Title: Letter enclosing Applications Correspondence for #200003.03
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 Material Information
Title: Letter enclosing Applications Correspondence for #200003.03
Alternate Title: Letter enclosing Applications Correspondence for #200003.03, 200004.02, and 203647.02
Physical Description: 8p.
Language: English
Publication Date: April 9, 1993
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
General Note: Box 2, Folder 5D ( COSME-ODESSA SFWMD - SWFWMD ), Item 124
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051283
Volume ID: VID00001
Source Institution: University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text




ET Southwest Florida


Water Management District
2379 Broad Street (U.S. 41 South) Brooksville, Florida 34609-6899
/ Phone (904) 796-7211 or 1-800-423-1476 SUNCOM 628-4150
GM T.D.D. No. only: 1-800-231-6103



Charles A. Black
Chairman, Crystal River
Roy G. Harrell, Jr.
Vice Chairman, St. Petersburg
Sally Thompson
Secretary, Tampa
Joe L. Davis, Jr.
Treasurer, Wauchula
Ramon F. Campol 9 1993
Brandon April 9, 1993
James L. Cox
Lakeland
Rebecca M. Eger
Sarasota Blain & Cone, P. A.
John T. Hamner 202 Madison Street
Bradenton
Curtis L. Law Tampa, FL 33602
Land O' Lakes
James E. Martin
St. Petersburg
Margaret W. Sistrunk Attention: Catherine Lamica
Odessa Legal Assistant
Peter G. Hubbell
Executive Director Re: Applications Correspondence # s 200003.02,
Mark D. Farrell
Assistant Executive Director 200004.02, and 203647.02
Edward B. Helvenston
General Counsel Dear Ms. Lamica:

Enclosed please find a copy of correspondence for above
referenced applications.

Sincerely,


Mary Toole
Senior Clerk
Processing & Records

MT

Enclosure: As stated












Excellence
Through \ "',
(Q quality '^ l '.
iServicc 4 *! I








ES Southwest Florida

Water Management District
2379 Broad Street (U.S. 41 South) Brooksville, Florida 34609-6899
Phone (904) 796-7211 or 1-800-423-1476 SUNCOM 628-4150
T.D.D. No. only: 1-800-231-6103 Southwest Florida
Water Man:- .' .
March 31, 1993

Charles A. Black APR 02 1993
Chairman, Crystal River Mr. Warren Hogg
Roy G. Harrell, Jr. West Coast Regional Water Supply Authority
Vice Chairman. St. Petersburg 2535 Landmark Drive BR00KSVILLE PER:TT
Soly Thompson Clearwater, Florida 33519 Brooksvlle ri":
Secretary. Tampa
Joe L. Davis. Jr. an
Treasurer, Wauchula a
Ramon F. Campo
Brandon Mr. William Johnson
James L. Cox Public Utilities Department Director
Lokeland City of St. Petersburg
RebeccaM. Eger 1635 3rd Avenue North
Sarosoto
JohnT. Hamner St. Petersburg, Florida 33713
Bradenton
Curtis L Low Subject: CLARIFICATION OF RECEIVED INFORMATION
Land O'Lkes WUP Appl. Nos. 200003.02, 200004.02, and 203647.02
St Petersburg County: Hillsborough and Pasco
Margaret W. Sistrunk
Odessa Reference: Chapter 40D-2.101, Florida Administrative Code
Chapter 40D-2.301, Florida Administrative Code
Peter G. Hubbell Chapter 40D-1. 603 (6), Florida Administrative Code
Executive Director
Mark D. Farrell
Assistant Executive Director Dear Sirs:
Edward B. Helvenston
GeneralCounsel The District has reviewed the Authority and City's responses to the
District's September 17, 1992 Request For Additional Information and
November 25, 1992 Request For Clarification Of Received Information
letters. Your application is still lacking the information necessary for
us to complete our review. The needed information is indicated below.

The March 1, 1993 submittal has been reviewed in its entirety and the
following questions regard the March 1, 1993 submittal. If any response
to the questions contained in this letter requires a reference to
previously submitted information, provide the date, page number, and
paragraph of the previously submitted information. However, the complete
answers to the questions contained within this letter should be contained
within your response to this letter.

