estech will
dump in the neighborhood of 36,700 gallons per minute
of excess water into the North Fork of the Manatee.
Aside from the hazards of radioactivity and
the residue of known carcinogen reagents used in the
flotation process, the EIS concedes that federal/state
standards for total suspended solids, total phosphorus
and fluorides will be exceeded for varying amounts of
time up to 14 percent.
Additionally, we are told fluoride concentra-
tions, based on acceptable methods of data projections,
cannot meet the state standards at a station near to
the Manatee County water plant intake.
However, we are told Swift will regularly
monitor effluent water quality at the permitted points
of discharge to assure compliance with NPDES permit
conditions and that these discharges of effluents will
not noticeably alter water quality.
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Of course, accumulated levels of fluorides, solids,
phosphorus, reagents and radium will adversely affect
water quality and permit accumulations of harmful
materials- It will just be accomplished, perhaps, at
permitted levels.
Further, the company saying, when the situation
can be corrected, that it is too expensive to clean up or
prevent this degrading to water quality discharge from
entering the North Fork is not cause for reassurance
nor is the fact that monitoring abuse is prevalent
throughout the industry and that water quality cannot
be checked often by our regulatory personnel.
We can think of no justification for permitting
new source discharges of pollutants that should be ter-
minated by 1985 anyway. This discharge is clearly not
in the public interest and should not be permitted.
The 13 million gallons a day, after 3 years
10 million gallons a day, withdrawal by Estech from
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the deep ground water system will further divert water f
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that normally seeps through the aquifer south and west
through Sarasota. This withdrawal may permit further
salt water intrusion into our groundwater.
The proposed rerouting of a portion of the East
Fork of the Manatee River will inevitably lead to de-
gradation of water quality, if permitted.
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The decline of water quality and quantity
from this proposed mining is inevitable and it will
exerts its effect upon all water consumers.
Time does not permit a detailed examination
of the economic impacts of this proposed facility.
Suffice it to say, it poses no positive benefit to
the area, region or nation. Carefully reviewed, it
can only be considered an economic negative.
Finally, it appears several parts of this EIS
may be faulty, and we cannot, until they are investigated
and proven to be correct, accept it as accurate.
In line with its responsibilities to protect
the public health, we ask EPA to select the no-action
alternative. To do otherwise, when sufficient evidence
exists to demonstrate the damaging effects of this in-
dustry as it is now operated, is abdicating that respon-
sibility .
Thank you.
(Applause)
MR. PERRY: Thank you, Mrs. Rains. I would ask
that, because of the highly technical nature of your
comments, that you might leave your telephone number
with the court reporter so that she could call.
MRS. RAINS: I omitted quite a lot.
MR. PERRY: I'd now like to recognize Archie Fernald.
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MR. FERNALD: I'm sure anything I was going
to say has been presented far better than I can pre-
sent it.
I do hope that Manatee County is in con-
cert with Sarasota and their statement.
MR. PERRY: Thank you, sir.
Now I'd like to recognize Mary P. Green (sic),
who is with Manatee Save Our Bay. Greer; excuse me.
MS. GREER: I really haven't much to say, but
I wanted to speak up for the senior citizens in this
area.
(Applause)
Many of the senior citizens of this county
came here to preserve their health and to prolong
their lives.
Many of us have respiratory distress and
emphysema. We need clean air and clear water to live.
Since we form a rather large percent of Manatee County's
population, we depend on our county environmental pro-
tection agency to take care of us and protect us.
Allergist specialist, Dr. R. Layne's studies
show a clear relationship between the rise and fall
of chemical pollution levels and hospital admissions.
National and state existing standards do not protect
these senior citizens but gauge their air quality
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standards on healthful young people.
Additional studies also show increases in
chemical pollutants, such as nitrogen oxide, sulphur
oxide and the radioactive gases called phosphate and
uranium release, harmful to respiratory health.
These released pollutant gases are known
carcinogens. A Florida Health and Rehabilitative
Service investigation showed the region of Borden
Chemical Plant to be a most infected area.
With the accumulated pollutants from three
more phosphate companies, we human beings will be
the next endangered species. We senior citizens are
depending upon public health and the EPA to protect
our lives, to protect our air and water quality in
Manatee County.
We hope you will refuse further pollutant
industries.
(Applause)
MR. PERRY: Thank you, Ms. Greer.
Mr. Gerald Stern indicated that he perhaps would
want to speak.
MR. STERN: No.. It's all been said and much
better than I could say it.
MR. PERRY: Thank you, then.
Mr. Archie E. Brumfield, Vice-president of M.S. French
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Company.
MR0 BRUMFELD: Mr. Perry, the Board, members
of this audience, I would like to thank you for this
opportunity to talk briefly on the subject, mainly for
the phosphate industry.
Over the past ten years the phosphate industry,
I know, has spent millions of dollars in protecting
the protection and improvement of the environment, not
only in Polk County; in Hillsborough County.
The state of the art in this industry is changing
continuously. Good old American ingenuity continues
to play a very important part in this pro'ect, in this
mining industry.
I know for a fact, and we've been very actively
involved in developing processes with Che phosphate
company in reducing and hopefully eliminating the
phosphate slime ponds, and I would like for you to con-
sider the fact of the amount of money and the amount
of time and the amount of effort that all these men
and women have spent in looking through all of the pro-
cesses, looking at all the problems and trying to find
resolutions for those.
Please don't look at Polk County as a repre-
sentative sample of what you may end up getting.
Personally, I live in Manatee County. I've been
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here for twenty years. I don't want to see our county
like that either, but I do hope that you give people
an opportunity to expand, not only the technology it
takes, but also the integrity of this country.
We are now being hamstringed by the oil indus-
try, and I don't want to see it done by the phosphate
people.
Thank you.
(Applause)
MR» PERRY: I'd now like to recognize Connie J.
Pounders.
MS. POUNDERS: I feel that the people who have
already spoken presented their facts very clearly.
MR. PERRY: You do not wish to speak, then?
All right.
Hilda E. Quy. Quy; excuse me.
MS. QUY: I'm Hilda Quy. I live in Bradenton.
I'm a member of the Izaak Walton League, Save Our Bays,
Sierra Club, Manasota-88.
Much of what I had planned to say fortunately
has been said by someone else, so I'm going to be rather
briefer than I would have been otherwise, and I think
it shows that many of us have the same concerns, and I
think you appreciate that.
I want to refer first to page two, Project History
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of the EIS: "Other local state and federal permit
applications are in various phases of development "
This should be corrected to show that the Manatee H
II
County Commission last August voted 4 to 1 to deny the
special exception applied for by Estech.
That decision was entirely within the authority
of the local legislative body. Many concerned local
citizens objected to the first application to mine in
our county because phosphate mining threatens our
environment, our health and our quality of life.
We objected to the second, the third and the
fourth applications, citing cumulative increasing dan-
gerous effects.
When Swift, the fourth company, applied, our
County Commission denied the permit, in our opinion
weighing the significance of the cumulative effect of
several mines.
Nowhere in the EIS do I find reference to this
cumulative factor. I ask you, the United States Environ-
mental Protection Agency, at what point you would be *"1
concerned with the cumulative effect of an industry that
you know to be hazardous?
Would it be the tenth mine or the one hundredth
or when a dragline has walked over every square inch of
vacant land in Manatee County?
I
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Our local governing body has said this far and
no farther. How can you, the Environmental Protection
Agency, do any less?
Second, I would like to question, as others «
ifl
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have, the objectivity of Conservation Consultants,
Incorporated, which has prepared part of this report.
This company is employed by Port Manatee, whose present
and potential profitability is closely linked to the
phosphate business for the port. The firm has a finan-
cial interest in increased phosphate business of the
port, creating a clear conflict of interest by partici-
pation in preparation of this EIS.
In addition, the firm's employer, the Port
Authority, is made up of our Countv Commissioners.
Estech is now involved in litigation with our County
Commission.
Conservation Consultants may be incapable of
recognizing a conflict of interests, but it is astonishing
that EPA has cooperated in such a violation of professional
ethics. In fact, without commenting any further, it
appears that holding a hearing at this time may well
<0
be a serious interference in the judicial process.
It's impossible in just a few short minutes
to deal with the substantive issues in this EIS. Many
of them have already been covered very competently by
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longer and technical presentations. I just want to
mention two or three things that struck me as I went
|i through the report.
First of all, as others have pointed out, the
most significant and courageous decisions of the area-
wide EIS study, were ignored. The last page of the
summary sheet states that the operation "will be
sufficient in terms of minor medical treatment,
water supply, fire and pollution protection."
Within the last two weeks, an explosion and
fire at the International Mining and Chemical Company
in Bradley Junction required fire fighting units from
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Bartow, Lakeland, Mulberry, New Wales, and four units
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from MacDill Air Force Base in Tampa. So much for
self-sufficiency. As usual, the taxpayer foots the
bill.
On page 23, under the no-action alternative,
we read, " a potential for positive impact on
the United States balance of payments would be lost
due to unrealized sale of the rock product "
Some others have referred to this. If this
simplistic argument is permitted in a supposedly serious
document, an unbiased statement, we must also add that
as 6 percent of the world's population, we are using
30 percent of the world's fossil fuels. Nearly half of it
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is imported.
Our unfavorable balance of trade is due to our
excessive use and importation of oil, and furthermore,
at our present rate of mining and exportation of phos-
phate, the United States will be dependent on imports
of fertilizer in as little as two decades.
Dr. Ellis Verink, Chairman of the University
of Florida Material Science and Engineering Department,
recently said, "Many indicators suggest that non-fuel
materials will represent the next national crisis for
the United States." An OPEC-type fertilizer cartel
can th£n us hostage as easily as we are held hos-
tage by oil producers today.
You cannot throw in a glib one-sided remark
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about balance of trade without some semblance of i
unbiased treatment of the issue.
On page 103 there are outlined various measures
to prevent the possibility of a settling area, other-
wise known as slime pond, failure and release of waste
clay to the Manatee River. These mention " designed
by an experienced professional engineer, thorough inves-
tigation of foundation and soil conditions, daily inspec-
tion by qualified representatives, annual inspection by
a Registered Professional Engineer," and so forth.
In February of 1972, June of '76, November of '77
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and October of this year, we have had serious dam
breaks. No doubt, in each case, the dam was designed
by a so-called Registered Professional Engineer who
surely would have said that the chance of failure was
nil.
On page 52 of the EIS we read, "Limitations
on use of the surface soils for construction of
homogeneous pond embankments are considered severe."
«
Who will be out there watching that none cC ?
these poor soils are used in slime pond embankments?
Registered Professional Engineers have been unable
to restore the Peace River since a slime pond break
killed it many years ago.
The truth is, dam safety in Florida is in
limbo. Responsibility is ambiguously shared among the
DER, Corps of Engineers and water districts with inspec-
tion meagerly funded.
These Estech slime ponds will contain vast
quantities of hazardous waste. The drinking water of
many thousands of people is at stake if a dam should
fail.
Jim Hunter referred to the definition of
wilderness. I don't think many dictionaries would
give you this.
Section 4.12, Biology and Ecology, if we have
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wilderness area, the wilderness area will consist of
spoil piles, which will be allowed to become revege-
tated by natural means. The vegetation of similar sites
throughout the central Florida phosphate district con-
sists of woodlands, which do not closely resemble any
indigenous plant communities in structure or species
compos it ion.
If you've seen Polk County, you know an under-
statement when you hear one.
Later we read, "The steepness of the slopes will
retard the establishment of more luxuriant vegetation.
This vegetation will have a low aesthetic value. The
angle of slope will cause continual erosion in wet
seasons
Before this I think even the author of the
document bled a little because he said this area,
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termed "wilderness" by the Applicant, will result in iL
permanent parallel rows of steeply-sloped island chains
in the northernmost created lake, and I think that's a '
very strange definition of wilderness.
From your million dollar area-wide study, you
in the Environmental Protection Agency know that the
phosphate industry poses serious dangers to the environ**
ment and to mankind. I read that you reported in June
that Florida phosphate mines pose radiation hazards to
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local residents that could increase risks of lung cancer
by as much as 50 percent.
You know that Florida has three times as much
chemical waste as any other state, much of it from
Polk County's phosphate industry.
It's hard to understand how you can complacently
give your stamp of approval to create more of the same
against the wishes of the people of Manatee County and
our own local government, and I ask you simply take
another look at your name, the Environmental Protection
Agency, and act accordingly.
By that, I mean deny the permits that are re-
quested by Estech.
Thank you.
(Applause)
MR. HAGAN: Can we get a copy of your written
statement?
MS. QUY: Yes, I can give you one. I'll have
to just cut out a few things, then.
MR„ PERRY: Thank you, ma'am.
MR, HAGAN: If you would, at your convenience,
between now and December 14th, just drop it in an
envelope and mail it to us.
MS. QUY: I can give it to you tonight. I'll
just make a few little corrections.
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Yes, I'll send it to you. That's the best thing.
MR. HAGAN: Thank you.
MR. PERRY: Mr. Joe Christy? I'm having a
hard time with the handwriting. I presume it's Joe
Christy. It says President of It looks like The
Granary.
A VOICE FROM THE AUDIENCE: He left.
MR. PERRY: Cara Johnson?
MS. JOHNSON: I don't have anything to say.
MR. PERRY: That concludes, I believe, all of
the people who have registered to speak.
Are there any other persons present tonight
who would like to make a statement?
(No response)
MR. PERRY: Are there any other comments from
the panel?
MR. BRYANT: I would just like to make a state-
ment, that contrary to apparently the public opinion
here, the Department of Environmental Regulation has not
made any decision on this, and it is under consideration
for certification.
We are in the process of reviewing the volumes
of the EIS ourselves, so we appreciate your comments
tonight.
I intend to get copies of the statements that were
359
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submitted and read those very carefully and thoroughly
and go back and review and look at the EIS in com-
parison to the comments that were made and make some
recommendations of our own to EPA.
And those recommendations will also be avail-
able to the public.
A VOICE FROM THE AUDIENCE: Sir, may I ask a
question? Are you going to address yourself to the
questions that were raised about the fact that this
is in litigation at the moment? Are you going to
consult your legal staff to see if you do have standing
at the moment to make any kind of decision while this is
in litigation?
MR, BRYANT: Yes, ma'am. Yes, ma'am. As far
as the State of Florida is concerned, I intend to
speak with our attorneys to see what our situation would
be in regard to ongoing local litigation in opposition
to this project.
A VOICE FROM THE AUDIENCE: Does the same hold
true for EPA?
MR. PERRY: EPA's counsel is here. We will con-
sider it, yes, ma'am.
Are there any other comments?
MR. HAGAN: I'd like to make just one general
comment, that as usual, I have been involved in several
97
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hearings, in several meetings, formal and informal, in
this area of Florida on several different issues, and
as always the response from the public sector tonight
has been an intelligent, reasonable, well thought-out
and extremely articulately presented response.
This is a Draft Environmental Impact State-
ment. The purpose for a draft is to engender dis-
cussion and to raise questions which are in the public's
concern and in the public's interest, and I would like
to thank and compliment all the speakers tonight for
having done that in a very excellent manner.
(Applause)
MR. PERRY: I would like to thank the State
of Florida for being here tonight, and also, most im-
portantly, I'd like to thank each and every one of
you on behalf of the State of Florida and EPA for
participating with us here tonight.
The comment period on the Draft Environmental
Impact Statement, as we've stated here, I think several
times, will remain open until December 14th, 1979. I
believe that's a Friday, and the comment period will
close at the close of business on that day.
This will allow anyone wishing to submit addi-
tional comments or written comments at the time to do
so. Further submission must be in writing to be included
361
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in the official record and should be sent to the atten-
tion of Mr. John E. Hagan, Chief of the EIS Branch,
EPA, Region IV, 345 Courtland Street Northeast, Atlanta,
Georgia, 30308,
EPA will take into consideration the elements
in the statements made here tonight and those that
are submitted and made a part of the record between
now and December 14th, and we'll undertake to make
a determination regarding the permit, NPDES permit,
based on these comments and other comments and materials
in the record.
