Title: Letter of Clarification of Received Information
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Permanent Link: http://ufdc.ufl.edu/UF00051284/00001
 Material Information
Title: Letter of Clarification of Received Information
Alternate Title: Letter of Clarification of Received Information: WUP Appl. Nos. 200003.02, 200004.02, and 203647.02, reference to Florida Administrative Code: 40D-2.101, 40D-2.301, and 40D-1.603(6).
Physical Description: 7p.
Language: English
Publication Date: Nov. 25, 1992
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
General Note: Box 2, Folder 5D ( COSME-ODESSA SFWMD - SWFWMD ), Item 125
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051284
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.

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/

EST Southwest Florida


Water Management District
2379 Broad Street (U.S. 41 South) Brooksville, Florida 34609-6899
S Phone (904) 796-7211 or 1-800-423-1476 SUNCOM 628-4150
CEM T.D.D. No. only: 1-800-231-6103
November 25, 1992

Charles A. Black
Chairman. CrysTal River 'Mr. Warren Hogg
RoyG. Harrell,Jr. West Coast Regional Water Supply Authority
Vice Chairman, St. Petersburg 2535 Landmark Drive
SallyThompson Clearwater, Florida 33519
Secretary, Tampa
Joe L. Davis, Jr.
Treasurer, Wauchula and
Ramon F. Campo
Brandon Mr. David Wiley, P.G.
James L C Leggette, Brashears and Graham, Inc.
Rebecca MEger 10014 N. Dale Mabry Highway, Suite 205
Sarasota Tampa, Florida, 33618
John T. Hamner
Bradenton Subject: CLARIFICATION OF RECEIVED INFORMATION
Lauis L Law WUP Appl. Nos. 200003.02, 200004.02, and
Land O' Lakes 203647.02
James E. Martin 203647.02
St. Petersburg County: Hillsborough and Pasco
Margaret W. Sistrunk
Odessa Reference: Chapter 40D-2.101, Florida Administrative Code
PeterG. Hubbell Chapter 40D-2.301, Florida Administrative Code
Executive Director Chapter 40D-1.603(6), Florida Administrative Code
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.
The Authority and the City have refused to respond to numerous
questions that are clearly authorized by District rules and Florida
Statutes. The following questions regard responses that the
applicant did provide which require clarification.

Cosme-Odessa Wellfield

1. As previously stated, the site sketches provided are not to
scale; please correct the site sketches (WCWRSA file names:
COSMEWF5, COSMEWF2 and COSMEWF4) to reflect the true widths of
the right-of-ways as specified in the legal descriptions.

2. The site sketch COSMEWF2 shows the parcel of land containing
production well 12A located inaccurately. Please provide a
i corrected sketch.

3. As previously stated, the 1985 aerial photograph provided is
not recent and does not show all of the property boundaries of
the Cosme-Odessa Wellfield. Florida Administrative Code Rule
40D-2.101(2) requires the Applicant to submit information
required on the Water Use Permit Application and supplemental
forms. Part IV, Section B, No. 3, of the Water Use Permit
Application form states "Provide a recent aerial map
showing:....(d)property boundaries...". Discussions with
Hillsborough County Engineering Services indicates that the
County does have available a recent, January 1992, 1"=1000'
aerial photograph for Township 27 south, Range 17 east, which
shows the Cosme-Odessa Wellfield area. Pursuant to 40D-
ExCclkizCC 2.101(2), provide a high-quality copy of the January 1992,
Throu4Ih
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Scvic~ INOV 3J0 1992 ILED ON ) ^ ; {










Mr. Hogg and Mr. Wiley
Page 2 of 7
November 25, 1992

1"=1000', Township 27 south, Range 17 east, aerial photograph accurately
depicting all of the boundaries of the Cosme-Odessa Wellfield. The map
must be consistent with and accurately reflect the legal description of
owned or controlled lands associated with the wellfield.

4. Regarding Folio No. 988.0000 on the APO list, the latest response
indicates that this folio has been added to the revised APO list, however,
this folio number is not listed. Please explain this discrepancy. If
left off, provide the owners name and complete mailing address for this
folio. Regarding Folio No. 2172.0000 on the APO list, as the District
previously indicated, this folio is listed under the ownership of the City
of St. Pete. It is apparent that this folio has been listed twice on the
APO list in error. Please correct any errors to the APO list and provide
a revised list.