LAW STUDY AND OTHER AUTHORITY TECHNICAL COMMITTEE WORK
The Applicants' March 1, 1993 responses to Question Nos. 9, 40 through
50, 56, and 57 of the District's September 17, 1992, Request for
A__ itional Information, and to Question Nos. 8b, Sc, 9, 10, and 26
Southwest Florida Wa er. through 29, of the District's November 25, 1992, Request for
Management Dis'rict Cl rification indicated that ongoing studies which are currently being
RECEIVED undertaken by Law Environmental, Inc., or Authority Technical Committees
(e 4g. the Authority's Environmental Mitigation Plan/Adverse Impacts
S0P 1993 q Co nmittee) will be used to provide appropriate and complete answers to
th1 above-referenced questions.

Therefore, the responses to these aforementioned questions remain
PROCESSING & RECOu^ inc complete. Please provide the following information.
Brooksville, Florida.
1. Provide four (one unbound) complete copies of the referenced Law
Environmental, Inc. studies, and supporting documentation. The
EXCellerCe supporting documentation should contain but not necessarily be
Through FILE OF RECORD
Quality D LE OF RECOR
Service PERMIT NO.









Mr. Hogg and Mr. Johnson South.... h:orCd
Page 2 of 7 Watr M' .-'*
March 31, 1993
limited to: APR 02 1993

A. All modeling documentation, including all model ng UOiKSVYlLE LPERMiTT;G i
both hard copy and computer disk) as well as t e put (on
B. All criteria and methodologies that have been developed and are proposed
to be implemented as part of the Wellfield Management Plan's strategy,
which will be used to avoid adverse environmental impacts related to
wellfield withdrawals. This should include, but not be limited to
environmental and hydrologic monitoring programs, impact analysis,
surface water drainage alteration effects, wetland assessment wetland
and lake mitigation, well production rotation and rehabilitation, and
any actions that the Applicants propose to undertake should adverse
impacts be detected.
C. Documentation and explanation of the magnitudeof drawdown and
environmental or ecological effects which are believed by the Applicants
to be due to groundwater withdrawals, versus any other factors (e.g.
surface drainage alterations, rainfall, and any other non-groundwater
withdrawal related parameters analyzed). This should clearly explain
and detail the magnitude of drawdown and environmental or ecological
effects that the Applicants attribute specifically to the Applicants'
roundwat withdrawals from these three t. PetesburgWellfields
versus non-groun udwaer related parameters. If drawdowns and effects are
attributed to any grossed undwater withdrawals other than the Applicants'
withdrawals proposed under these three St. Petersburg Wellfields, the
magnitude of the Applicants' drawdown and effects versus other
groundwater withdrawals shall be specified separately.
The details of how the magnitude of each effect was determined and
attributed to groundwater withdrawals versus non-groundwater related
parameters, and why these effects are believed to be due to each
parameter, shall be provided with the response.
D. Individual responses to Question Nos. 9, 40 through 50, 56, and 57 of
the District's September 17, 1992, Request for Additional Information
and to Question Nos. 8b, 8c, 9, 10, and 26 through 29, of the District's
November 25, 1992, Request for Clarification. The Applicants, March 1,
1993 submittal had deferred final responses to these questions to allow





District reserves the right to view the video logs and obtain copies



Request For Clarification Of Received Information.
G. With regard to the response to Question th itricts
September 17, 1992 Request For Additional Inform0aton, the District will
require that the District-ge enen sta ted n sftu oro their leeluthr
drawdown contour be provided on the ecApomplated Area a w.ter le
incorporating the DistriGct'generated Iwetlad data ic s





.-Oa





Mr. Hogg and Mr. Johnson
Page 3 of 7
March 31, 1993 APR 02 1993

INACCURATE FLOW METER/PUMPAGE DATA
According to affirmations from the Applicants, the Co-permittees h a" eTre e
pumpage to the District by as much as 3.1 to 6.4 million gallon per BaytKor, s ieral
years due to flow metering discrepancies. The actions required by ne Compliance
Notices issued by the District to the Permittees on February 10, 1993 must be
completed and accepted by the District before processing of the permit applications
can continue. The Compliance Notice items requiring actions directly related to
correction of historic data and collection of accurate future data are included
below. This list should not be construed to supersede or replace any of the
specific requirements of the Compliance Notices. The District suggests that the
following items be completed under the requirements of the Compliance Notices, prior
to submittal as a part of this clarification request.