After making that determination, we will then
inform all the persons who've come here tonight, as
well as those making additional comments, of our
determination. This will be a final determination of
the agency, and the agency decision respecting the
permit will be included in the final Environmental
Impact Statement for the Estech facility.
I wish to thank you again for appearing here
tonight. If there's no further business
Yes, sir?
A VOICE FROM THE AUDIENCE: I'd like to ask a
question. We came in, and we filled out a card, and I
ask that we be Whatever the EPA will mail us, how
much of what happened tonight are we going to receive copies
362
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Of?
MR. HAGAN: The process is that a verbatim
transcript, which is being kept by our court reporter,
is a part of the final Environmental Impact Statement,
along with EPA's responses to the issues that have been
raised, so the entire transcript of tonight's pro-
ceedings will be included in that document.
A VOICE FROM THE AUDIENCE: Thank you.
MR. PERRY: Are there any other matters?
If not, I think that the meeting is adjourned.
(Whereupon, at 9:55 p.m. the
hearing was concluded)
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CERTIFICATE
This is to certify that the attached proceedings
before THE ENVIRONMENTAL PROTECTION AGENCY, REGION IV
in the Matter of:
Draft Environmental Impact Statement Public
Hearing
Manatee Junior College
Bradenton, Florida
7:30 p.m.
November 28, 1979
were held as herein appears and that this is the
original transcript for the file of the Agency.
-oOo-
364
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RESPONSES TO TRANSCRIPT COMMENTS
Response T-l
See Response W-97
Response T-2
See Response W-1 7
Response T-3
See Response W-2
Response T-4
See Response W-9
Response T-5
See Response W-3
Response T-6
At the request of Sarasota County and as a result of an agreement
between Manatee County, Sarasota County, Estech General Chemical'
Corporation and the State of Florida Department of Community
Affairs, additional borings and attendant radiological analyses
have been performed. Please see Section - Supplemental
Analyses for a discussion of the results of this program and a
comparison of this latest effort with the results and conclusion:
of the Draft EIS.
Response W-7
See Response W-6
Response T-8
See Response W-7
Response T-9
See Response W-9
365
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Response T-10
See Response W-10
Response T-ll
See Response W-14
Response T-12
See Response W-1 5
Response T-13
See Response W-16
Response T-H
See Response W-17
Response T-15
See Response W-18
Response T-16
See Response W-20
Response T-17
See Response W-21
Response T-18
See Response W-22
Response T-19
See Response W-26
Response T-20
See Response W-27
Response T-21
See Response W-28
366
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Response W-22
See Response T-6
Response T-23
See Response W-125
Response T-24
See Response W-126
Response T-25
See Response W-130
Response T-26
See Response W-90
Response T-27
See Response W-130
Response T-2S
The proposed reclamation plan incorporates many innovative
procedures and methodologies not typically associated with past
mining operations. Preservation of wetland and upland biologica
corrmun it ies, a single above-ground clay wastes disposal area,
extensive water recircu1 ation and sand/clay mix disposal are
several features relatively unique to the mining industry and
represent the present state-of-the-art in reclamation and
disposal. For this reason, Estech's reclamation plan can not be
usefully compared to other plans by Estech or others.
Response T-29
Estech General Chemicals Corporation (Estech) is a wholly owned
subsidiary of Estech Incorporated. Approximately twelve percent
of the mining operation is owned by Japan investors who currently
receive product from Estech and are expected to continue to receive
product from the Duette Mine. The Japanese interest is the only
foreign investor in the Estech mining operation and is the only
foreign investor who wants to export phosphate.
367
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Response T-30
See Response W-117
Response T-31
See Response W-3
Response T-32
See Response W-38
Response T-33
See Response W-39
Response T-34
See Response W-40
Response T-35
See Response W-41
Response T-36
See Response W-^2
Response T-37
See Response W-43
Response T-3S
See Response W-44
Response T-39
See Response W-45
Response T-*fO
See Response W-49
Response T-41
See Response W-50
•tfO
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Response T-42
See Response W-51
Response T-43
See Response W-52
Response
See Response W-53
Response T-45
See Response W-54 &
Response T-^6
See Response W-56
Response T-47
See Response W-57
Response T-^8
See Response W-58
Response T-49
See Response W-59
Response T-50
See Response W-60
Response T-51
See Response W-61
Response T-52
See Response W-96
Response T-53
See Response W-63
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Response T-54
See Response W-64
Response T-55
See Response W-65
Response T-56
See Response W-67
Response T-57
See Response W-109
Response T-58
See Response W-110
Response W-59
See Response W-111
Response T-60
See Response W-112
Response T-61
See Response W-1H
Response T-62
See Response W-115
Response T-63
See Response W-116
Response T-64
See Response W-117
Response T-65
See Response W-118
370
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6.0 LIST OF PREPARERS
United States Environmental Protection Agency
A. Jean Tolman
Andrea E. Zimmer
Robert B. Howard
John E. Hagan, III
Char les P. A1bus
Ronald Rowland
Thomas R. Cavinder
A. Eugene Coker
Delbert B. Hicks
William L. Kruczynski
James E. Orban
Br ian Mitchel1
Roger Pfaff
Richard Payne
Joel G. Veater
Pr o j ec t Of f i cer
Previous Project Officer
Chief, EIS Preparation Se< tion
Chief, EIS Branch
NPDES Permit
NPDES Permit
Surface Water
Groundwater
Biology and Ecology
Biology and Ecology
No i se
Air
Air
Rad i at i on
Rad iat i on
Conservation Consultants, Inc.
William W. Hamilton
H. Clayton Robertson
Andre F. Clewell, Ph.D.
Richard M. Eckenrod, P.E.
Byron E. Nelson
John F. Schatmeyer, Ph.D., P.E.
Senior Project Manager
Assistant Project Manager
Biology and Ecology
Surface Water Quality
No i se
Ai r Qua 1i t y
Civil Engineering Consultants, Inc.
Robert J. Lombardo, P.E., I.T.E.
Transpor tat ion
Leggette, Brashears, & Graham, Inc
Frank H. Crum
Harry F. Oleson, 3r.
Groundwater
Groundwater
Planning/Marketing Services, Inc.
Dav id E. Wi 1k inson
Soc ioeconomi cs
371
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Zellars-Wi
Michael E. Zellars
Douglas E. Blows
Luther H. Bumgardner
W. H. Hawkins
Ronald R. Potts
James M. Williams, P.E.
Mickey R. Lee
John P. Bunch
iams, Inc.
Project Manager, Geology
Water Balance, Mining
Eng i neer i ng
Geology, Mining Engineering
So i 1 s
Water Discharge
Process Engineering
Geotechnical Engineer, Waste
Di sposa 1
Geologist, Waste Disposal
Consultants
Melvin W. Anderson, Pfr.D., P.E.
Errmett Bolch, Ph.D., P.E.
Roger T. Grange
J. Raymond Williams
Surface Water Hydrology
Radiat ion
Archaeological & Historical
Proper t ies
Archaeological 6c Historical
Proper t ies
372
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7.0 FINAL ENVIRONMENTAL IMPACT STATEMENT COORDINATION LIST
Copies of the Final Environmental Impact Statement are being sen
to the following Federal, State and local agencies, public
officials, organizations and interest groups.
Federal Agencies
Bureau of Outdoor Recreation
Bureau of Mines
Coast Guard
Corps of Engineers
Council on Environmental Quality
Department of Agriculture
Department of Commerce
Department of Health, Education
and Welfare
Department of
Department of
the Inter ior
Transpor tat i on
Energy Research and
Development Agency
Federal Highway
Admin i st rat ion
Fish and Wildlife Service
Food and Drug Administr< tion
Forest Service
Geological Survey
National Park Service
Nuclear Regulatory Conmn ssion
Economic Development
Admin i strat ion
Members of Congress
Honorable Lawton Chiles
United States Senate
Honorable Richard Stone
United States Senate
Honorable Sam Gibbons
U.S. House of Representatives
Honorable Andy P. Ireland
U.S. House of Representatives
Honorable Skip Bafalis
U.S. House of Representatives
State
Honorable D. Robert Graham
Govenor
Patrick K. Neal
State Senator
Department of Administration
Department of State
Environmental Regulation
Conrmi t tee
373
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Ralph H. Haben, Jr.
State Representative
Lawrence F. Shackleford
State Representative
Thomas E. Danson, Jr.
State Representative
Ted Ewing
State Representative
Coastal Coordinating Council
Department of Natural Resources
Department of Agriculture and
Consumer Services
Geological Survey
Game and Freshwater Fish
Corrmi s s i on
Department of Commerce
Department of Health and
Rehabilitative Services
Bureau of Intergovernmental
Re 1 at i on s
Department of Environmental
Regu1 at i on
Interest Groups
The Fertilizer Institute
Florida Phosphate Council
Florida Audubon Society
Florida Sierra Club
Manasota 88
League of Women Voters
Conservation Council of Manatee
Co u n t y
Tampa Audubon Society
Florida Department of the
Envi ronmen t
Izaak Walton League of
America Florida Divison
Florida Wildlife Federation
Local and Regional
Polk County Commission
Hillsborough County Commission
Manatee County Commission
DeSoto County Commission
Hardee County Commission
Charlotte County Commission
Sarasota County Commission
Tampa Bay Regional Planning Council
Sarasota County Health Dept.
Hillsborough County Dept.
of Environmental Protection
Manatee County Department of
Pollution Control
Sarasota County Environmental
Control Department
Southwest Florida Water
Management District
374
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8.0 APPENDICES
Pag-
8.1 Draft NPDES Permit A-1
8.2 PSD Permit Application - Preliminary Determination ... A-2
8.3 Supplemental Radiological Data A-3
375
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8.1 DRAFT NPDES PERMIT
A-l
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Permit No. FL003(609
frRAFr
^6 1 3
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Water Pollution Control Act, as
amended, (33 U.S.C. 1251 et. seq; the "Act),
Estech General Chemicals Corporation
(formerly Swift Agricultural Chemicals Corporation)
1st Commercial Bank Building
410 Cortez Road, West
Bradenton, Florida 33507
is authorized to discharge from a facility located at
Duette Mine
Between East and North Forks Manatee River
about latitude 27° 31' 09" & longitude 82° 07' 13"
Manatee County, Florida
to receiving waters named
East and North Forks of Manatee River
in accordance with effluent limitations, monitoring requirements and other
conditions set forth in Parts I, II and III hereof.
This permit shall become effective on
This permit and the authorization to discharge shall expire at midnight,
Date Signed
draft
ANSI 3 1980
Sanford W. Harvey, Jr.
Director
Enforcement Division
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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
1. "During the period beginning on the effective date and lasting through the term of this permit, the
permittee is authorized to discharge from outfall(s) serial numbers 001, 002 and 003 - process generated
wastewater and mine dewatering water.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Flow-m3/Day (MGD)
Total Suspended Solids
Total Phosphorous (as P)
Total Fluoride (as F)
Temperature (Winter)
Temperature (Summer)
Biochemical Oxygen
Demand (5-day)
Copper * (above background
concentration)
Oil & Grease
Specific Conductance
mhos/cm @ 25°C
Radium 226
Discharge Limitations
Daily Average Daily Maximum
30 mg/1
3.0 mg/1
5 mg/1
55° t 10°F
85° ± 10°F
2.9 mg/1
0.01 mg/1
5 mg/1
500 or less
60 mg/1
9.0 mg/1
10 mg/1
10 mg/1
0.03 mg/1
15 mg/1
1000 maximum
9 pCi/1
Monitoring Requirements
Measurement
Frequency
(During Discharge)
Continuous
1/week
1/week
1/week
1/week
1/week
1/week
1/week
1/week
1/week
1/month
Sample
Type
Recorder
24 Hr. Composite
24 Hr. Composite
24 Hr. Composite
Grab
Grab
24 Hr. Composite
24 Hr. Composite
24 Hr. Composite
24 Hr. Composite
24 Hr. Comoosit2
* See Page 3 of 12 - Definitions, 2(e)
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be
monitored 1/week during discharge with a grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
The effluent limits and any additional requirements specificed in the attached certification
supersede any less stringent effluent limits listed above. During any time period in which more
stringent state certification effluent limits are stayed or inoperable, the effluent limits listei
above shall be in effect and fully enforceable.
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Samples taken in compliance with the monitoring requirements specified above shall be taken at the
following locations: nearest accessible point after final treatment but prior to actual discharge
or mixing with the receiving stream. A single monitoring station located upstream of discharge
point 001 (diversion to Reservoir) shall be employed for sampling discharges 001 and 002. Separate
flow measurement capability shall be provided for discharges 001 and 002. A separate monitoring
station shall be provided for discharge point 003.
Any overflow from facilities designed, constructed, and maintained to contain or treat the volume
of wastewater which would result from a 10-year, 24-hour precipitation event shall not be subject
to the suspended solids effluent limitation or the pH limitations listed on the preceding page.
Monitoring and reporting shall be required for all the parameters including TSS and pH.
2. DEFINITIONS
(a) The term "mine dewatering" shall mean any water that is impounded or that collects in the mine
and is pumped, drained, or otherwise removed from the mine through the efforts of the mine
operator. However, if a mine is also used for the treatment of process generated wastewater,
discharges of commingled water from the mine shall be.deemed discharges of process generated
wastewater.
(b) The term "10-year, 24-hour precipitation event" shall mean the maximum 24-hour precipitation
event with a probable re-occurrence interval of once in 10 years. This information is available
in "Weather Bureau Technical Paper No. 40, May 1961 and may be obtained from the Environmental
Data Service, Nation Oceanic and Atmospheric Administration, U.S. Department of Commerce.
(c) The term "mine" shall mean an area of land, surface or underground, actively used for or
resulting from the extraction of a mineral from natural deposits.
(d) The term "process generated wastewater" shall mean any wastewater used in the slurry transport of
mined material, air emissions control, or processing exclusive of mining. The term shall also
include any other water which becomes comningled with such wastewater in a pit, pond, lagoon,
mine or other facility used for settling or treatment of such wastewater.
TJ T3
fl> 01
(e) For the purposes of this permit, background concentration shall be the greater of: h to
1) Copper concentration measured in groundwater withdrawn for facility use, or ^ L J i
2) Copper concentration measured in surface water reservoir at time the reservoir
rt
is initially filled by diversion from the East Fork Manatee River. This value ^
shall be determined before any discharge to Reservoir has occurred. " ^ 2
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PARTI f\UG S S
Pace 4 of 12
Permit No. FL0036609
B. SCHEDULE OF COMPLIANCE
1. The permittee shall achieve compliance with the effluent limitations specified for
discharges in accordance with the following schedule:
a. Permittee shall comply with the effluent limitations by
the effective date of the permit.
b. This permit shall be modified, or alternatively, revoked
and reissued, to comply with any applicable effluent
standard or limitation Issued or approved under sections
301(b)(2) (C), (D), (E), and (F), 304(b)(2), and 307(a)(2) of the
Clean Water Act, if the effluent standard or limitation
6o issued or approved:
(1) Contains different conditions or is
otherwise more stringent than any
effluent limitation in the permit; or
(2) Controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph
shall also contain any other requirements of the Act
then applicable.
2. No later than 14 calendar days following a date identified in the above schedule of
compliance, the permittee shall submit either a report of progress or, in the case of
specific actions being required by identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the cause of noncompliance,
any remedial actions taken, and the probability of meeting the next scheduled
requirement.
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PART I
Piifc 5 of 12
Permit No. FL0036609
DRAFT
C. MONITORING AND REPORTING
AUG 13 1980
1. Representative Sampling
Samples and measurements taken as required herein shall be representative of the volume
and nature of the monitored discharge.