South Pasco Wellfield

5. The construction dates provided in the application do not agree with the
construction dates submitted in the prior application. Please verify the
construction date for withdrawals with District ID #1 through #8.

General Questions for All Wellfields

6. Question No. 9 of the District's September 17, 1992 Request for Additional
Information included the following specific question which was not
directly answered by the Applicants, and which still requires an
appropriate response and is therefore repeated below:

How would the Applicant propose to avoid adverse impacts to water
resources if no regulatory level is applied?

The intention of the question is for the Applicant to identify all
measures (if any) the Applicant proposes to take during the term of any
future issued permit to avoid adverse impacts to water resources, due to
the Applicant's requested pumpage quantities, if no regulatory level is
applied.

7. The Applicant's response to Question No. 9 of the District's September 17,
1992 Request for Additional Information included the following statement:
"...we do not believe that the proposed consumptive use will need to be
reduced in order to avoid adverse environmental impacts to wetlands,
lakes, streams, estuaries, fish and wildlife, and other natural
resources." Provide scientific evidence sufficient to support the
Applicant's "belief" that pumpage at the requested quantities for each
wellfield will not cause such adverse environmental impacts. This data
should be in the form of baseline and comparative biological/hydrological
monitoring data for the area within the one-foot drawdown contour.

8. The Applicant's response to Question No. 9 of the District's September 17,
1992 Request for Additional Information included the following statement
that water level limits were established: "...under different hydrologic
and environmental conditions." Please provide the following information
with regard to this statement:

A. In what specific ways and to what degree are hydrologic and
environmental conditions different today?
B. To what degree are the differences in hydrologic and environmental
conditions caused by wellfield pumpage?
C. Document the extent, magnitude, and cause of the difference in
hydrologic and environmental conditions caused by pumpage from the










Mr. Hogg and Mr. Wiley
Page 3 of 7
November 25, 1992

wellfields.
D. Will wellfield pumpage significantly contribute to continuation of
these stated changes in hydrologic and environmental conditions if
regulatory levels are not applied? If not, please explain why and
how this was determined.

9. The Applicant's response to Question No. 37 of the District's September
17, 1992 Request for Additional Information included the following
statement: "The Applicants believe that at the requested quantities there
will be no resulting adverse impacts to lakes." Based on current
hydrologic and environmental conditions, as well as current Chapter 40D-2
rules and the Basis of Review, provide scientific evidence sufficient to
support the Applicant's "belief" that pumpage at the requested quantities
for each wellfield will not result in adverse impacts to lakes. This data
should be in the form of baseline and comparative biological/hydrological
monitoring data for the area within the one-foot drawdown contour.

10. The Applicant's response to Question No. 37 of the District's September
17, 1992 Request for Additional Information also included the following
statement:

"Only after effects on lakes have been evaluated with respect to
other activities...will the City consider augmentation of lakes for
environmental purposes."

The District does not agree that consideration of such measures are only
appropriate after all other non-wellfield pumpage activities have been
evaluated, as the degree of impacts due to pumpage from these three
wellfields are the primary issue being addressed in this WUP application.
However, since the applicant believes that this is important, please
detail the "other activities" which the applicant has stated need to be
evaluated. Please document and quantify in detail how each of these
activities have affected lakes. Be sure to include how the applicant's
activities onsite have affected lakes.

Unless informed otherwise, it will be concluded by the District that the
Applicant will not consider or propose augmentation of lakes. Identify
any lakes that are proposed to be augmented under any such proposal.

11. Regarding the submitted 1981 Water Exchange Agreement and the Regional
System Water Supply Contract, provide an explanation of the City of St.
Petersburg's obligations and WCRWSA's obligations and the relationship of
these obligations to the requested quantities for these permits. How much
of the quantities requested for each wellfield will go to the regional
system for other users?

12. The District has reviewed the wastewater flow and reuse records table
submitted in the Applicant's response letter for the previous five years.
It does not appear evident that there is a "low flow" period in the "water
distributed to reuse customers" during the time you identified as the dry
months. Is the "low flow" period that the Applicant refers to in the
submittal supposed to be the "water distributed to reuse customers" values
in the table, or is it some other values that you are referring to? If it
is some other set of values, what are they? Also provide information on
how the "low flow period" affects the reuse distribution system.