2. Under a District-approved testing and data-correction program, directly and
accurately measure flow for each well within the wellfields and each master
meter identified in the diagram attached to the Compliance Notices (Identified
as Nos. 1-7). Compare this measured flow to the flow provided by the meters.
Determine the magnitude of error for each meter, and develop a coefficient
that will correct past data inaccuracies and ensure correct future data
submission. All proposed testing and corrections shall require a written
proposal to, and approval of the Director, Tampa Permitting Department prior
to implementation. The proposal shall include the results of an investigation
of methodologies to correct previous pumpage data taking into account the
deterioration of meter accuracy over time.

3. Based on the data collected through the District-approved testing and data-
correction program of Item 2 above, provide corrected historical data to the
District for each well, master meter, and each wellfield as a whole. At a
minimum, corrections shall be made to all pumpage data reported for 1961 to
the present (period of record for South Pasco Wellfield). The corrected data
shall be provided on hard copy and electronic media, and be accompanied by a
report documenting in detail how the data was corrected. The document which
provides the corrected data and correction methodologies shall be signed and
sealed by a licensed Professional Engineer registered in the State of Florida,
who has the expertise to undertake such work.

4. Identify when all meters were installed, replaced, and when any meters were
calibrated.

5. Provide plans, procedures and methodologies that the Co-permittees will follow
to ensure that accurate data will be submitted in the future. Include a
proposed calibration schedule for each well meter and master meter to verify
that flow reporting accuracy will be maintained in the future. These items
shall require the approval of the Director, Tampa Permitting Department.

6. Accelerate installation of accurate meters on each well within each wellfield
and a master meter for each wellfield. This action should not precede the
activities listed in Item 2 above. Within 30 days, provide a schedule for
accelerated meter installation and plans to ensure that meters will provide
accurate data under installed conditions. These items shall require the
approval of the Director, Tampa Permitting Department.

7. For the period of record, provide the details of how quantities submitted to
the District for each well and each wellfield as a whole were derived to date.

8. Provide a proposal to correct the technical metering limitations imposed by
the "archaic" wells and distribution system at the Cosme-Odessa Wellfield, for
the approval of the Director, Tampa Permitting Department. The proposal shall
ensure that meters within the wellfield will have and maintain an accuracy
within five percent of actual flow as installed.







Sutibtv Fr:;.L
Wa" A,:

Mr. Hogg and Mr. Johnson
Page 4 of 7 APR 02 1993
March 31, 1993

9. For 1987 through 1992, provide a comparison of the t ta~,( pa y r tign y o
water sold to all water users, as summed from a 1 whc esle an- retail
customer meters, including retail residential cust mx- ,, 4
total quantity of water distributed from the Cosme Water Treatment Plant (as
measured at the plant effluent meters), and any other treatment and
distribution facilities which will allow the total quantity of water sold by
St. Petersburg to be accounted for.

This comparison should utilize quantities which reflect the corrected meter
data derived from the meter testing program. Identify which meters were used
to quantify the use, the last time calibration was undertaken on the meters,
and the last time the meters were changed out. For all meters, describe what
type of calibration was undertaken and explain the procedure used for
calibration. A general description of the calibration and change out program
will suffice for the individual residential meters. Detail and justify any
adjustments or "corrections" made to the data.

PROPERTY AND WELL LOCATIONS
Several administrative items relating to property boundaries and well locations
still need to be clarified. The following questions regard these items.

10. The 1992 aerial map provided does not show the correct property boundaries of
the Cosme-Odessa Wellfield. Specifically, the larger portion of property in
the area of Section 27. Please provide a clear 1992 aerial photograph (as
previously submitted) showing the correct property boundaries of the Cosme-
Odessa Wellfield. The map must be consistent with the County folio records
for ownership, and must be consistent with and accurately reflect the legal
description of owned or controlled lands associated with the wellfield. Refer
to the property boundaries as depicted in the Authority's revised site
sketches submitted March 1, 1993.