2. Reporting
Monitoring results obtained during the previous 3 months shall be summarized for
each month and reported on a Discharge Monitoring Report Form (EPA No. 3320-1),
postmarked no later than the 28th day of the month following the completed reporting
period. Hie first report is due on . Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the Regional
Administrator and the State at the following addresses:
Environmental Protection Agency
Water Enforcement Branch
345 Courtland Street, N;E.
Atlanta, Georgia 30365
3. Definitions
a. The "daily average" discharge means the total discharge by weight during a calendar
month divided by the number of days in the month that the production or
commercial facility was operating. Where less than daily sampling is required by this
permit, the daily average discharge shall be determined by the summation of all the
measured daily discharges by weight divided by the number of days during the
calendar month when the measurements were made.
b. The "daily maximum" discharge means the total discharge by weight during any
calendar day.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to regulations published
pursuant to Section 304(g) of the Act, under which such procedures may be required.
5. Recording of Results
For each measurement or sample taken pursuant to the requirements of this permit, the
permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. The dates the analyses were performed;
c. The person(s) who performed the analyses;
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PARTI
Pago 6 of 12
Pcrmii No. FL0036609
d. The analytical techniques or methods used; and
e. The results of all required analyses. AUG 1 '•< 1980
6. Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s) designated herein more
frequently than required by this permit, using approved analytical methods as specified
above, the results of such monitoring shall be included in the calculation and reporting of
the values required in the Discharge Monitoring Report Form (EPA No. 3320-1). Such
increased frequency shall also be indicated.
7. Records Retention
All records and information resulting from the monitoring activities required by this
permit including all records of analyses performed and calibration and maintenance of
instrumentation and recordings from continuous monitOiirg instrumentation shall be
retained for a minimum of three (3) years, or longer if requested by the Regional
Administrator or the State water pollution control agency.
DRAFT
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PART II
Page 7 of 12
Permit No. FL0036609
A. MANAGEMENT REQUIREMENTS
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this
permit. The discharge of any pollutant identified in this permit more frequently than or
at a level in excess of that authorized shall constitute a violation of the permit. Any
anticipated facility expansions, production increases, or process modifications which will
result in new, different, or increased discharges of pollutants must be reported by
submission of a new NPDES application or, if such changes will not violate the effluent
limitations specified in this permit, by notice to the permit issuing authority of such
changes. Following such notice, the permit may be modified to specify and limit any
pollutants not previously limited.
2. Noncompliance Notification
If, for any reason, the permittee does not comply with or will be unable to comply with
any daily maximum effluent limitation specified in this permit, the permittee shall
provide the Regional Administrator and the State with the following information, in
writing, within five (5) days of .becoming aware of such condition:
a. A description of the discharge and cause of noncompliance; and
b. The period of noncompliance, including exact dates and times; or, if not corrected,
the anticipated time the noncompliance is expected to continue, and steps being
taken to reduce, eliminate and prevent recurrence of the noncomplying discharge.
3. Facilities Operation
The permittee shall at all times maintain in good working order and operate as efficiently
as possible all treatment or control facilities or systems installed or used by the permittee
to achieve compliance with the terms and conditions of this permit.
4. Adverse Impact
The permittee shall take all reasonable steps to minimize any adverse impact to navigable
waters resulting from noncompliance with any effluent limitations specified in this
permit, including such accelerated or additional monitoring as necessary to determine the
nature and impact of the noncomplying discharge.
5. Bypassing
Any diversion from or bypass of facilities necessary to maintain compliance with the
terms and conditions of this permit is prohibited, except (i) where unavoidable to prevent
loss of life or severe property damage, or (ii) where excessive storm drainage or runoff
would damage any facilities necessary for compliance with the effluent limitations and
prohibitions of this permit. The permittee shall promptly notify the Regional
Administrator and the State in writing of each such diversion or bypass.
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PART II
m i *
6. Removed Substances
Page 8 of 12
Permit No. JELD036609
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or
control of wastewaters shall be disposed of in a manner such as to prevent any pollutant
from such materials from entering navigable waters.
7. Power Failures
In order to maintain compliance with the effluent limitations and prohibitions of this
permit, the permittee shall either:
a. In accordance with the Schedule of Compliance contained in Part I, provide an
alternative power source sufficient to operate the wastewater control facilities;
or, if such alternative power source is not in existence, and no date for its implementation
appears in Part I,
b. Halt, reduce or otherwise control production and/or all discharges upon the
reduction, loss, or failure of the primary source of power to the wastewater control
facilities.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the head of the State water pollution control agency, the
Regional Administrator, and /or their authorized representatives, upon the presentation of
credentials:
a. To enter upon the permittee's premises where an effluent source is located or in
which any records are required to be kept under the terms and conditions of this
permit; and
b. At reasonable times to have access to and copy any records required to be kept under
the terms and conditions of this permit; to inspect any monitoring equipment or
monitoring method required in this permit; and to sample any discharge of pollutants.
2. Transfer of Ownersh ip or Con trol
In the event of any change in control or ownership of facilities from which the authorized
discharges emanate, the permittee shall notify the succeeding owner or controller of the
existence of this permit by letter, a copy of which shall be forwarded to the Regional
Administrator and the State water pollution control agency.
3. Availability of Reports
Except for data determined to be confidential under Section 308 of the Act, all reports
prepared in accordance with the terms of this permit shall be available for public
-------
DRAFT
AUG 1 3 1980
PART II
Page 9 of 12
Permit No. FL0036609
inspection at the offices of the State water pollution control agency and the Regional
Administrator. As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of
criminal penalties as provided for in Section 309 of the Act.
4. Permit Modification
After notice and opportunity for a hearing, this permit may be modified, suspended, or
revoked in whole or in part during its term for cause including, but not limited to, the
following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant
facte; or
c. A change in any condition that requires either a temporary or permanent reduction or
elimination of the authorized discharge.
5. Toxic Pollu tants
Notwithstanding Part II, B-4 above, if a toxic effluent standard or prohibition (including
any schedule of compliance specified in such effluent standard or prohibition) ?s
established under Section 307(a) of the Act for a toxic pollutant which is present in the
discharge and such standard or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit shall be revised or modified in accordance with the
toxic effluent standard or prohibition and the permittee so notified.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II, A-5) and "Power
Failures" (Part II, A-7), nothing in this permit shall be construed to relieve the permittee
from civil or criminal penalties for noncompliance.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties to which the
permittee is or may be subject under Section 311 of the Act.
8. State Laws
Nothing in this permit shall be construed to preclude the institution of any legal action or
relieve the permittee from any responsibilities, liabilities, or penalties established pursuant
to any applicable State law or regulation under authority preserved by Section 510 of the
Act.
-------
PART II
P«je 10 of 12
Permit No. FL0036609
9. Property Rights
The issuance of this permit does not convey any property rights in either real or persona]
property, or any exclusive privileges, nor does it authorize any injury to private property
or any invasion of personal rights, nor any infringement of Federal, State or local laws or
regulations.
10. Severability
The provisions of this permit are severable, and if any provision of this permit, or the
application of any provision of this permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the remainder of this permit,
¦hall not be affected thereby.
PART III
Definitions
1. The "daily average" concentration means the arithmetic average
(weighted by flow value) of all the daily determinations of con-
centration made during a calendar month. Daily determinations of
concentration made using a composite sample shall be the concentra-
tion of the composite sample. When grab samples are used, the
daily determination of concentration shall be the arithmetic
average (weighted by flow value) of all the sample collected during
that calendar day.
2. The "daily maximum" concentration means the daily determination of
concentration for any calendar day.
3. "Weighted by flow value" means the summation of each sample concen-
tration tiifces its respective flow in convenient units divided by ,
the summation of thf respective flows.
4. Composite Sample: A "24-hr. composite sample" is any of the following:
a. Kot less than six influent or effluent portions collected at
regular intervals over a period of 24 hours and composited in
proportion to flow.
b. Not less than six equal volume influent or effluent portions
collected over a period of 24 hours and composited in proportion
to the flow.
c. An Influent or effluent portion collected continuously over
a period of 24 hours at a rate proportional to the flow.
5. For the purpose of this permit, a calendar day is defined as any
consecutive 24-hour period.
DRAFT
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PART III
Page 11 of 12
Permit #FL0036609
draft
National Environmental Policy Act (NEPA) Requirements ^
The below listed requirements, conditions and limitations were recommended in
Estech General Chemicals Corporation Duette Mine site specific Environmental
Impact Statement, and are hereby incorporated into National Pollutant Dis-
charge Elimination System permit, No. FL0036609, in accordance with
40 CFR 1122.62(d)(9). (May 19, 1980)
1. Estech shall exclude the utilization of any conventional aboveground
slime-disposal areas with the exception of one 480-acre initial above-
ground clay storage area. Estech*s waste disposal and reclamation plan
shall employ a sand-clay mix process as described in the EIS. The 480-acre
aboveground settling area shall be inactivated and reclaimed a minimum of
one year before cessation of mining activities at the site.
2. Estech shall meet the requirements of its Southwest Florida Water Management
District (SWFWMD) Consumptive Use Permit.
3. Estech shall provide storage that allows recirculation of water recovered
from slimes. The water circulation system and storage capacity shall be
as described in the EIS for Estech's proposed activity.
4. Estech shall meet county and state reclamation requirements.
5. Estech shall preserve from mining,or any other disturbance, the 18-acre
cypress stand and the 50-acre stand of sand pine scrub as described in the
DEIS and shown on Figure 4.12-1 of that document.
6. Before beginning any land-disturbing activities, Estech shall contract with
a qualified individual approved by the Florida Endangered Species Coordinator
to recover eastern indigo snakes from the mine site for relocation to a
suitable area. The recovery and relocation efforts and schedule shall be
coordinated with the Florida Endangered Species Coordinator. Estech shall
also familiarize its employees who will work in the field with the
appearance of the snake and instruct them as to its preservation.
7. Estech shall comply with the categorization of wetlands present on the mine
property as set forth in the EIS and illustrated in Figure 6-1 of the DEIS.
In summary, within Category 1 wetlands, Estech shall not mine, shall limit
activities to those essential to and unavoidable for the mining operation,
and shall otherwise take all reasonable efforts to preserve all Category I
wetlands. Additionally, Estech shall restore all Category 2 wetlands in
accordance with Estech1s restoration plan in the EIS.
-------
PART III
Page 12 of 12
Permit #FL0036609
AUG 1 i 198ft
8. Estech shall preserve the Carruthers Mound from any mining or construction
disturbance. To insure its preservation, no buildings, roadways, pipelines,
excavations or ground disturbance shall occur within 400 feet of the mound.
Estech shall erect a clearly marked fence at a minimum radius of 400 feet
from the mound except on the southeastern quadrant which is protected by the
preservation of the river and floodplain. Following the .cessation of mining
and construction activities, Estech shall remove the fence. An additional
buffer outside the 400-foot radius shall be maintained within which no
mining will be undertaken. This area will be defined by the limits of
mining projected by the permittee as follows: 2,150 feet to the west of
the mound; 1,020 feet to the south of the mound; and, 620 feet to the north
of the mound. In the event the permittee's mining projections are revised,
the buffer may be adjusted upon concurrence by the Advisory Council on
Historic Places.
9. Estech will cooperate fully with the National Ocean Survey (NOS) in
protecting and/or in relocating any geodetic control survey monuments
determined to be located in the project area which may be disturbed by
Estech's operations at the project site. Estech shall provide NOS at least
ninety (90) days notice prior to the proposed relocation of any monument.
The funding required for protection and/or relocation of the monuments shall
be provided by Estech.
10. Unless specified otherwise by a preceding condition in this permit, Estech
shall carry out its Duette Mine project in accordance with the applicant's
proposal described and evaluated in the Estech EIS, including the employ-
ment of mitigating measures set forth in the EIS.
-------
8.2 PSD PERMIT APPLICATION - PRELIMINARY DETERMINATION
A-2
-------
APPLICATION PSD-FL-036
PRELIMINARY DETERMINATION
I. Applicant
Estech General Chemicals Corporation
410 Cortez Road West
Bradenton, Florida 33507
II. Location
The applicant proposes to construct rock mining facilities in the
town of Duette in Manatee County, Florida. Duette is located approxi-
mately 19 miles east of the town of Parrish, off highway 62. The various
facilities will be located at the following UTM coordinates: Boiler
389.18E and 3047.63N; Rock Dryers 388.95E and 3047.28N; Silos 388.72E
and 3047.32N; and product Loading Stations 388.73E and 3047.18N.
Ill. Project Description
The proposed source is a phosphate rock mine and associated process-
ing plant. Air pollution emitting facilities at this source include the
following:
• Boiler (3.99 MMBTU/hr)
• Two fluid bed dryers (£90 tons material input/hr each)
• Eight dry rock storage silos (3750 ton storage capacity)
• Two dry rock loading stations (200 ton bin capacity)
The applicant proposes to use a fuel oil fired 100 horsepower pack-
age boiler to generate steam for heating purposes. Heat is required to
maintain flotation reagents at proper temperatures for process use and
to preheat No. 6 fuel oil so that it can be pumped to the two phosphate
dryer oil burners. The boiler will be fired with low sulfur distillate
fuel having a nitrogen content of 0.4 percent and a sulfur content of 0.7
percent.
The two fluidized bed dryers will dry phosphate rock from about 13
to 2 percent moisture. (The dryers remove moisture by passing heated
air through the fluidized bed of rock). The air is heated by combustion
of fuel oil in the air stream directly before entering the fluidized bed.
Large size, heavy components of product exit the fluidized bed dryer to
a product conveyor and the lighter components are carried along with the
fluidizing air to product recovery cyclones which remove economically
-------
TABLE 1. EMISSIONS SUMMARY
FaciIi ties
POTENTIAL EMISSIONS
TC'IS ?CR vri?
ACTUAL EMISSIONS
to>|c jco vras
Fugi tive
Dust
Fugitive
TSP
TSP
so2
CO
HC
NOx
Fluoride
Fugi tive
Dust
Fugitive
TSP
TSP
so2
CO
HC
N0x
Fluoride
Package
Boiler
0.25a
-,2.4a
0.62b
0.12b
9.94c
—
—
—
0.25a
12.4a
0.62b
0.12b
2.73c
—
Phosphate
Rock
Dryers (Z)
-•
-
45,486d
904°
28.8e
5.76e
418c
<100
-
-
85.4C
32. Oc
28.8®
5.76e
264 f
0.15c
Ory Rock
Storage
--
--
10,028d
--
--
—
—
—
—
—
38.8f
«
—
--
--
—
dry Rock
Loadi ng
Station
--
--
4,095d
--
--
--
—
-
-
-
25.3f
-
--
-
-
—
Mining and
Sec'aination
43.lc
--
—
--
--
—
--
--
43.lc
~
—
—
--
--
—
--
Wet Phosphate
Rock Storage
Pi le
77. 2C
—
-
-
—
—
-
—
47.5C
-
—
-
--
-
—
TOTAL
43.1
77.2
59,609.3
916.4
29.42
5.88
427.94
<100
43.1
47.5
149.25
44.4
29.42
5.88
256.3
0.15
a. Calculated by applicant in the FDER construction permit application section of the PSD application.
b. Calculated by using emission factors given in Table 1.3-1 of AP-42.
c. Calculated by applicant in the 8ACT application section of the PSO application.
d. Calculated from data supplied by applicant in the FDER construction permit application section of the PSD application.
e. Listed by applicant in Air Quality Resource Document section of the PSD application.
f. Based an allowable emission limit and maximum allowable yearly hours of operation.
-------
recoverable product from the gas stream. Product recovered by the cyclones
is also discharged to the product conveyor. The remaining hot gas is clean-
ed in a wet scrubber and vented to the atmosphere.
The eight Dry Rock Storage Silos are designed to hold production out-
put for relatively short periods of time and supply product to the Dry
Rock Loading Stations on demand. The input rate is consistent with produc-
tion of the two phosphate rock dryers and the output rate designed for op-
timum and effective shipment of product. Fugitive emissions generated dur-
ing product transfer and silo loading are captured by hoods and collected
in a silo loading scrubber.
