S........ ... i ....
October 15, 1975
MEMORANDUM \ "
TO: Jim Mann, Director, Regulatory Division "
THRU: J. B. Butler, Deputy Executive Director for W.R.D&R, ? & R
C. H. Miller, Director, Resource Development Divis'on///!17
FROM: i"Bob Moresi, Technical Coordinator, R.D.D.
On April 10, 1974, the Governing Board held a public hearing relative to
the validity of the E-100 chloride and regulatory monitor well located in
the Cosme-Odessa well field. It was pointed out at that meeting that the
E-100 well was not a valid chloride monitor and the staff recommended that
E-100 be replaced by a well then designated as Grace #3. The Board accepted
the recommendation and stipulated by Order 74-2R that E-100 be altered or
replaced by April 1, 1975.
As of this date the staff has not even reviewed the plans of a corrective
procedure or replacement well; also it is not yet known if the Order was
officially cleared through Tallahassee, which would make the regulatory
well replacement legal. In effect, not only have we allowed St. Petersburg
to remain in violation since April without confronting them, we don't know
if E-100 has been officially replaced. Both these points could put the
District in a bad position at the public hearings to be held at the November
Governing Board. If any representative of the participating parties remembers
the April 1974 hearing, it would be brought out that St. Pete is in violation
and no official regulatory well or level exists in the Cosme Odessa Well Field.
Another potential problem is the validity of the E-100 series as chloride
monitors. At the 1974 hearing Mr. Moresi testified that E-100, along with
all other E-100 series wells, was not a valid chloride monitor and that
they should all be replaced or altered to create valid monitors. At the
October 8, i975, public hearing on the East Lake Road Well Field, data from
the E-100 series was introduced by the staff to indicate a trend of salt
water encrochment. The testimonies tend to be contradictory and if
Mr. Moresi would have been called to testify, the staff would have been
presented as inconsistent.
Clarification of the position and data presented should be seriously
considered for the November hearing in, order to prevent any confusion.
Attached is a memo from Bob Moresi to R. N. Cherry detailing the E-100
evaluation, and the minutes of the April 10, 1974 public hearing. They
may assist in your course of action. ,I wilT1-.bwkfTi'.li^^toi-a?'l T^1i:f,
CC: Jay T. Ahern
Terry D. Vandell
Attachments: As stated