11. During the field visit to the Cosme-Odessa Wellfield, District staff noted
other small diameter wells existing which were not listed on the well summary
submitted March 1, 1993. Wells other than those identified were noted to be
located in the vicinity of production wells CO-31, CO-23 and at ID. Please
provide the information for these wells on a revised summary table showing all
existing small diameter wells at the Cosme-Odessa Wellfield.

12. Show the locations of the small diameter wells identified in Item 11 above on
the revised 1992 aerial map to be submitted for the Cosme-Odessa Wellfield.
It was also noted that none of the small diameter wells are shown on the site
sketches. Please revise the site sketches to show the well locations of all
small diameter wells.

13. At the March 3, 1993 field meeting for discussion of the meter testing
program, the accuracy of the property boundaries for the Cosme-Odessa
wellfield wells located along the railroad right-of-way corridor was brought
into question. This event combined with the inaccuracies of the previously
submitted property boundaries, calls into question the accuracy of the
property boundaries for the Cosme-Odessa Wellfield wells located along the
railroad right-of-way corridor. Please provide verification that the Cosme-
Odessa Wellfield wells located along the railroad right-of-way corridor are
located within property owned or otherwise controlled by the Applicants. This
should be provided in the form of a sealed property boundary land survey which
also depicts the surveyed location of the wells.

14. The well locations (production, monitor wells and others) shown on the site
sketches provided for the Cosme-Odessa Wellfield do not correlate with the
1992 aerial map submitted. It appears to the District that the aerial map
shows the most accurate locations for the wells. Please indicate which map







SScLthwisw Flor'



Mr. Hogg and Mr. Johnson
Page 5 of 7 APR 02 1993
March 31, 1993
BRUO,;\SViLL :..\,,.,, j;", ,, !
shows the correct locations of the wells and cor ect ij jw.ich is
erroneous.

PUBLIC HEALTH AND SAFETY
15. At the December 18, 1992 meeting between District and Authority staffs,
Authority staff indicated that if the St. Petersburg wellfield permits were
reduced to reflect actual historic water use over some portion of the last
permit term, then the Authority and its member governments would experience
a public health, safety, and welfare (PHS&W) emergency. The Authority stated
that this is because other sources are not available at this time, and that
the Authority was intending to rely upon the St. Petersburg wellfields permit
quantities to meet these regional system demands. This December meeting was
the first time that this issue was presented by the Authority to the District.

The Authority's March 1, 1993 submittal included discussion of regional system
demands. It appears that the Applicants are now requesting to use the St.
Petersburg wellfields to meet regional system demands. Please answer the
following questions.

A. Are the Applicants now requesting to use the St. Petersburg wellfields
to meet regional system demands? If so, is this request intended for
the Applicants' requested duration of the permit, or for some other
duration (e.g. until another water supply wellfield can supply these
regional demand quantities)? If the Applicants are not requesting to
use the St. Petersburg wellfields to meet regional system demands,
please explain. Please do not simply defer a response to this question
until the Authority's Resource Development Plan (RDP) is completed.

B. With the exception of the Section 21/Northwest Hillsborough Regional
Wellfield exchanges with Hillsborough County, and trades with Pinellas
County, the District's understanding of the historic water use of the
three St. Petersburg wellfields under consideration in these three St.
Petersburg wellfield WUP applications, is that these wellfields have
only been used to assist in meeting regional demands (i.e. non-St.
Petersburg service area demands) under emergency conditions (e.g.
pipeline breaks), and not on a regular basis. If the District's
understanding is not correct, please explain the historic use of the
three St. Petersburg wellfields under consideration in meeting regional
demands (i.e. non-St. Petersburg service area demands). If trade or
exchange deficits exist, please explain whether these deficits are
intended to be paid back.

C. Please explain what demand centers) are causing the PHS&W emergency.
Assign a magnitude (an actual needed water supply quantity/demand) to
this (or these) demand centerss. Explain in detail why the Applicants
believe that an emergency exists (e.g. wellfield production cutbacks,
lack of a new wellfield, or no request or intentions by the Applicants
to increase quantities at an existing wellfield, to meet these demands).
This information should be provided for each demand center which needs
the emergency-related quantities. Provide the quantity of water needed
for each of these demand centers for the period of time these quantities
are requested based on your response to Item "A" above.