The two dry rock loading stations are each designed with a compart-
mented 100 ton loading bin. Each bin is designed to discharge through
eight spouts into the hatches of a 100 ton railroad hopper car. The bin
loading collection systems exhaust into a single wet scrubber serving
both loading bins. The rail car loading spouts are designed to enclose
the car hatch openings and include necessary air inflow and dust capture
features to prevent fugitive dust release during the car loading opera-
tions. A single wet scrubber is designed to serve both car loading dust
collection systems on an alternating basis.
Source Impact Analysis
The proposed construction has the potential to emit greater than 100
tons per year of TSP, S02 and N0X as shown in Table 1. Therefore, in ac-
cordance with the provisions of Federal Regulation 40 CFR 52.21 promul-
gated 19 June 1978, Prevention of Significant Deterioration (PSD) review
is required for these pollutants. It should be noted that the application
was reviewed under the Partial Stay of PSD Regulation, published February
5, 1980 and the proposed revisions of the PSD regulations referenced in
that partial stay. It was determined that the exemption outlined in the
partial stay does not apply and that the proposed source is subject to
review under existing PSD regulations because it has greater than 100 TPY
enforceable post-control TSP and NO emissions.
A
Full PSD Review includes an analysis of the following:
• air quality impacts (National Ambient Air Quality Standards
(NAAQS) and PSD increments),
• monitoring data,
• Best Available Control Technology (BACT),
-------
• growth impacts,
• visibility soils, and vegetation impacts,
• Class I area impacts.
However, the applicant proposes installing wet scrubbers, which will
reduce the actual SO2 emissions to a total of 44.4 tons per year (refer
to Table 1). Under 40 CFR 52.21 (k), major modifications with allowable
emissions less than 50 tons per year, 1000 pounds per day, or 50 pounds
per hour, as appropriate, are exempted from the requirement of NAAQS and
increment analyses, monitoring data, growth impact analysis and visibility,
soils and vegetation analyses, unless the allowable emissions from the
source would impact a Federal Class I area or an area in which the PSD
increments are known to be violated. Furthermore, under 40 CFR 52.21 (j),
no such source need apply BACT to get a PSD permit but must demonstrate
that the source meets all applicable emission limitations under SIP and
all applicable emission standards and standards of performance under 40
CFR part 60 and part 61. These, exemptions apply to emissions of SO2 only;
full PSD review is required for TSP and NO .
A
A. BACT Analysis
TSP
Total suspended particulate emissions are capable of being
generated from all of the facilities proposed for construction
(refer to Table 1), Since TSP emissions are greater than 100 tons
per year under 40 CFR 52.21 (j) these facilities are required to
apply best available control technology for TSP.
The applicant proposes to utilize two Ducon wet venturi-
absorber scrubbing systems to collect particulate and gaseous
pollutants from the phosphate rock dryers. Particulate emissions
from transfer points are proposed to be enclosed and eventually
vented to a dust collection system. The captured TSP emissions
from the dryers will be exhausted £0 a Centrifield wet scrubber.
The design outlet rate for the Ducon scrubbing system as in-
dicated by the supplier is 0.022 gr/DSCF. Based on an estimated
inlet concentration of 12.0 gr/DSCF this is equivalent to a col-
lection efficiency of 99.82 percent for the system. The design
outlet rate for the Centrifield scrubber is listed as 0.022
-------
gr/DSCF by the manufacturer of the control device. Based on an esti-
mated inlet grain loading of 7.8 gr/DSCF this is equivalent to a col-
lection efficiency of 99.71 percent for the Centrifield scrubber.
The total particulate emission from the phosphate rock dryers using
the aforementioned emission rates is estimated to be 22.93 Ib/hr or
85.4 tons/yr (refer to Table 1). This emission rate compares favor-
ably with the 0.U4 lb TSP per ton of material proposed New Source
Performance Standard for phosphate rock dryers. Using the above
emission rate, particulate emissions from the proposed phosphate
rock dryers for 590.3 tons/hr of material processed (wet basis) are
23.61 Ibs/hr.
Also proposed for Construction is a dry rock storage facility
consisting of eight storage silos with a storage capacity of 3,750
tons. The silos will be arranged in two bays of four silos each
centered over two enclosed reclaim belt conveyors which load the
rail car transfer stations. An enclosed dry product conveyor of
600 tons per hour capacity (from the rock dryers) will deliver dry
rock to a distribution chute and discharge to an enclosed reversible
conveyor belt. The reversible belt will supply either one of two
tripper conveyors which traverse the length of each bank of silos.
All transfer points in the loading system that lead to the tripper
conveyors are proposed to be enclosed and ventilated with exhaust hoods
to prevent TSP emissions. Silo discharge gates to the reclaim con-
veyors will also be enclosed with fugitive TSP collection hoods to
prevent escape of particulate matter at the base of the silos. All
active transfer points will be enclosed and ducted to scrubbers. A
schematic of the silo storage and reclaim fugitive dust control
system is given in Figure 1. The outlet grain loading for the
Centrifield scrubbers as listed by the manufacturer is 0.022 gr/
DSCF. The collection efficiency of the Centrifield scrubbers is
estimated to be greater than 99.7 percent. This is comparable to
the collection efficiencies for other control devices such as fabric
filters and centripetal vortex contact scrubbers.
The two dry rock loading stations at Duette Mine are proposed
to be installed with wet Centrifield scrubbers. Each dry rock
-------
-------
loading station consists of a coinpartmented 100 ton
washing bin on load cells as illustrated in Figure 2 . The bins
will be loaded with enclosed, variable speed conveyor belts through
hooded hoppers and a distribution chute system. Each bin will dis-
charge through eight spouts into the hatches of a 100 ton railroad
hopper car. Fugitive TSP emissions at all transfer points are
designed to be captured by collection systems. The captured
emissions are ducted to Centrifield wet scrubbers. The outlet
grain loading of the scrubbers is listed as 0.022 gr/DSCF by the
manufacturer. The collection efficiency of the scrubbers is esti-
mated to be 99.72 percent. This is comparable to the collection
efficiencies of 90.7 percent listed for alternative control devices
such as the fabric filter and the wet centripetal vortex contact
scrubber.
The oil fired package boiler will use distil ate fuel as a
means of limiting TSP emissions. The boiler TSP emissions are
estimated to be 0.057 Ib/hr or 0.25 tons per year. EPA agrees
that this rate meets BACT for TSP for the boiler and no additional
controls are required.
The applicant estimates that mining and reclamation activities
will disturb approximately 3 acres of land on any given day. How-
ever, since the material handled is in a relatively moist condition
at the time it undergoes active disturbance, a limited amount of
fugitive emissions will be generated* As the mining and reclama-
tion activities constantly move into new areas, disturbed ground
surfaces are left behind which contribute to fugitive dust emissions.
It is estimated that this would contribute up to 43.1 tons per year
of fugitive dust emissions. Control measures such as water spray-
ing in cases like these are not quite effective due to accessibility
problems of these areas by light vehicles and the subsequent gen-
eration of fugitive dust by these vehicles even if such spraying
is possible. A proposed long term measure suggested by the appli-
cant is the introduction of interim vegetative cover, i.e., grass,
as soon as practical after completion of activities which disturb
the ground surface. The new vegetation will encourage establish-
ment of more permanent natural grasses and plants and help to
~Verified by EPA-450/3-78-030 "Air Pollution Control Techniques For The
Phosphate Rock Industry." No fugitive emissions are anticipated from quarry
operations.
-------
-------
reduce emissions from these areas to levels approximating preconstruc-
tion conditions.
The storage piles at Duette Mine will be loaded with a movable
double wing stacker. The material loaded to the pile will essen-
tially be saturated with excess moisture. The inherent nature of
the storage materials is expected to contribute to an overall esti-
mated control efficiency of 38.4 percent. This estimate was based
on emission factors developed from the expanded methodology provided
in Table 2, Technical Guidance Document EPA 450/3-77-010. No ex-
ternal controls are projected to be required.
—X
The two primary sources of nitrogen oxide emissions are 1) the
Oil Fired Package Boiler and 2) the two phosphate rock dryers. Nitrogen
oxides generated by mobile sources such as haul trucks, etc., are
not subject to PSD review.
The control of nitrogen oxide emissions in boilers is generally
performed by combustion modification techniques. However, recently
some developmental work has been done on flue gas treatment tech-
niques. The applicant however proposes to utilize neither one of
the above techniques to reduce N0X emissions from the 3.99 MMBTU/ hr
package boiler but intends to rely solely upon the use of low nitro-
gen distillate fuel oil instead of residual fuel oil containing 0.4
percent nitrogen by weight. Estimates indicate the use of distillate
fuel oil will reduce NO emissions by as much as 72.5 percent over
A
emissions as calculated by AP-42 techniques from firing the residual
fuel oil originally proposed by the applicant.
The control technique proposed for the reduction of NO emis-
X
sions from the phosphate rock dryers is use of low nitrogen (0.3
percent nitrogen weight) Number 6 residual fuel oil and low N0X
burners. Also, some control of NO is expected when the dryer off-
gases pass through wet scrubbing devices that have been designed
for efficient removal of sulfur dioxide. Since no estimates are
available for reduction in NO emissions obtained by the latter
A
two techniques for phosphate rock dryers, a total of 32.6 percent
reduction in NO emissions was estimated by the applicant due to
X
-------
the use of low nitrogen fuel and an allowable NO limit of
0.32 Ib/MMHtu was proposed. EPA disagrees with the proposed BACT
for NO . The NSPS limit for industrial boilers firing liquid
A
fuels is 0.30 lb/NO /MMBtu. Fuel bound NO formation from the
A A
dryers will be minimized through use of low nitrogen fuel.
Further, dryers which require lower gas temperatures than boilers
need not have higher thermal NO formation than occurs in boilers.
A
Therefore, a well operated dryer should not emit greater NO than
A
an industrial boiler. Finally, no justification for a lower limit
for NO from rock dryers could be found and BACT for NO from the
A A
dryers is determined to be 0.3 1b/MMBTU. The combination low
nitrogen fuel- and low NO' burners are capable technology for
meeting the limit.
B. Increment Analysis
The applicant is required to demonstrate that the proposed source
does not cause or contribute to a violation of any maximum allowable
increments consistent with paragraph (1) of the PSD regulations. In-
crements have been defined for TSP and S02, however, allowable emis-
sions of S02 are less than 50 tons per year, 1000 pounds per day and
100 pounds per hour and no increment analysis is needed for SO2 con-
sistent with the exemption in paragraph (k) of the PSD regulations.
Therefore only the increment analysis for TSP is required.
The applicant used the EPA approved Air Quality Display Model
(AQDM) for evaluating long-term air quality effects contributed by
the proposed source. Meteorological input was represented by a five
year period measured at the Tampa National Weather Service (NWS)
Station. Modeling of the emissions from the proposed construction
was performed in conjunction with 33 other increment consuming
sources lasted in Table 2 . Annual air quality effect of increment
consuming spurces was determined for maximum allowable annual emis-
sion rates of all sources for comparison with the allowable annual
mean PSD increment of 19 micrograms per cubic meter (refer to Table 3).
-------
TABLE 2 . INTERACTIVE SOURCE LIST
1
Allowed
Operat
ional
Hours
UTM
Ht.
Diam.
Temp.
Flowrate
Particulates
Hours
Weeks
NEDS No.
Source Name
Coordinates
(ft)
(^)
°F
(ACFM)
(Ib/hr)
Day
Week
Year
1800-102-1
Borden - Rock Dryer
394.7
3069.6
100
4.0
210
. 90,000
42.32
24
5
52
1800-102-2
3orden -"Dry Rock Storage
394.7
3069.6
27
3.1
75
18,000
42.32
17.3
5
52
1800-102-3
Borden - Dry Rock Shipping
394.7
3069.6
26.5
1.1
70 '
18,000
50.44
5.8
5
52
1800-50-1
S.I. Lime - Bulk Terminal
362.9
3084.7
60
2.0
95
. 1,000
31.83
8
6
52
1800-8-44
Gardinier - Ammonia Phosphate
Plant
362.9
3082.5
80
3.0
130
20,000
16.2
22
7
52
1800-8-45
Gardinier - Vessel Loading
Facility
363.2
3082.3
3
2.3
72
16,000
40.0
24
1.5
52
1800-50-5
Chloride - Lead Oxide Transfer
System
361.8
3088.3
40
1.5
125
, 5,500
12.88
24
5
50
1800-50-6
Chloride - Lead Oxide Kettle
361.8
3088.3
40
1.5
125
5,438
12.88
24
5
50
1800-29-6
Nitram, Inc. - Prill Tower
No. 2
363.1
3089.0
200
22.6
90
150,000
27.28
16
7
50
3680-56-5
IMC Prairie - No. 4 Raymond
403.0
3087.0
65
2.0
140
• 6,300
19.2
24
5
52
3680-57-4
Conserv Chem. - Granulator.
398.4
3084.2
211
3.2
180
. 35,000
30.98
24
7
52
3680-57-4
Conserv Chem. - Dryer
398.4
3084.2
201
3.52
140
44,000
31.41
24
7
52
3680-57-4
Conserv.Chem. - Sizing
398.4
3084.2
172
2.5
150
16,000
31.35
24
7
52
3680-52-15
C.F. - Phosphate Rock
Unloader to Silos
408.2
3082.S
45.3
4.5
77
37,000
41.89
24
7
52
3680-55-23
Agrico - GTSP Production
407.9
3071 .C
) 140
9.0
107
156,000
49.6
22
7
52
-------
TABLE 2 . (Continued)
1
1 Allowed
1 Operational
Hour
UTM
Ht.
Dfam.
Temp.
Flowrate
Particulates
Hours
Days
Week
NEDS No.
Source Name
Coordinates
(ft)
(ft)
°F i
(ACFM)
(Ib/hr)
Day
Ueek
Yeat
3680-59-24
New Wales - Bag Collector AFI
Shipping
396.7
3079.4
120
8.0
125
110,000
40.41
24
7
48
3680-59-25
New Wales - Limestone Storage
396.7
3079.4
50
1.0
80 ;
4,000
33.33
24
7
48
3680-59-26
New Wales - Silica Storage
396.7
3079.4
18
1.0
77
. 1,500
14.99
24
7
52
3680-59-27
New Wales - Granulator Plant
for AFI
396.7
3079.4
172
8.0
120
130,000
36.8
24
7
48
3680-59-28
New Wales - AFI Silos
396.7
3079.4
116
1.0
77
1,600
36.2
24
7
52
3680-59-29
New Wales - Railroad & Truck
Shipping
396.7
3079.4
40
3.0
80
12,000
41.88
24
7
50
3680-59-30
New Wales - Soda Ash Unloading
396.7
3079.4
61
.66
77
1,500
16.76
8
7
50
3680-59-31
New Wales - Soda Ash Conveying
396.7.
3079.4
45
1.0
77
1,500
15.00
8
7
50
3680-59-32
New Wales - A Kiln Cooler
396.7
3079.4
87
1.5
325
i .30,000
15.00
24
50)
3680-59-33
New Wales - B Kiin Cooler
396.7
3079.4
87
1.5
325
30,000
15.00
24
7
50
3680-59-34
New Wales - Multifos Sizing
396.7
3079.4
17
1.25
225
10,000
23.00
24
7
5C
3680-59-35
New Wales - Multifos Class.
System
396.7
3079.4
57
1.25
175
6,000
18.44
24
7
5C
3680-59-36
New Wales - Dryer & 2 Kilns
396.7
3079.4
172 '
4.5
100
43,000
18.41
24
7
5(
3680-59-37
New Wales - DAP/MAP Loadout
396.7
3079.4
N/A
N/A-
80
18,500
38.6
24
7
52
3680-59-38
New Wales - AFI Storage and
Loading
396.7
3079.4
65
1.0
85
8,000
40.35
24
7
52
-------
TABLE 2 . (Continued)
Ht.
Allowed
Operational!
Hour
UTM
Diam.
Temp.
Flowrate
Particulates
Hours
Days
Week
NEDS No.
Source Name
Coordinates
(ft)
(ft)
°F
(ACFM)
(Ib/hr)
Day
Week
Yea
3680-50-3S
USS Agri-Chem. - DAP Facility
413.2
3006.3
133
7.0.