13. In the Applicant's statement "Pressure reductions in the reclaimed water
system occur occasionally during this period when demand equals or exceeds
supply", it is not clear which specific supply you are referring to. Is
this supply the actual available reuse, the untreated wastewater inflow to










Mr. Hogg and Mr. Wiley
Page 4 of 7
November 25, 1992

the WWTPs, the supply that can be physically pumped through the existing
distribution system or some other factor? Please clarify which type of
supply the Applicant is referring to.

14. Regarding the Applicant's statement "the duration of pressure reductions
(in the reuse distribution system) is on the order of 8 to 12 hours",
provide methods or measures that can be undertaken to resolve the problem
and better exploit the available treated wastewater.

15. Please respond to the following questions regarding the expansion of the
reclaimed water reuse distribution system:

a. Are there any hydraulic bottlenecks within the reuse distribution
system? If so, where are they and can they be rectified?
b. Is the city currently working on solutions to any bottleneck
problems? If so, identify the project locations and when the
projects will begin and be completed? If not, why not?
c. If the reuse distribution system bottleneck problems are rectified
what will be the resulting increase of available reuse quantities,
on an average annual basis, to the reuse customers?

16. With regard to the infiltration problems discussed in the applicant's
response, please answer the following questions:

a. When will the sewer-sealing projects to rectify the infiltration
problems associated with the coastal communities be completed?
b. How much has reuse quality improved already, and how far along are
the projects?
c. If the problem is rectified, what amount of the 12 MGD will be able
to be utilized, and is this amount limited by the redistribution
system (bottlenecks)?
d. Regarding the 12 MGD reported to be lost during the spring, what was
the total loss for the Northwest WWTP on an average annual basis?

17. Provide an explanation as to why chlorides of 450 to 650 MG/L are not
acceptable. Include supporting documentation if any is relied upon. What
is the maximum acceptable chloride concentration?

18. In the Reclaimed Water Customer Table (Table 4) submitted in your
response, are the listed "Acreage" values actually irrigated acres? If
not, re-calculate the "Estimated Annual Usage" values based on the actual
irrigated acres and provide a revised table. If specific figures are not
available, provide reasonable estimates of irrigated acreage for each
site, document how these figures were estimated, and re-calculate the
"Estimated Annual Usage" values.

19. The limited population growth and water conservation programs as the
Applicant has stated in the response have no real relevance to further
expansion of reuse connections. Ultimately, there will be a net increase
of effluent flow to the WWTPs resulting directly from increasing potable
water use as you have projected for the City of St. Petersburg. The
Applicant's statement that "A substantial increase to allow additional
reclaimed water connections is not expected, since once a customer is
added to the system, they expect water at all times" implies that the
City's chosen management of the reuse distribution system is the reason
for the infeasibility of additional reuse connections. Is this what the
Applicant intended this to mean? If not, what specifically does the
Applicant mean by this statement?









Mr. Hogg and Mr. Wiley
Page 5 of 7
November 25, 1992

20. Indicate the final means of disposal for the projected increase in water
use which will be treated at the City's WWTPs. Will the additional
treated water be disposed of by the injection wells, utilized for reuse,
or disposed of by another method or utilized for some other purpose? If
it is disposed of by another method or utilized for some other purpose
please identify what these are.

21. As previously requested, please provide a map showing the service area for
the City of Oldsmar.

22. Why are environmental mitigation and rotational quantities more
appropriately addressed under "Regional System WUP" and which "WUP" is it?

23. In the submittal the Applicant stated that 1) the environmental and
rotational demands are not included in the demand projections for the
three wellfields but are more appropriate in the regional system and, 2)
that the data submitted is the most recent and accurate available and, 3)
if the District has any questions regarding the data submitted, we will
respond to those specific questions as appropriate. Therefore:

A. Please explain or justify the requested quantities which exceed the
present, six, ten and 20 year projected average demands by 13.1,
8.3, 9.4 and 7.4 MGD, respectively.

B. Please explain or justify the requested quantities which exceed the
present, six, ten and 20 year projected peak month demands by 17.3,
10.5, 11.3 and 8.8 MGD, respectively.