Explain any future plans there are to eventually shift pumpage away from
the three St. Petersburg wellfields under consideration in these three
WUP applications, to meet the specific PHS&W emergency-related
quantities of the demand centers causing the problem.










Mr. Hogg and Mr. Johnson
Page 6 of 7
March 31, 1993

D. The burden of providing this emergency water appears to be placed
completely on the three St. Petersburg wellfields. What other existing
wellfield sources could assist in meeting the emergency-related
quantities, under 1) existing permitted quantities, and 2) under any
requested increase in permit quantities?

E. What measures can and will the Authority staff request the Authority's
Board to undertake to meet the PHS&W emergency demands through a sharing
of this emergency demand burden among other Authority and Authority-
member facilities? Does the Authority staff intend to present this
problem to the Authority Board, and request the Authority Board to
undertake these measures prior to completion of the RDP? If not, why
is such an approach not proposed?

F. The Authority's March 1, 1993 submittal indicates that Cypress Bridge
Wellfield will be the only "additional wellfield which will be added to
the regional system during the Phase 1 construction period" of the loop
system. However, it was the District's understanding that Phase 1
included the interconnection to Morris Bridge Wellfield. In addition,
at the Authority March 15, 1993 Board meeting, Jon Kennedy of the
Authority staff stated that some quantity of water from Morris Bridge
would be sent to the Lake Bridge pump station and then distributed into
the regional system.

Please explain this discrepancy. Can Morris Bridge Wellfield water be
used to meet some of the stated PHS&W emergency demand once Phase 1 is
completed? Once Phase 1 is completed, what quantity of water can the
Morris Bridge Wellfield physically provide to the regional system?

G. What quantity of the PHS&W emergency related quantities can and will be
offset by water conservation measures? Provide documentation to support
your answer.

OTHER
16. In response to Question No. 10 of the District's September 17, 1992, Request
for Additional Information, the Applicants referenced a reclaimed water study
by Camp, Dresser, and McKee that was due to be completed in February, 1993.
Please provide four copies (one unbound) of this report to the District.

The District requests that a meeting (or series of meetings as appropriate) be held
in the field (and in the office as appropriate) to review the existing and any
future proposed ecologic monitoring sites. Please contact John Emery or John Post
at the telephone numbers below to schedule such meetings.

V Southwe. Florida



APR 02 1993


BROOKSV1LLE rL.-...-j
Brooksvric, -r.L;,. _;











Mr. Hogg and Mr. Johnson
Page 7 of 7
March 31, 1993

To help us expedite our review, please furnish us with three copies (one copy of
certain items may suffice, please call for prior approval) of all requested
information within 30 days from the date of this letter. Failure to submit the
required number of copies may constitute an incomplete submittal, and/or cause delay
in the processing of your permit application. If the information is not received
within 30 days from the date, according to Florida law, your permit can be denied.
An extension of time to respond can be granted provided that it is demonstrated that
progress is being made on the response and that the need for additional time is
justified. A request for extension must be received prior to the 30 day due date,
and the District will respond in writing either granting or denying the extension.
If we may be of further assistance, please contact us at the following numbers:

Section 21 and Cosme-Odessa wellfields and general questions-
Mark Haberman, Tampa Office, 985-7481, extension 2049
Mario Cabana, Tampa Office, 985-7481, extension 2014
John Emery, Tampa Office, 985-7481, extension 2006 (envir.)
South Pasco wellfield
Bob Perry, Brooksville Office, 904-796-7211, ext. 4326
John Post, Brooksville Office, 904-796-7211, ext. 4369

Sincerely,



Mark Haberman, Hydrologist
Tampa Permitting Department
Resource Regulation Sauthwest Florida




Resource Regulation
SBroouthwesv t Flori, da






Bob Perry, Hydrologist
Brooksville Permitting Department
Resource Regulation


cc: File of Record WUP Nos. 200003.02, 200004.02, and 203647.02
R. V. McLean
J. Heuer
K. Weber
J. Guida
J. Emery
J. Sternfels
A. Martinez
J. Manley
J. Parker
J. Post
D. Wiley Leggette, Brashears and Graham, Inc.
STPETCL2 .LTR




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