90
110,000
34.35
24
7
52
3680-50-39
USS Agri-Chem. - DAP/MAP
Storage & Loading
413.2
3086.3
74
2.0
80
3b,000
43.12
4
7
52
2540-29-1
Manatee Energy - Splitter
Boiler
346.6
3057.7
64
2.0
550
5,000
1.25
24
7
5C
2540-29-1
Manatee Energy - Splitter
Furnace
346.6
3057.7
^00
3.0
550
9,100
5.75
24
7
5C
1680-11-1
American Orange - Citrus
Peel Dehydrator
419.8
3047.3
34.5
10.0
185
27,000
10.12
24
6
2£
1680-11-2
American Orange Citrus
Pulp Dehydrator
419.8
3047.3
35.5
13.3
185
45,000
16.52
24
6
Zi
-------
TABLE 3. CLASS II INCREMENTS
Pollutant
Sulfur Dioxide
(S02)
Particulate Matter
(TSP).
Averaging Time
Annual Mean
24 - Hr.
3 - Hr.
Annual Mean
24 - Hr.
Maximum Allowable
Increases (Increments)
Mi crograms/Meter^
20
9ia
512®
19
37a
a The applicable maximum allowable increase may be exceeded during one such
period per year at any receptor site.
-------
The results indicated the annual effect of all increment con-
suming sources at the point of maximum impact to be 1.4 micrograms
per cubic meter, about 8 percent of the increment. Estimated annual
effects of the increment consumers at the property boundaries ranged
from 0.4 to 0.7 micrograms per cubic meter. Effect at the nearest
population groups - Keentown and Duette v/as 0.5 and 0.4 micrograms
per cubmic meter respectively.
Short-term air quality effects were computed from all allowable
source emission rates listed in Table 1 using the PTMTP-W computer
model and worst case (highest, second highest concentration) meteor-
ology. Worst case meteorology v/as determined from CRSTER computer
code analysis of five years of hourly meterological data. All major
upwind increment consuming sources or source groupings were included
in the model runs to identify maximum highest, second highest short-term
concentrations within the proposed source's impact area irrespective
of property boundaries and for two locations on property boundaries.
Short-term effects of all increment consuming sources at the
worst two points of highest , second highest concentrations were
found to be 12.9 and 9.8 micrograms per cubic meter. Increment
consumption was therefore 12.9 micrograms per cubic meter or 35
percent of the allowable 37 micrograms per cubic meter (refer to
Table 3) PSD increment at the point of maximum concentration. Increment
consumption at the worst two property boundary locations were found
to be 8.1 and 5.2 micrograms per cubic meter. Further analysis of
short-term increments considering source interaction is determined
to be unnecessary on the basis that the proposed source's impact
area is small (^5 kilometers) relative to the distance from other
sources (^20 kilometers) and no potential for serious interaction
exists. The analysis adequately demonstrates preservation of the
short term increments.
It must be noted that concentrations of particulate matter
attributable to the increase in emissions from construction and
other temporary activities were excluded from increment consump-
tion in accordance with paragraph (iii) of 40 CFR 52.21 (j).
-------
Further, fugitive T$P emissions from rock handling, etc. which do
consume increment were not considered in the modeling analysis
consistent with current Region IV policy. Region IV policy cur-
rently does not require modeling for fugitive TSP because of the
controversy over the accuracy of currently available fugitive
modeling techniques. In addition, fugitive dust emissions were
treated as not consuming increment in accordance with PSD regula-
tions.
C. NAAQS Analysis
The applicant must perform a NAAQS analysis to demonstrate
that emission of TSP and N0X do not threaten the NAAQS ceilings
for these pollutants. As explained previously the source is ex-
empt from air quality analysis of SOg emissions.
The NAAQS analysis is similar to the increment analysis dis-
cussed above. Ambient concentrations were determined for annual and 'J4
hour average conditions using the AQDM and a combination of CRSTER
PTMTP-W computer runs, respectively, for several locations of worst
effect. The grid spacing was 0.1 kilometers. The data presented
in Table 4 indicates that NAAQS for these pollutants will not be
violated as a result of the operation of the proposed facility.
This assessment was performed by combining the calculated air
quality levels contributed by the proposed source and surrounding
sources to existing background levels. The background levels for
TSP were obtained by measurement from six monitors located in the
general vicinity of the proposed project location.
D- Soils, Vegetation, Visibility
The applicant has stated that no adverse impacts on soils or
vegetation will result from the operation of the proposed new source
Any effect at all to the nearby agricultural lands, e.g., citrus,
grazing pasture, etc., is expected to be beneficial due to the nu-
tritive values of the phosphate and sulfur compounds contained in
the particulate matter emissions. Plumes from the stacks will con-
tain varying degrees of heated water vapor and will dissipate with-
in a relatively short distance from the stack. Although plumes are
aesthetically unattractive, in this case the landscape is not viewed
as characteristically scenic and therefore the plume is not expected
to detract from aesthetic values.
-------
TABLE 4. AMBIENT AIR STANDARDS COMPARED TO CALCULATED
CONCENTRATIONS AND BACKGROUND
Pol 1utant/Averagi ng
Time
Background
(ug/m3)
Maximum Calculated^
Concentrations
(jjg/m3)
Total
Concentrations
NAAQS
(ug/m3)
TSP
- 24 hr
110.4b
12.8
123.2
150
- annual
29.2a
1.2
30.4
60
no2
- annual
20 C
1.0
21.0
100
a Based on the measured highest annual geometric mean for 1977-1978.
b Based on the highest second highest 24-hr measurement for 1977-1978..
c Yearly maximum annual average concentrations measured 6 miles from the
source from 1974-1978 of 20 pg/m3 was utilized as a conservative
estimate of N02*
d Includes concentrations contributed by surrounding sources listed in
Table II.
-------
E. Growth Impacts
Vehicular travel on paved and unpaved roadways to and from the
proposed source is expected to cause fugitive dust emissions. It is
estimated that 325 employee vehicles and a smaller number of service
and delivery vehicles will be using the paved access road to the
plant. The construction work force during the construction period
will also contribute to vehicular fugitive dust emissions. Popula-
tion growth and commercial activities are not expected to develop
in the immediate area of the mine.
F. Class I Area Analysis
No Class I area is within a radius of 100 Km of the proposed
source. Tit'5 Chassahowitzka National Wilderness Area is located
approximately 130 Km to the north west of the proposed source. Ap-
proximately 200 Km to the south east is the Everglades National Park.
Considering the modeling results which indicated acceptable ambient
concentrations in the vicinity of the plant and the additional dis-
persion which will occur over this distance, no adverse impact on
these Class I areas is expected from the proposed construction.
V. Conclusions
EPA Region IV proposes a preliminary determination of approval for
construction of the phosphate rock mining facilities at Estech General
Chemicals Corporation's Duette Mine in Manatee County, Florida proposed
in their application received August 16, 1979. This approval is based
on the information provided in their application and additional informa-
tion received in correspondence dated August 21, 1979, January 22, 1980,
and March 10, 1980. The conditions set forth in the permit are as follows:
1. The proposed construction will be in accordance with the capacities
and specifications stated in the application. This specifically
includes:
a) Fluid bed phosphate rock dryers (2);
• Maximum capacity - 262 tons/hr each (dry basis) or 290
tons/hr each (wet basis)
t NO control technology - low NO burners
A X
• SO2 control technology - wet dual alkaline scrubbers/low sulfur fuel.
• Type of fuel used - Number 6 residual oil with nitrogen
and sulfur content not to exceed 0.3 and 1 percent by
weight, respectively.
-------
TABLE 5. ALLOWABLE EMISSION RATES
Facility
TSP
N0X
so2
Phosphate Rock Dryers (2)
22.93*1bs/hr and
71 Ib/hr and
8.60 1bs/hr and
0.098 1b/MMBTU
0.30 1b/MMBTU
.037 1b/MMBTU
heat input
heat input
heat input
Package Boiler
0.057 1bs/hr and
0.624 lb/hr and
2.82 lb/hr and
0.014 Ibs/MMBTU
0.16 1b/MMBTU
0.71 1b/MMBTU
heat input
heat input
heat input
Dry Rock Storage Silos
8.74 1bs/hr
Dry Rock Loading Station
5.77 1bs/hr
* Corresponds to 0.04 lb TSP/Ton of Phosphate Rock Feed (Wet Basis)
-------
b) Package boiler (1):
• Capacity - 100 HP
• Maximum heat input - 3.99 MMBTU/hr
• Type of fuel used - distillate oil with sulfur content
not to exceed 0.7 percent by weight, respectively.
2. The allowable emissions limits for emission sources of TSP, N0X
and SO2 are listed in Table 5.
3. Compliance with each allowable emissions limit listed in condition 2
will be determined by performance tests. Operation during these tests
will be within 10% of the rated maximum capacity. Tests will be con-
ducted with EPA standard methods and in accordance with the applicabl<
provisions of 40 CFR 60.8. Testing of emissions will be carried out
isokinetically with a minimum sampling volume of 30 dscf and a mini-
mum sampling time of 60 minutes for each run and three runs per test.
NOg grab samples will be obtained at 15 minute intervals.
4. The applicant is required to install, calihrate, maintain and operate
a continuous monitoring system, and record the output from the system,
for measuring the NO content of the flue gases from the phosphate
rock dryers.
5. The following measures will be complied with for fugitive TSP and
dust emissions:
a) Speed limit on unpaved roads is not to exceed 20 miles per
hour. In addition, unpaved roads are to be sprayed with water
and where practical and environmentally safe, watering should
be supplemented with dust suppressant chemicals.
b) Speed limit on paved roads is not to exceed 30 miles per hour.
c) Exposed areas due to mining and reclamation activities are to
be revegetated as soon as possible or within one year from the
time overburden is initially spread and graded.
d) The top surface tto a depth of 6 inches) of material storage
piles must be maintained at a moisture content of at least
13 percent.
6. The applicant will comply with the requirements and provisions of
the attached general conditions.
-------
7. The phosphate rock dryers will not operate greater than 7446
hours per year (365 day consecutive period) or in excess of
the capacity and fuel limits listed in condition 1. To show
compliance with these restrictions a log will be maintained
daily which indicates for each dryer cummulative hours of
operation for each preceding 365 day period and the time of
each unit startup and shutdown. Unit startup is defined as
the point at which combustion commences. In the dryer log ,
entries of startup times will be made prior to unit startup.
The log also will contain a record of sulfur and nitrogen
contents of all fuel oil fired in the dryers and the sulfur
content of the fuel oil fired in the package boiler.
-------
GENERAL CONDITIONS
1. The permittee shall notify the permitting authority in writing of
the beginning of construction of the permitted source within 30 days
of such action and the estimated date of start-up of operation.
2. The permittee shall notify the permitting authority in writing of
the actual start-up of the permitted source within 30 days of such
action and the estimated date of demonstration of compliance as
required in the specific conditions.
3. Each emission point for which an emission test method is established
in this permit shall be tested fn order to determine compliance with
the emission limitations contained herein within sixty (60) days of
achieving the maximum production rate, but in no event later than 180
days after initial start-up of the permitted source. The permittee
shall notify the permitting authority of the scheduled date of compliance
testing at least-thirty (30) days in advance of such test. Compliance
test results shall be submitted to the permitting authority within
forty-five (45) days after the complete testing. The permittee shall
provide (1) sampling ports adequate for test methods applicable to
such facility, (2) safe sampling platforms, (3) safe access to sampling
platforms, and (4) utilities for sampling and testing equipment.
4. The permittee shall retain records of all information resulting from
monitoring activities and information indicating operating parameters
as specified in the specific conditions of this permit for a minimum
of two C2) years from the date of recording.
5. If, for any reason, the permittee does not comply with or will not be
able to comply with the emission limitations specified in this permit,
the permittee shall provide the permitting authority with the following
information in writing within five (5) days of such conditions:
(a) description of noncomplying emission(s),
(b) cause of noncompliance,
(c) anticipated time the noncompliance is expected to continue or,
if corrected, the duration of the period of noncompliance,
(d) steps taken by the permittee to reduce and eliminate the
noncomplying emission,
and
(e) steps taken by the permittee to prevent recurrence of the
noncomplying emission.
Failure to provide the above information when appropriate shall constitute
a violation of the terms and conditions of this permit. Submittal of this
report does not constitute a waiver of the emission limitations contained
within this permit.
-------
6. Any change in the information submitted in the application regarding
facility emissions or changes in the quantity or quality of materials
processed that will result in new or increased emissions must be re-
ported to the permitting authority. If appropriate, modifications to
the permit may then be made by the permitting authority to reflect any
nrvcv.dry rliancjes in I he permit, conditions. In no case .ire any new or
increased emission!, allowed that will cause violation ol the emission
limitations specified herein.
7. In the event of any change in control or ownership of the source described
in the permit, the permittee shall notify the succeeding ov/ner of the
existence of this permit by letter and forward a copy of such letter to
the permitting authority.
8. The permittee shall allow representatives of the State environmental
control agency or representatives of the Environmental Protection Agency,
upon the the presentation of credentials:
(a) to enter upon the permittee's premises, or other.premises
under the control of the permittee, where an air pollutant
source is located or in which any records are required to
be kept under the terms and conditions of the permit;
(b) to have access to and copy at reasonable times any records
required to be kept under the terms and conditions of this
permit, or the Act;
(c) to inspect at reasonable times any monitoring equipment or
monitoring method required in.this permit; ~' ~
(d) to sample at reasonable times any emissionof pollutants;
and
(e) to perform at reasonable times an operation and maintenance
inspection of the permitted source.
9. All correspondence required to be submitted by this permit to the permitting
agency shall be mailed, to the:
Chief, Air Facilities Branch
Air and Hazardous Materials Division
U.S. Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
10. The conditions of this permit are severable, and if any provision of this
permit, or the application of any provision of this permit to any circum-
stance, is held invalid, the application of such provision to other
circumstances, and the remainder of this perniTt, shall not be affected
thereby.
The emission of any pollutant more frequently or at a level in excess of that
authorized by this permit shall constitute a violation of the terms and conditions
of this permit.
-------
8.3 SUPPLEMENTAL RADIOLOGICAL DATA
A-3
-------
May 6, 1980
MEMORANDUM
TO: J- Davis
FROM: R. Gonzalez
SUBJECT: Transmittal of Duette Radiological Data
Attached for your review and transmittal to Sarasota County.
RLG:ln
Enclosure
-------
STATE CF FTDRJEA
DIVT5ICN CF AOMIHISTRATIVE KEAXI.'GS
Cz . 3- «
—-
ESTTCH a^MICALS CORPORATION, •
foxrcrly SWItT AGRICULTURAL C-SUCALS
CORrCPATICN, * CASS ^ 79-1994
Petitioner, •
vs.
K*NAnx CCCNTlf, a political subdivision •
of the State of Florida, et &1.,
respondent.
ACRESgn1 CF THE PARTIES
At the request of Sarasota County, the parties signing be lew agree
they shall ccrxicct the following data collection progran -nich will prrrv: la
additional radiological data regarding Els tech's Eoette .Tina site.
Socoe of Program
1. TV«nty-sev
-------
The analysis shall include a weight, BPL, and radiun-226 analysis for all of
the corponents, including the natrix. A radium 225 ba-lar.oe shall te made
per the preceding flow sheet.
4. Subject to Dr. Lincer's concurrence, Estech shall select the
drillers, geologist, core washing lab, analytical lab, and other cm tract
personnel to expedite this program. A representative of Sarasota and/oc
Manatee County shall be given a reasonable opportunity to be present at,
and .iccutor, all phases of the program.
5. It is agreed that the cores will be split vertically down the
middle in the field. Cr,e half will be used as provided ir. paragraphs 1
through 4 fcr analysis and the other half will go to Manatee and/or
Sarasota Counties for quality assurance testing.
6. The partits shall pay for this program on a pro-rata basis i_o
to 510,000. Estech shall pay for all costs above $10,000 for the re.Tk3i--.cier
of the data collection and analysis prtxjri.-r. set forth ir. par:cr»phs 1
through 4.