24. Does the City support the "safe yield" analysis presented by the Authority
in the Cypress Bridge Wellfield application as shown below for these three
wellfields which was submitted in support of the regional system?
Section 21 9.2 mgd
South Pasco 15.6 mgd
Cosme-Odessa 11.5 mgd

25. Based on question No. 24 above, please explain or justify the requested
average and peak month quantities which exceed (shown below) the "safe
yield" for these wellfields.

Average Peak
Section 21 2.8 MGD 6.8 MGD
South Pasco 1.3 MGD 8.4 MGD
Cosme-Odessa 0.5 MGD 5.5 MGD
Total 4.6 MGD 20.7 MGD

If the City supports the analysis why is the applicant requesting greater
quantities in the applications? Provide supporting scientific evidence to
document the safe yield with consideration of environmental impacts. If
the City does not support the analysis, please explain what the revised
safe yield of the regional system is and provide supporting scientific
evidence to document the revised safe yield and the requested quantities.
Document the revised safe yield with consideration of environmental
impacts.

26. As asked previously please provide a discussion of the proposed
methodology that will be used to identify "adverse impacts". Please note
that all factors must be considered when identifying an adversely-affected
wetland, such as soil subsidence and tree fall, reduced hydroperiods and
water levels, and change of plant species. The response to the District's
September 17, 1992 letter was to quote from the Performance Standards for









Mr. Hogg and Mr. Wiley
Page 6 of 7
November 25, 1992

wetlands, lakes and streams in the Basis of Review. This is not
considered an acceptable response. It is true that if these performance
standards are not met, the District recognizes adverse impacts have
occurred. However, the District must evaluate specifically how the adverse
impacts will be identified to determine if the applicant's methodology can
reasonably be expected to perform this task.

27. The District requests that the Applicant suggest a methodology that will
be used to identify the adverse impacts that may be discovered during
ecological monitoring, because the performance standards are only
indicators of adverse impacts and are not methods to be used to measure or
identify impacts. For instance, the standards state that the wet season
water levels shall not deviate from their normal range. For example:

a. How will the Applicant determine when the levels deviate from their
normal range? Will the Applicant compare wet season water levels of
a similar wetland during the same period of time?
b. Another standard is that wetland habitat functions shall not be
adversely impacted as a result of withdrawals. How will the
Applicant determine when the habitat functions are adversely
impacted? Will the Applicant compare the habitat functions of
similar wetlands?

Please provide a specific methodology to address each identified adverse
impact listed in the performance standards.

28. As asked previously, please provide a discussion of how, if "adverse
impacts" are identified, causes will be identified. Suggested methods for
identifying causes of wetland degradation within the wellfield influence
area shall include but not be limited to monitoring nests, ground-
penetrating radar, and some information that is collected under the
ecological monitoring program. The response provided was a quote from the
1984 administrative hearing and is not acceptable. Again, specifically
how will causes of adverse impacts be identified? Propose a methodology
that the Applicant will follow to determine any causes of adverse impacts.
Please be advised that Chapter 40D-2 F.A.C. requires that "on-site" and
"off-site" impacts be addressed.

29. As asked previously, specifically how will the "land use impacts"
monitoring sites that were mentioned in the Appendix A attachment entitled
"The Ecological Monitoring of NWHRWF, Cosme-Odessa, Section 21, and South
Pasco Wellfields" be specifically used to differentiate between the
effects of land use versus water production on biological communities?
The response only stated that the land use impact monitoring sites used as
control sites will provide information on the effects of land use
alterations on wetland communities and is not acceptable. What
information will be gathered that could and will be used to differentiate
between the effects of land use versus water production? The District
requests that the Applicant identify a specific methodology that will
identify any land use impacts upon the wellfield areas.

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 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










Mr. Hogg and Mr. Wiley
Page 7 of 7
November 25, 1992


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 (envir.)


Sincerely,



Mark Haberman, Hydrologist
Tampa Permitting Department
Resource Regulation



Mario Cabana, P.G., Hydrologist
Tampa Permitting Department
Resource Regulation



Bob Perry, Hydrologist
Brooksville Permitting Department
Resource Regulation


cc: File of Record WUP Nos. 200003.02, 200004.02, and 203647.02
Bill Johnson, City of St. Petersburg, Public Utilities Director
R. McLean
J. Heuer
K. Weber
J. Guida
J. Emery
J. Sternfels
A. Martinez
J. Parker
J. Post

stpetclr.ltr




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