7. This Aore
-------
EXHIBIT "A"
SECTiOW HOLE NUM3SS
15 H-3
15 C-10
• 16 0-15
IS F-U
17 F-2
17 E-ll
18 H-ll
7 £-6
7 tt-12
8 A-5
8 K-3
9 K-12
9 J-S
4 J-6
4 X-U
4 A-3
• 6 C-U
31 F-U
31 K-2
30 C-12
30 C-4
19 E-ll
19 ?-6
• 20 L-13"
21 A-5
21 F-13
18 F-U
The closest hole to each of the locations
identified Above, with matrix thickness
nearest to the average of the above
K tvcr.cy-scven (2?) oatrix thicknesses shall
be selected as the three (3) special drill
holes referred to in Piraijraph 3 of the
A*;rv-.*r,ent c*. the ."arti^s.
-------
DRILL HOLE LOCATIONS
AT EGCC DUETTE MINE
Section Hole #
15 H-3
15 C-10
16* 0-15
16 F-ll changed to J-8
17 F-2
17 E-ll
18 H-ll
7 E-6
7 M-12
8 A-5
8 K-8
9 K-12
9 J-5
A J-6
4 1-11
4 A-3
6* G-ll
31 F-ll
31 K-2
30 C-13
30 C-4
19 E-ll
19 P-6
20* L-13 changed to P-16
21 A-5
21- f-13 changed to C-15
18 F-ll changed to A-9
(Three samples for matrix and Ra226 balance)
* Closest hole to these locations, with matrix thickness closest to
the average of th'e above 27 matrix thicknesses shall be analyzed
for radiation balance.
Special Holes
E-ll Sec. 17
G-ll Sec. ; 6
F-13 Sec. 21 changed to C-15
Note: Co W€t field conditions, some hoi
(vlth Dr. Lincer's approval)
locati
ere changed
Richard
-------
ESTECH GENERAL CHEMICAL
CORE WASH PROCESSING DATA
-150 Mesh
Hole
Section
Z Dry Weight
Ra226 pCi/fim*
J-6
A
16.6
4 .78 +0.28
A-3
4
13.3
12.9 +0.6
K-12
9
31.9
2.97 +0.15
1-11
4
15.2
3.0 +0.24
J-5
9
21.6
14.0 +0.7
F-2
17
15.7
3.62 +0.18
K-8
8
14.2
11.27 40.56
E-6
7
22.4
7.9 +0.4
A-5
6
16.1
5.8 +0.5
H-ll
18
24.0
7.5 +0.4
M-12
7
22.9
8.6 +0.4
F-ll
31
27.4
3.49 +0.22
C-13
30
26.0
4.86 +0.60
G-4
30
22.5
12.79 +0.64
H-3
15
23.2
5.23+0.31
G-10
15
19.4
4.65 +0.44
E-ll
19
19.7
3.80 +0.29
J-8
16
18.6
11.4 +0.57
A-9
18
25.6
6.04 +0.30
K-2
31
32.0
3.56 +0.17
A-5
21
29.7
2.94 +0.28
P-16
20
18.5
5.88 +0.29
P-6
19
29.7
6.65 +0.33
0-15
16
24.0
4.91 +0.25
* Data supplied by S. A. I.
S - WILLIAMS. INC 4222 SOUTH *LOI«.OA AVINUI LAKCIANO FLO*,OA 3J.OJ - • 3.«,
-------
ESTECH GENERAL CHEMICAL
CORE WASH PROCESSING DATA
Hole
Section
Sample Description
Wt. 2
X BPL
Ra 226*
pCi/gra
E-ll
•
17
Matrix
•
100.0
12.99
4.99 +0.25
Concentrate Product
15.3
65.79
18.0 +0.9
Pebble Product
2.7
57.91
31.0 +1.5
Waste Pebble
0.5
52.98
21.4 +1.1
Tails
62.2
1.88
0.55 +0.28
Clays
19.3
7.74
3.47 +0.4 7
G-ll
6
Matrix
100.0
23.67
10.7 +0.5
Cdncentrate Product
16.0
66.77
23.4 +1.2
Pebble Product
7.0
59.69
29.7 +1.5
Waste Pebble
1.3
62.28
28.6 +1.4
Tails
57.1
1.56
0.48 40.08
Clays
18.5
20.39
10.0 +0.5
C-15
21
Matrix
100.0
21.58
7.04 +0.39*
Concentrate Product
19.1
67.14
21.9+1.1
Pebble Product
5.7
58.58
30.3 +1.5
Waste Pebble
2.A
45.66
23.1 +1.2
Tails
56.8
1.69
0.47 +0.04
Clays
16.0
17.45
6.84 +0.34
*Data supplied by S. A. I.
S ¦ WILLIAMS INC 4222 SOUTH FLORIDA AVCNUC. LAKELAND FLORIDA 31«09 ¦ •> >
-------
ZELLARS-WILL.IAMS. INC.
Geologists - Metallurgists - Enyinccrt
April 16, 1980
Dr. Jeff Llncer
Environmental Specialist
P. 0. Box 8
2002 Ringling Blvd.
Sarasota, FL 33577
Dear Dr. Lincer.
This letter documents transmittal of the matrix and slime samples
from our Estech 27 hole core washing program. From each hole you
have received one-half of the mineable matrix that was drilled
and logged in the field and one 5-gallon container of -150 mesh
clays from our core wash.processing. The matrix from six holes
was picked up by you on Friday, April 4. The remaining matrix
samples and all of the -150 mesh clay samples were picked up and
delivered to you by Delta Drilling and/or Eddie Baiter on April 9
and April 10.
A sample inventory of the Estech samples forwarded to you is
attached. A cross reference listing of our corresponding Zellars-
Williams, Inc. lab numbers is included for clarity. Please verify
this inventory and acknowledge receipt of these samples as shown
bfelow. Thank you very much for your cooperation.
Sincerely,
Zeliars-Williams, Inc.
J. M. Williams
Executive Vice President
JMW/kw
Attachment
I acknowledge that the above documen
received the forementioned Estech sai
<1IS SOUTH rLamm AU.UH.
-------
ESTECH
SAMPLES TO SAXASOTA COUNTY
SAMPLE INVENTORY
Zellars-Williams -150
Hole i Section Lab No. Matrix Mesh Clays
j-6 4 MM-1 X X
A-3 4 MM-2 X X
X-12 9 MM-3 X X
X_U k MM-4 X X
j_5 9 MM-5 X X
E—11 17 MM-6 X X
F-2 17 1 ' X X
k_8 8 MM-8 X X
e_6 7 MM-9 X X
a_5 8 MM-10 X X
H-Il 18 MM-11 X X
j>-\2 7 MM-12 X X
G_ll 6 MM-13 X. X
F_ll 31 MM-1 A X X
C-13 V MM-15 X X
C-4 30 MM-16 X X
H-3 15 KM-17 X X
G—10 15 MM-18 X X
C-15 21 MM-19 X X
E-ll 19 MM-20 X X
a
j_8 16 MM-21 X X
A_9 18 MM-22 X X
K-2 31 MM-2 3 X X
-------
Hole I
A-5
P-16
P-6
0-15
Section
21
20
19
16
Zellars-Wllllams
Lab No, •_ Matrix
MM-2A X
MM-25 X
MM-26 X
MM-27 X
-1! 0
Mesh ( 1 ays
X
X
I
-------
\
BOARD OF COMMISSIONERS
COUNTY OF SARASOTA
I l O I I 0 A
J.*''-
I
i?" 1
AMOMCW f ANDC6RIN • 0>ST«*CT I
ICVCHIV CLAV • DitlAICT ft
J*mC« O. NCVILLC • OlST««
rwoNC ftj/ses-iooo
APR 2 5 1930
April 23, 1980
Mr. J.M. Williams
Executive Vice President
Zellars-Williams, Inc.
4222 South Florida Avenue
Lakeland, Florida 33803
Dear Mr. Williams:
Thank you very much for your letter of April 16, 1980, concerning the transmittal
of matrix and slime samples from your Estech core washing program.
As per your request, I have verified the attached inventory and acknowledged
receipt of these samples by signing a copy of your cover letter to me. Please
note that the following changes were made on your sample inventory sheet:
1. Line 8, Hole 8F-2, your lab number has been changed from MM-6 to MM-7.
I believe this was simply a typo.
2, Line 16, Hole #C-13, I believe that hole was in Section 30 rather than
in Section 31.
I hope the above and the attached will help complete your records and encourage
you to advise me of any problems created by the above two changes. Thank you
very much for your prompt action on this.
Jeffrey
County Environmental Specialist
Sincere!
JLL/bml
Attachment
ccr Mr.-Dick Nelson, County Attorney
-------
ANALYSIS OF ESTECH CORE SAMPLES
FOR NATURAL RADIOACTIVE CONTENT
James E. Cline and Joanne Hollcroft
Science Applications, Inc.
Rockville, MO
SUMMARY:
Sixty six Estech core samples were analyzed for concentrations of uraniun,
radium, thorium and potassium. Techniques used in the analyses were tho
-------
1.0 BACKGROUND
Radioactivity exists normally in common soils, minerals, and sedimentary
deposits. The activity consists principally of the natural radioactive
decay chains that begin with the two isotopes of uranium, 235U and 238U,
ilA
the thorium isotope, Th, and an isotope of potassium, °K. The decay
of the uranium and thorium nuclides initiate chains of radioactive decays;
each nuclide, in the chain decays either through the emission of beta or
alpha particles. Gamma rays are often emitted following a beta decay. The
end product of each chain is a stable isotope of lead. Every nuclide in a
chain has a different half-life; most are very short (i.e., less than a few
hours) but all are shorter than the half-life of the initial chain parent.
Hence, if the material containing these nuclides is undisturbed for a long
period of time, each member of the decay chain is present and the material
is said to be in radioactive equilibrium.
The characteristics for the decay of every radioactive nuclide species are
unique to that nuclide. Measurements of the type and energies of the radiation
emitted in a decay generally permit a unique identification of the presence
of the specific nuclide in the sample. This quality has been likened to that
of a "fingerprint". In addition, a measurement of the quantity of the radi-
ation will give a quantitative assay for that radioactive nuclide in the
sample. Of the three principal types of radiation emitted in radioactive
decays, alpha, beta or gamma radiation, gamma radiation is generally the most
useful for assay purposes. Gamma rays, unlike beta or alpha particles, can
penetrate substantial thicknesses of material without severe loss in either
energy or intensity. Hence, measurements of the gamma radiation (gamn;a-ray
spectroscopy) can be used to assay bulk samples quantitatively for naturally
occurring activities as well as for artificially produced radioactivity. This
technique is called non-destructive assay (NDA) by gamma-ray spectroscopy.
The method for the quantitative assay of materials for uranium, thorium,
radium, and potassium was developed for the assay of ore samples; it was
developed for the U.S. Department of Energy (DOE), under contract with the
Bendix Field Engineering Corp. The techniques, detailed in Reference 1, use
238
the gamma-rays emitted by the shorter-lived members of the U decay chain
1. Development of New and Improved Data Reduction Techniques for Radiometric
Assay of Bulk Uranium Ore Samples. J. E. Cline, Science Applicat ions, Tnc.,
Unpublished report to Bendix Field Engineering Corp., Grand Junction, CO,
September 1977.
-------
(214Bi, 214Pb, and 234mPa); of the 235U decay chain (231Th and 231Pa); md
of the 232Th decay chain (228Ra, 227AC, 212Bi, 212Pb, and 208T1). Beca ;se
238
of the longer half-lives of some of the nuclides in the U chain
234 226
(principally U and Ra), radioactive equilibrium may not be realized
in this chain for samples that have been subjected to chemical separati )ns.
These separations may be deliberate or may occur through leaching by 1i quids.
The degree of equilibrium between uranium and radium, historically called
"dis-equil ibrium" in the field^of uranium mining, is given by the ratio of
the radioactive emission rate of uranium to that of radium. A value for
dis-equi1ibrium of unity signifies equilibrium, whereas a value greater than
one denotes the degree of the lack of an equilibrium. A lack of equilibrium
is important in the present context only in that it worsens the sensitivity
and accuracy of uranium assay; this is because most of the gamma rays knitted
238
in the U decay chain came from nuclides that follow radium in the chain.
ppc
Difficulties can also result from a lack of equilibrium between Ra and
222 222
its daughter, Rn. The nuclide Rn is an isotope of a noble gas and can
escape from a sample. This problem can be easily solved through proper
packaging of the sample and a delay of at least seven days between packaging
and analysis to allow re-establishment of the radioactive equilibrium.
Other facets of the technique involve corrections for attenuation of the
gamma rays in the bulk material of the source, the partitioning of the
235
principal gamma ray from the decay of U {unresolved in the measurements
2?6
from a gamma ray of Ra at a similar energy) into its components, and the
use of all observed gamma rays to obtain the best values for the assay. These?
aspects are described in Reference 1.
-------
2.0 MEASUREMENTS AND ANALYSES
2.1 Sample Preparation
Table 1 gives a list of samples analyzed in the present study. Zellar-
Williams, Inc. prepared the samples by drying, packaging in 4-inch diameter
by 2-inch thick plastic containers. When the amount of sample material was
not sufficient to fill the container, the sample was homogeneously mixed
with the necessary volume of sugar. The samples were then stored for at
least 10 days before analysis.
Standards
During 1976-77 SAI participated in a program with the Department of Energy
(DOE) to develop techniques for the analysis of uranium ore samples. Nine-
teen samples of standard material were prepared by DOE and distributed to
different laboratories for interlaboratory and intertechnique comparisons.
The results of these intercomparisons are given in Table 7 of the project
report. Sample 22683, containing uranium and thorium concentrations most
comparable to those of the present samples was used as a standard for the
present measurements.
An analysis of this standard during the series of core sample analyses
appears in the following table. It compares favorably with previous measure-
ments of the sample, thereby validating the accuracy of the core sample
analyses.
-------
rin?HHI7V_DF"TE^rrrTT?WTRHT'LE—ft e M O nx O V.G--4* 2 Z t -3
fiTTTmV t'OllFCTrnrfiTToTi uTjcTr T ft'fTiTv
RTH5TUH 13. 67910 071^8395 "
URflHIUH(;235.U> G. 82504 0. 41029
URRN I UH< 238-U> 39. 38416 10, 94291
THORIJJH . 12.19268 1. 25162
POTASSIUM 14. 68395" 1. 47834
"UIYEWITTBRIUH RJHTO : r~T2570l~ 0. 66259
URRNIUH
-------
TABLE 1
ESTECH CORE SAMPLES
RECEIVED FOR ANALYSIS
FROM ZELLAR-
¦WILLIAMS,
INC.
zwft
DESCRIPTION
HOLE
SECTION
PACKAGING
DATE
ANALYSIS
DATE
NET WEIGHT
(gm)
MM1
Matrix
J-6
4
4-3-80
4-30
402. 3
MMl
Clays
J-6
4
4-3-80
5-5
268.4
MM2
Matrix
A-3
4
4-3-80
4-30
420.9
MM2
Clays
A-3
4
4-8-80*
5-2
195.7*
MM3
Matrix
K-17
9
4-3-80
4-30
411.4
KM 3
Clays
K-12
9
4-3-80
4-30
238.2
MM 4
Matrix
1-11
4
4-3-80
5-5
490.4
MM 4
Clays
1-11
4
4-3-80
5-5
275.8
MM 5
Matrix
J-5
9
4-2-80
4-17
416.1
MM 5
Clays
J-5
9
4-3-80
4-17
291.2
MM6
Matrix
E-ll
17
4-3-80
5-1
334.0
MM6
+6M Pebble
E-ll
17
4-8-80
4-18
141.4*
KM6
+14M Pebble
E-ll
17
4-8-80
4-21
454.9
MM6
Final Cone.
E-ll
17
9-8-80
4-21
5 32.5
MM6
Comb. Tail
E-ll
17
4-8-80
4-22
464. 3
MM6
Clays
E-ll
17
4-8-80
4-21
226. 3
MM 7
Matrix
F-2
17
4-2-80
4-21
371. 3
MM7
Clays
F-2
17
4-8-80
4-22
270.0
MM8
Matrix
K-8
8
4-2-80*
4-28
389.8
MM 8
Clays
K-8
6
4-3-80
4-14
265. 3
MI-'. 9
Matrix
E-6
7
4-2-80
4-17
344.5
MM 9
Clays
E-6
7
4-3-80
4-18
229.0
MM10
Matrix
A-5
8
I
4-2-80
4-17
360.2
MM10
Clays
A-5
8
4-8-80
4-23
2 76.4
MMll
Matrix
H-ll
18
4-2-80
4-23
341
MMll
Clays
H-ll
18
4-8-80
4-23
244.6
MM12
Matrix
M-12
7
4-2-80
4-18
378. 9
mi 2
Clays
M-12
7
4-11-80
* repacked
4-23
261.1
* sugar adricc?
resealcd 4-14-80
-------
zwti
DESCRIPTION
HOLE
TABLE 1
SECTION
(continued)
PACKAGING
DATE
ANALYSIS
DATE
NET WEIGi
(gm)
MMl 3
Matrix
G-ll
6
4-2-80
4-21
351.6
MM13
+6M Pebble
G-ll
6
4-8-80
4-26
266.5*
MMl 3
+14M Pebble
G-ll
6
4-8-80
4-22
460. 3
MMl 3
Final Cone.
G-ll
6
4-8-80
4-30
527.0
MMl 3
•
Comb. Tail
G-ll
6
•
4-8-80
4-28
477.2
MMl 3
Clays
G-ll
6
4-8-80
4-28
261.8
MM 14
Matrix
F-ll
31
4-8-80
4-22
40 3. 3
MMl 4
Clays
F-ll
31
4-9-80
4-24
260.8
MM15
Matrix
C-13
30
4-8-80
4-23
35:3.9
MMlS
Clays
01.3
30
4-9-80
4-30
25 7.1
MM16
Matrix
G-4
30
4-8-80
4-24
395.2
MMl 6
Clays
G-4
30
4-9-80
4-24
25(->. 2
MM17
Matrix
H-3
15
4-8-80
5-2
37Si. 3
MM17
Clays
H-3
15
4-9-80
4-24
24.5.7
MMl 8
Matrix
G-10
15
4-8-80
4-29
340.2
MMl 8
Clays
G-10
15
4-9-80
4-29
290. 0
MM19
Matrix
C-15
21
4-9-80
5-2
4 2?. 6
MM19
+6M Pebble
C-15
21
4-9-80
4-29
399.8
MM19
+14M Pebble
C-15
21
4-9-80
4-29
4 38. 3
MM19
Final Cone.
C-15
21
4-9-80*
4-29
495.4
MM19
Comb. Tails
C-15
21
4-9-80
4-29
460.2
MM19
Clays
C-15
21
4-9-80
4-29
262 .6
MM20
Matrix
E-ll
19
4-9-80
4-28
375 .2
MM20
Clays
E-ll
19
4-9-80
4-24
26C .4
MM21
Matrix
J-8
16
4-9-80
5-5
447.0
MM21
Clays
J-8
16
4-9-80
5-2
257.2
MM22
Matrix
A-9
18
4-9-80
4-26
406.6
MM22
Clays
A-9
18
4-9-80
4-24
2 72.4
MM2 3
Matrix
K-2
31
4-10-80
4-28
372 . 8
MM2 3
Clays
K-2
31
0
00
1
0
1
4-28
25P. 7
MM24
Matrix
A-5
21
4-10-80
4-28
325.6
MM24
Clays
A-5
21
4-10-80
4-30
2 36.1
-------
TABLE 1 (continued)
zw#
DESCRIPTION
HOLE
SECTION
PACKAGING
DATE
ANALYSIS
DATE
NET WEI'
(gm)
MM25
Matrix
P-16
20
4-10-80
4-25
360.6
MM25
Clays
P-16
20
4-10-80
4-24
258.7
MM 2 6
Matrix
P-6
19
4-9-80
4-29
389.4
MM26
ClayS
P-6
19
4-11-80*
4-29
286.6
MM27
Matrix
0-15
16
4-9-80
4-29
410.6
MM27
Clays
0-15
16
4-10-80
4-26
277.4
Blank
Sugar
—
—
0
GO
1
H
V
4-21
257.9
-------
2.2 Measurement of Gamma Radiation
Measurement of the gamma radiation emitted by the samples used a 4096-cfannel
Ge(Li) gamma-ray pulse-height spectrometer. This device is a high-reso ution
gamma-ray spectrometer that is capable of quantitatively measuring the energy
spectrum of gamma rays emitted by a source. The basic spectrometer hardware,
although complicated, is commercially available and readily obtainable trom
several vendors.
A gamma-ray spectrum is an energy vs. intensity distribution of gamma-r
-------
2.3 Data Analysis
Analysis of the acquired pulse-height spectra to extract the assay results
consists of the following steps:
1. Location and identification of the full-energy peaks in the spectrum;
2. Calculation of the energy equivalent of the full-energy peak;
3. Identification, on the basis of gamma-ray energy, of the most probably
nuclide assignment for each gamma ray;
4. Determination of the net area of each full-energy peak (i.e., gross
area minus basfe-line area;
5. Calculation of radionuclide concentration from net area using
detection efficiency-energy calibration and absolute decay in-
tensities (from basic nuclear decay data); and
6. Calculation of best value for the concentration of each nuclide
through a weighted average of the determinations from all gamma
rays emitted in the decay of that nuclide.
These computations can be done by hand, but are most easily done using the
mini-computer associated with most gamma-ray spectrometers. Details of the
i
computations and the computer program used in the present measurements are
given in Reference 1. The calculations also partition the 186-keV transition
235
into the two components—that from the decay of U, and that from the
decay of ^Ra. Statistical uncertainties are propagated throughout all
the calculations.
A typical analysis result, in the form of the output from the analysis
computer, are given in Appendix A. The uncertainties given with the final
summary result only from the propagation of the statistical uncertainties
throughout all of the computations. They do not reflect uncertainties in
the accuracy of the detection efficiency determination (estimated at ±5%)
or in the basic nuclear data.
-------
3.0 Results and Discussion
Table 2 sumnarizes the results of the analyses of the samples for radium
uranium, thorium, and potassium, in terms of pico curies per gram. The
235 231
results obtained for all peaks of U as well as the results from Pa
OOfL
and Ra were checked and found to be consistent within statistical errors
for spectra of all samples.
The sugar had no discernable activity.
Comparison of radium content of samples counted 7 days after packaging ard
again 20 days later shows that the Ra 226 was in equilibrium with Rn 222
as seen in the table below:
RADIUM CONCENTRATION (picocuries per gm)
Sample
MM1 Matrix
MM1 Clay
MM4 Matrix
MM4 Clay
7 days
9.73±0.49
4.78+0.28
5.42±0.27
3.00±0.24
27 days
9.79±0.49
4.99±0.25
5.58±0.28
3.0U0.26
238
The 1001 KeV energy gamma ray used to identify U is a low intensity r?diation
n a « O O O
seen in only 0.6% of the disintegration of Pa, the U daughter. This with
238
the very low concentrations of U as encountered in the core sample, t\ e un-
238
certainty in the U analysis is large and its measurement is less reliable
than that of ^^Ra.
235
The ratio of uranium obtained from the U measurement to the uranium ecuivalent
??fi poo
obtained from the Ra - Rn spectra is tabulated as the disequilibriim ratio
%
in Table 2. Figure 1 displays distributions of disequilibrium ratios calculated
for the core sample analyses. When all of the data are reviewed, it is clear
that uranium-radium equilibrium exists in the core samples.
-------
TABLE 2
Sample
MM-
1 Matrix
1 Clays
2 Matrix
2 Clays
3 Matrix
3 Clays
4 Matrix
4 Clays
5 Matrix
5 Clays
6 Matrix
6+6M Pebble
6+14M Pebble
6 Final Cone.
6 Coinb. Tail
6 Clays
7 Matrix
7 Clays
8 Matrix
8 Clay
9 Matrix
9 Clay
10 Matrix
10 Clay
11 Matrix
11 Clay
12 Matrix
12 Clay
SUMMARY OF ANALYSIS RESULTS OF ESTECH CORE SAMPLES
Concentrations in Pico curies/gin ± 2a
Radium
(Ra226)
Uranium
(U235)
9.73+0.49
0.5110.22
5.00±0.25
0.36±0.03
11.1±0.5
0.51±0.06
12.9±0.6
0.61±0.07
10.4±0.5
0.5110.08
2.8410.14
0.3010.27
5.58±0.28
0.34±0.25
3.0 ±0.24
0.16±0.01
13.0±0. 7
1.07+1.69
14,0±0.7
0.74±0.04
4.99±0.25
0.24±0.03
21.4±1.1
1.02±0.12
3l.0±1.5
1.5210.21
18.0±0.9
1.2010.85
0.55±0.2 3
.0051.040
3.47±0.47
0.1810.31
4.69±0.23
0.5110.71
3.621"'. 18
0.25+0.08
9.05±0.45
0.4210.31
10.9±0.5
0.5710.09
4.9 ±0.3
0. 33±0.05
7.5210.37
0.37+0.23
8.6 ±0.4
0.49±0.37
5.8 ±0.5
0. 35±0.05
5.79±0.29
0.31±.10
6.3 ±0.35
0.28+0.05
8.5 ±0.4
0.42+0.02
8.6 ±0.4
0.47+0.11
Uranium
(U238)
Thorium
(Th2 32)
11.817.7
0.3310.07
11.513.2
0.5610.04
15.1±3.5
0.55+ .07
25.3±9.1
1.34+0.40
NS*
0.52+0.16
NS
0.4310.12
6. 36±5.33
0.27±0.06
6.9 ±4.7
0.56±0.25
15.916.9
0.4 1 .05
12.8±7.2
1.1 10.1
NS
0.4410.13
20.9117.4
2.1 ±2.7
41.4111.5
0.5 10.5
29.618.4
1.0 +0.3
2.6 ±2.5
0.1810.09
NS
0.7 ±0.3
NS
0.2510.04
6.3 ±3.0
0.56+0.08
NS
0.66+0.18
12.914.5
1.37±0.13
NS
0.50±0.26
17.5+4.0
0.90±0.35
NS
0.92±0.75
12.015.7
0.81±0.13
NS
0.39±0.09
19.6+9.1
O.71±0.20
15.713.1
0.27+0.12
14.313.9
0.6110.12
Potassium Disequili-
(K40)
brium Rat
3.5±0.8
1.1 ±0. 5
6.6±0.5
1.6+0.14
2.5±0.3
1.0+0.1
5.2+1.3
1.0±0.1
3.2+0.7
1.1+0.2
5.7±0.4
2 . 3 ±2 .1
1.8±0.6
1.3+1.0
3.9±0.7
1.2±0.5
0.5±0.8
1.8+2.9
5.3+0.9
1.1+0.1
5.0+0.8
1.1+0 .J
2.7+1-.6
1.0±0.1
1.3±1.0
1.1±0.1
1.5±0.8
1.5+1.0
4.3±0.5
0.2+1.6
7.7±1.1
1.1+2.0
3.1+0.8
2.4 + 3.3
6.0+0.5
1.5+0.5
2.4+0.9
l.OiO.8
8.6+0.5
1.1+0.2
5.7±0.9
1.5+0.2
6.5+0.6
1.1+0.7
2.2+0.8
1.2+0.9
6.8±0.9
1.3+0.2
2.8±0.7
1.2+0.4
2.8±1.2
1.0±0.1
1.6+0.3
1.1+0.1
5.3+0.5
1.2±0.3
* Not seen
-------
13 Matrix
13+6M Pebble
13+14MPebble
13 Final Cone.
13 Comb. Tail
13 Clays
14 Matrix
14 Clays
15 Matrix
15 Clays
16 Matrix
16 Clays
17 Matrix
17 Clays
18 Matrix
18 Clays
19 Matrix
19+6M Pebble
19+14M Pebble
19 Final Cone.
19 Comb. Tail
19 Clays
20 Matrix
20 Clays
21 Matrix
21 Clays
22 Matrix
22 Clays
23 Matrix
2 3 Clays
24 Matrix
24 Clays
25 Matrix
25 Clays
26 Matrix
26 Clays
27 Matrix
27 Clays
Sugar
10.7+0.5
0.5310.19
28.6±1.4
1.12+0.31
29.7+1.5
1.3510.17
23.411.2
1.19+0.33
0.4810.08
NS
10.010.5
0.65+0.11
4.48+P.22
0.2610.00
3.4910.22
0.29+0.16
6.4810.37
0.2210.08
4.1310.51
0.101 .08
7.8610.39
0.3310.10
12.79+0.64
0.75+0.53
6.7510.33
0.38+0.06
4.4510.19
0.2310.02
6.31+0.36
0.2210.12
3.9510.37
0.2710.01
7.0910.35
0.40+0.15
23.1±1.2
1.15+0.26
30.311.5
1. 3 3± 0.07
21.911.1
0.9510.45
0.4710.04
0.0410.02
6.8410.34
0.4210.07
6.2910.31
0.2910.01
3.23±0.29
0.1910.05
12. 7±0.6
0.69+0.11
11.4+0.6
0.6210.03
4.83+0.24
0.2910.08
5.1310.25
0.2310.27
6.63±0.33
0.24+0.09
3.03±0.14
0.1810.23
4.70+0.37
0.3010.09
2.9410.28
0.2410.17
10.2+0.5
0.5510.24
5.8810.29
0.4910.31
7.05+0.35
0.2910.07
5.37+0.27
0.2510.11
7.9110.39
0.3610.02
4.91+0.25
0.24+0.25
0. 31+0.55
0.0 10.0
TABLE 2 (continued)
9.6+3.8
0.39+0.11
36.9+12.3
0.19+0.18
36.0+11.6
0.2 3+0.14
16.3+9.9
0.9810.56
NS
0.12+0.03
15.0+8.5
0.9410.15
NS
0.3510.02
NS
0.4710.17
6.97+6.53
1.0210.95
NS
0.77+ .04
8.84+6.56
0.4710.30
NS
0.7610.29
9.3415.93
0.52+0.05
NS
0.6510.27
NS
0.4610.25
14.5+6.6
0.7510.19
11.7+6.0
0.50+0.04
40.7110.0
0.2010.12
35.9111.8
0.2810.15
29.719.9
0.7510.06
NS
0.1310.11
9.6815.03
0.78+0.17
NS
0.6210.44
10.915.2
0.5110.09
18.7+8.2
0.5610.18
15.914.4
0.94+0.17
NS
0.4410.39
7.69+5.39
0.6110.03
NS
0.68+0.23
NS
0.71+0.24
NS
0.4710.08
3.3813.18
0.5910.17
19.6+8.0
0.61+0.58
NS
0.7610.2 3
1.2615.7
0. 3410.10
7.7413.14
0.5710.07
10.9+6.5
0.4310.09
6.7512.97
0.58+0.08
NS
0. 59*0. 35
2.710.4
1.110.4
1.5+1.1
0.9+0.2
1.110.9
1.010.1
1.6+0.8
1.1+0.3
2.410.3
Not detormir.
8.711.2
1.4+0.3
4.310.8
1.3±0.4
5.110.9
1.8+1.0
2.3+0.8
0.7+0.3
5.9+1.2
0.6+0.4
2.510.7
0.9+0.3
6.5+1.1
1.3+0.9
3.1+0.8
1.2+0.2
5.311.2
1.1 + 0.1
3.711.1
0.8+0.4
7.0+1.1
1.5+0.2
3. 310.7
1.210.5
0.710.9
1.1+0.3
1.5+1.0
1.0+0.1
0.710.9
1.0+0.5
2.610.3
1.9+0.9
8.310.81
1. 310.2
2.5+1.0
1.0+0.1
4.010.8
1.1+0.3
2.110.7
1.2+0.8
4.010.5
1.2+0. 1
2.810.7
1.3+0.4
4.3+0.8
1.0*1.2
4.3+1.0
0. 8*0. 3
7.610.9
1. 3+1.7
4.6+0.8
L. 44 0 . 5
6.2+0.5
•f
00
3.2+0.9
1.210.5
7.710.9
1. 811. 2
3.210.7
o
•
o
b*
6.110.5
1.0+0. 5
2. 3+0.7
1.0+0.1
4.210.5
1.1+1.1
0.2*0. 3
Not dctermjtf
-------
FIGURE 1
DISTRIBUTION OF DISEQUILIBRIUM RATIOS
ALL SAMPLES
lO
>-
o
z
UJ
cr
UJ
ca
t
O
II
tf'Z
a?
\.o *-T.
RATIO
/.r
EL
to
CLAY
MATRIX
i
o{
a
¦t4—
i.d
—r~
Jt.o
a
1*0
RATIO
Ti n. n
•V 2.o
-------
APPENDIX A
Typical output from computer-assisted analyses of samples.
-------
' RUf< Jfl.'K'i:
flNFM. S'S IS DATE: APRIL 21 12:30 '80
HINIT? 8100 :1 8180•2 1
VETFCTOVr'T:
fFFICIENCV FILE NUMBER - 1
fFT lUlkHLV L'DHVt HHHk • 6451
sample log number.- S406
GTIE TTtT T7T P inifiTIFy-IT
TffiPE RECORD NUMBER; t: G
£ R 7fP rr73"(TirU^ff7T077TKRS^"~"15
lJUHBER OF SIGMA UNITS ON PEAK FIND- ^
t>7r*G-v-SE?T^rair™^
HjRCE I/O DLV1Ct Switch on remote position then tvpe cr
f,itflLVZER IS FREE TO ACQUIRE THE NEXT SPECTRUM
COUNTING RATES
CORRECTED
FOR BACKGROUND
* INDICATES MI
SSHAPED
OR
E }•> C E S SI V E L V
WIDE PEAK.
tOUNTIHG TIME:
8300
SECONDS
>• E A K
CHANNEL
ENERGV
COUNTS,'SEC.
GAMMA,'SEC.
X UNCERT.
NUCL_IDE_ fl_S_S I_GNI1ENJ S
—I~~
..... ; 3
35. 10
0. SIX?
bU/. bi
4. 06
2*
4 9. 44
38. 53
0. 84 2
94. 64
19. 16
TT'
* T9. ET
4b. UO
0. 343
16. 68
47. 2b" -
4
83. 0?
62. 9?
0. 1833
2?. 50
10. 04
—¦EH"
IUTT'4'5
~"7b.
1. U4/J
91. 62
2771"""
6
123. 39
92. 28
0. 4535
26. 74
4. 51
if'
¦ iyj. y/
14J. 33
U. lUbU
4. 2J
ib. 16
U-225,
8
201. 28
148. 90
0. 335
1. 34
49. 93
—0—
""Z0"7."7r
15T 6J~
0. 566
"7. "27 "
~~21T. 3T" "
- 7rfr-syrr
10
220. 41
162. 81
0. 422
1. 72
38. 61
U-235,
'IT""'
252707
T"8"57"~82~'
"077777
3478T" "
tw—
"'0 - 235 ,~RR- 2 2 S7
12
278. 42
204. 98
0. 313
1. 57
43. 98
U-235,
—329. lb
241. 86
b. 6316
35. 59
2. 42
RA-226/
14
352. 00
258. 47
0. 425
2. 52
27. 21
Kfl-226,
~i'5~
~T&T €2
2 £9. 83
0. 895
5. 50
12. 71
f'A-231,
ie
402. 43
295. 13
1. 5805
104. 43
1. 07
f-.' A - 2 2 6,
T7~
—mTTff
314. 73
0. 362
2. 52
24. 79
Pft-231,
18
441. 0?
323. 23
0. 286
2. 03
31. 68
T15~
445. *9
228. 55
0. 262
1. e9
33. 96
20
456. 44
334. 40
0. 322
2. 36
27. 44
-Ti
¦ 41T0. Tb
351. 8b
2. 602?
198. 49
0. 76
RA-226,
22*
530. 62
388. 33
0. 38?
3. 21
20. 96
R A - 2 2 6,
1. ^
bbb yy
48?. 45
0. i?2
1. 74
35. 23
26
699. 18
510. 89
0. 404
4. 21
15. 14
"27
772. 28 ~
564. 11
0. 116
1. 32
45. 45
28
795 80
581 14
0. 140
1. 64
39. 39
-------
v.9—
B~<4 52 "
609. 30
1.
8104
220. 04
0. 87
Rfl-226,
30
911. 57
665. 33
0.
528
6. 94
9. 95
Rfl-226,
31
55b. S3
698. 24
0.
102
1. 40
40. 46
32
963. 52
703. 10
0.
131
1. 81
34. 83
3T"*~
-S~95T*T~
726. 30
__ ^
82
1. lb
"4"§T'24"
TH™228:
34
1017. 42
742. 30
0,
138
2. 00
31. 63
33-
nrsr.TJT-
7bB.r9
0.
1657
24. 72
3. 79
Rfl-226,
36
1077. 32
785. 86
0.
371
5. 65
12. 41
Rfl-226,
if
1105. 22
t!(Jb. lb
u
355
5. 53
13. 03
Rfl-226,
38
1141. 04
832. 21
0.
116
1. 85
40. 98
Pfl-231,
TST"
"1T50". *T~~
839.02
0.
~1T5
2. 34
33. 48
40
1280. 86
93.3. 89
e.
925
16. 46
5. 76
Rfl-226,
4 L
OZi." 8 b
yti. /U ~
0.
122
2. 23
34. 94
42
1352. 38
985. 91
0.
99
1. 85
38. 68
4s
14/2. < 0
1UUU. by
0.
iU5
5. 79
13. 85
U - 2 3 8 <
4 4 *
1396. 78
1018. 21
0.
84
1. 62
46. 03
4y»r
"HF3V57"
~T0Br'Tr
0.
113
""""27T1 "
~3ff. 4 6"
46
1513. 47
1103. 09
0.
77
1. 60
47. 44
- 47
153b. BU
1120. 05
0.
JbJ9
7b. 54
2."i"3
" RA-226,
4 8*
1554. 83
1133. 17
0.
78
1. 67
45. 17
4y
15^4. «y
115b. U4
0.
411
B. 69
9. 9?
R fi - 2 2 b ,
50
1609. 60
1173. 01
0.
39
0. 85
91. 91
51™
~~t~b2T"?T"
n"80B "
" "07
- - "9 0-
"2". "00 "
38. 76 "
1 ~"""*"*•• —**
52
1647. 54
1200. 61
0.
87
1. 96
34. 72
" ' 5 T~
Tb'5b. "21
"T2Tjb79?"
0.
S3
"2. '0"i '
37. 69
54
1667. 17
1214.89
0.
78
1. 78
40. 79
55
1698. bl
123?:76
0.
1275
29. 44
4. 12
Rfl-226,
56
1718. 09
1251. 94
0.
77
1. 80
41. 40
57"
1757. 60
1280. 67
0.
339
8. 08
10. 84
Rfl-226,
56
1790. 24
1304. 42
0.
122
2. 95
24. 83
5T_
T6"2"57"SB"
il"30. 15
0.
94
2. 32
31. 56
60
1890. 44
1377. 31
0.
942
24. 04
4. 76
Rfl-226,
" bl
1^01. 21
1385. 15
0.
133
3. 42
24. 58
62
1923. 06
1401. 05
0.
255
6. 61
14. 22
—jErj.._
-T51T77?~~
1407. 72
0.
41?
12. 69
8. 23
Rfl-226,
64
2005. 01
1460. 67
0.
88
2. 37
37. 00
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——2024.2b
1T74. SB
0.
71
1. 94
40. 29
66*
2056. 88
1498. 41
0.
72
1. 98
41. 12
b/
20 71. 36
1508. 94
0.
406
11. 31
9. 7 7
Rfl-226,
08
2094. 22
1525. 58
0.
97
2. 73
29. 23
—£T9
"2T7rrrr
1583. 04
"0."
137
4. 00
1"9. 81
70
2188. 73
1594. 34
0
120
3. 54
21. 26
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"Zr?5: 85"
1599. 56
0.
7 0
2. 06
~ "T7:"b2—
72*
2246. 87
1636. 65
0.
43
1. 29
47. 85
f' 3
L" 2 U U. U1
lbbU. / <'
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2 5?
?. 55
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74
2291. 76
1669. 31
0.
42
1. 28
40. 94
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"2J21. 26
I"b92. 2'4~
0.
52
i. 6 3"
39. 5 6
76
2346. 50
1709. 15
0.
47
1. 47
31 30
77~
TJbT 7T5~
7L72IT727—
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" T5 "
i. Iff
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7B
2374. 06
1729. 20
0
573
18. 20
5. 60
Rfl-226,
7 9
2421. 9b
176 4. 08
0.
2842
91. 9b
2. 15
Rfl-226,
. 80*
2473. 58
1801. 63
0.
40
1. 31
31. 93
-~gr"
T~
"T8"3?'"BT~
-0;
86
2 90
20. 48
¦ — - ¦"
82
2536 02
1847.06
0.
317
10. 72
8. 70
-BT*~
T5"4B7'ir0~
"Tff5"6. 22
0.
34
1. 15
4 4". 8 9
84
2617. 82
1906. 60
0.
37
1. 28
39. 82
B5 ~
2658.07
1935. 89
0.
39
1. 39
37. 62
86
2819. 27
2053. 21
0.
31
1. 15
37. 31
b r
2B5'4. 61
2078. 94
0.
34
1. 28
26. 24
86
2e69. 69
2089. 91
0.
33
1. 24
32. 92
mmt •
-------
C9 TBFfT .""5 3~
"2102717"
0
3 0
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5*0 2908. 39
2118. 08
0.
188
7. 27
9. 25
Rft-226,
9 i * «: y t>«». y «
21by. LV
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0. 67
45. IB
92 2973. 91
2165. 78
0
26
1. 02
27. 32
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25. 47
4. 76
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94 3148. 82
2293.09
0.
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1. 89
23. 32
Rft-226,
-9-5 *~~ imrrs—2ii"B. wz
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0. 41
35. 36
.
96 2246. 25
2364. 02
0.
12
0. 52
31. 62
,v V J297. 90
2401. 63
6
7
0. 32
40. 82
98* 33 IP. 82
2416. 13
0.
11
0. 48
33. 33
• 5T(grff--&.r
"544?. 53
0.
228
10 19
7. 51
Rft~22lT,
K 100 3382. 69
2463. 35
0.
6
0. 27
44. 72
T&T*-T3FT'-
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7
0. 33
40. 82
J 0 2* 3444. 80
2508. 57
0.
6
0. 28
44. 72
lUi* 24 91.27
2542. 41
6.
7
0. 34
40. 82
L 104* 2509. 54
2555. 71
0.
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0. 22
50. 00
ICS 3 T." 90751"
6.
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2. 20
21. 56
TH--228,
, 1 0 6* 2691. 09
2687. 90
0.
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0. 53
33. 33
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"26327T2 '
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0. 59
31. 62
^ 108 3 702. 00
2695. 84
0.
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0. 41
37. 80
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2700. 21
G.
6
0. 30
44. 72
110* 3743. 00
2725. 70
0.
5
0. 24
50. 80
frrr"1775-;^-g-
~27'4"97'6"4
0.
7
0. 36
40. 82
k 112 3803. 78
2769. 96
0.
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0. 37
40. 82
riy*--3-8'i77W~
7779759
~B.
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0. 31
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114* 3846.59
2801. 13
0.
5
0. 25
50. 00
lib* ib'bi.'. bU
2812. 72"
u.
d
0. 25
50. 00
. 116* 3879. 58
2825. 16
0.
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0. 68
30. 15
ri7*"*79T
-------
i/ucrn>r
TME6V
"GfiMlTn/SE'C."
UNCERTAINTV
H IC R 0 C U RIE 5/C
(DECflV CORP.
) CO
U-235
143. 79
4. 23
16. 17
. 15716792E - 5
lbL'. yu " ~
l. rt
38. 60
.~2'5"6'2"0T5bI ""-5 ~
185. 90
13. 26
7. 19
.14708357E -5
205. UU "
1. Dt>
4 3. 98
. lb90b6i?E -5
PR-231
153.90
2. 27
29. 99
. 19024 009E -5
235. By
2 70. 09
5. 50
12. 70
.1634 7589E -5
314. 30
2 52
24. 78
. 41 ~-S '
4 ?7. 19
832. 00
1. 85
40. 98
.2824D840E -5
Rfl-226
186.00
21. 44
2. 50
.31076575E -4
241. uy
J5. 59
2. 42
.28345936E -4
258. 30
2. 52
27. 20
.18735019E -4
?S"577F
lF4. 4^
1. 0b
.31334680E -4
351. 90
198. 49
0. 75
.31034595E -4
388. ID
3. 20
20. 96
.27208187E -4 ~
609. 29
220. 03
0. 86
.30052920E -4
bbb. 20
6. 93
9. 95
.29436149E -4
768. 40
24. 71
3. 78
.30033961E -4
• ?D '
5T~r«r
12. 40
. 3 0 7 913 5 4 E -4
806. 20
5. 52
13. 03
. 26694425E -4
5TJC-0g-
lb. 46
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. 2085"?414E -4
1120. 30
76. 53
2. 13
.32250316E -4
115S. iU
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.31257561E -4
1238. 09
29. 44
4. 12
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l ZBI. TT9
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. J2"673S2iE -4 ~
1377. 80
24. 03
4. 76
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12. 69
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1509. 40
11. 30
9. 77
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i/;.'y. /y
IB. 20
t>. t>y
. 3b'4bb9bBb -4
1764. 50
91. 95
2. 15
.35021739E -4
1847". 60
10. 72
8. 69
. 30G45463E ""-4" '
2118. 69
7. 27
9. 24
.35703768E -4
2204. 10
26. 46
4. 76
. 32759870E -4
2293. 40
1. 89
23. 32
. 35103 35OE -4
244?. 69
10. 1$
7. 50
.39076670E -4
TH-228
238. 59
5bt~ nr
727. 20
1. 16
48. 23
. 98664199E -6
es'0750" "
2614. 60
2. 20
21. 56
. 36426 737E -£
1001. UU
5. 78
13. 84
.41438693E -4 ~~
K - 4 0
1460. 70
2. 36
36. 99
. 13148763E -5
-------
Summar v of "results from sample r Hh ^ 6>Lt:
_. A VALUE OF 1.0 INDICATES
— UfcfltUUM-ftftDIUH EQUILIBRIUM
-------
Sai/Z V UNITl I.) VI /\ I l:S LNVIKONMI N I AL. I'ROTECTION AGENCY
i* a o>
,—;/«
Wffto\licy A?t (NEPA) (Riblic law 91-190) apd
applicable EPA regulations at 40 CFR Fart 6.9. The Final EIS may be reviewed
at the following locations:
Lakeland Riblic Library, Lakeland, Florida
Bartow Riblic Library, Bartow, florida
Ausley Memorial Library, Wauchula, Florida
DeSoto County Riblic Library, Arcadia, Florida
Lee County Free Library, Ft. Myers, Florida
Sarasota Riblic Library, Sarasota, Florida
Manatee County Library System, Bradenton, Florida
Tampa-Hillsbo rough Cbunty Riblic Library System, Tampa, Florida
Punta Qorda Public Library, Punta Gorda, Florida
Manatee junior Cbllege Library, Bradenton, Florida
Central Florida Regional Planning Council Library, Bartow, Florida
Tanpa Bay Regional Planning Council, Tampa, Florida
Oonroents on the Final EIS may be submitted in writing tot
Ms. A. Jean Tolman
EIS Project Officer
Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30365
&
The comment period will remain open through October1980.
Sincerely yours,
>
Rebecca W. Hanmer
Regional Administrator
Enclosure
FEIS
------- |