Title: Letter of Request for Additional Information
CITATION PAGE IMAGE
Full Citation
STANDARD VIEW MARC VIEW
Permanent Link: http://ufdc.ufl.edu/UF00051285/00001
 Material Information
Title: Letter of Request for Additional Information
Alternate Title: Letter of Request for Additional Information: WUP Appl. Nox. 200003.02, 200004.02, 203647.02 County: Hillsborough and Pasco, reference to Florida Administrative Code 40D-2.101 and 40D-1.603(6).
Physical Description: 16p.
Language: English
Publication Date: Sept. 17, 1992
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
General Note: Box 2, Folder 5D ( COSME-ODESSA SFWMD - SWFWMD ), Item 126
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
 Record Information
Bibliographic ID: UF00051285
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






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
September 17, 1992


Charles A. Black Mr. Warren Hogg
Chairman. CsTc river West Coast Regional Water Supply Authority ?
Roy G. Harrell, Jr. 2535 Landmark Drive
vice Chairmon. St. Petersourg Clearwater, Florida 33519 i It ..
Sally Thompson
Secretary. Tampa and
Joe L Davis, Jr.
Treasurer. Wcuchuol \
RamonF. Campo Mr. David Wiley, P.G.
Brcracon Leggette, Brashears and Graham, Inc.
JamesL. Cox 10014 N. Dale Mabry Highway J' ,
Lokelcno Suite 205
John T. Hamner
Brcdenton Tampa, Florida, 33618
Curtis L Law
Land O'Lckes Subject: REQUEST FOR ADDITIONAL INFORMATION
JamesE.Martin WUP Appl. Nos. 200003.02, 200004.02, and 203647.02
St. Petersburg County: Hillsborough and asco
Margaret W. Sistrunk
Ocessa Reference: Chapter 40D-2.101, Florida Administrative Code
PeterG. Hubbell Chapter 40D-1.603(6), Florida Administrative Code
Executive Director
Mark D. Farrell Dear Sirs:
Assistant Executive Director
Your permit applications for the City of St. Petersburg wellfields
Section 21, Cosme-Odessa, and South Pasco are currently being
reviewed. Since WCRWSA is the contact for Section 21 and Cosme-
Odessa, and LB&G is the contact for the South Pasco wellfield this
letter is addressed to both parties. The additional information
listed below is necessary before we can complete our review, and the
extensive list of questions here is designed to cover all three
wellfields and a wide variety of issues relavent to each. The
questions have been organized under the two main categories of
wellfield-specific questions and questions applying in general to all
three wellfields, and then into sub-catagories by topic. Please
contact us to schedule a meeting for discussion of this information
request sometime after October 4th, or, contact us by phone at any
time.

INDIVIDUAL WELLFIELD-SPECIFIC QUESTIONS

Cosme-Odessa Wellfield

Property Control
1. The following items concern Cosie-Odessa Wellfield property
control and boundaries.
A) The site sketches provided appear to have several
discrepancies. When compared to the Hillsborough County
tax folio records (1991) for ownership, it was noted that
several tracts of land were either omitted or added to the
property boundaries. Specifically, County folio numbers
2572.0000, 2729.0000, and 2553.0100 were shown to be owned
property (within the property boundaries) However, the
County records show these properties under private
ownership. County folio numbers 2733.0000, 2731.0000,
2483.0000, 2171.0000 (not shown in entirety), and the



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Mr. Hogg and Mr. Wiley
Page 2 of 14
September 17, 1992

entire extent of right of way (as described in portions of the
legal description provided) were not shown on the site sketches.
In addition, the boundaries of the right of ways (as described
in portions of the legal description provided) as shown on the
site sketches appear to be drawn out of scale (larger than
actual size). Please explain these discrepancies and if in
error, provide updated sketches showing the accurate site
boundaries for the Cosme-Odessa Wellfield.

B) Please provide an accurate legal description of the entire
property(s) owned by the City of St. Petersburg which comprises
the Cosme-Odessa Wellfield. Preliminary review of the legal
description submitted indicates that it does not include all of
the property owned by the City of St. Petersburg. In addition,
the legal description includes property in section 23 not shown
as being within the Cosme-Odessa Wellfield property boundaries
and is believed to be under private ownership. Please provide a
current legal description of all the property included for this
application and review it prior to submittal to assure that it
is accurate and complete.

C) The 1985 aerial map provided is not recent and does not show all
the property boundaries of the Cosme-Odessa Wellfield. Please
provide a recent (1991 or 1992), high quality, 1"=1000' (or
larger scaled, for instance 1"=500') aerial photograph
accurately depicting all of the 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. This
information may be depicted on the aerials requested under
environmental monitoring.

D) Based on Item C above, provide a revised figure for adjacent
well users which should be included if the site boundaries
increase in size.

Adjacent Property Owners
2. Please provide the complete mailing address for the APO listed as
Keystone Beach, Folio No. 988.0000. Folio No. 2172.0000 was listed on
the APO list under the ownership of the City of St. Petersburg.
However, County records show that in 1991 this folio number was under
private ownership. Please explain this discrepancy.

In addition, based on Item C of the Property Control questions above,
also provide the additional APOs which should be included if the site
boundaries increase in size.

Specific Capacity Testina
3. In the past, the City of St. Petersburg was planning to conduct
specific capacity tests for the production wells at the Cosme-Odessa
Wellfield. Were the tests ever conducted? If so, please provide
copies of all field data collected and any interpretations. If not,
does the City plan to conduct the tests in the future? If so, when?

Historical Pumoina
4. Please provide available Cosme-Odessa pumpage data to complete our
data base for the years prior to 1945. In addition to total wellfield
pumpage, where available provide information for individual wells
also.











Mr. Hcgg and Mr. Wiley
Page 3 of 14
September 17, 1992

South Pasco Wellfield
5. Please verify the well data submitted in response to IV.D.6,
Site/Withdrawal Information. The data submitted is not consistent
with prior information.

6. In addition to the well information submitted in response to IV.D.6,
Site/Withdrawal Information, please supply a similar table for the
monitor wells which were required by the current and prior permit.

7. In addition to the wellfield map submitted in response to IV.B.3,4a,
please submit a map depicting the location of the monitor wells which
were required by the current and prior permit.

Section 21 Wellfield
8. Why are only six wells in use at Section 21? Why are the other wells
not in operation, and how long have each of them been out of service?
when will the currently unused wells be placed back into service?


GENERAL QUESTIONS FOR ALL WELLFIELDS

Regulatory Levels
9. The applicants have described regulatory levels as "poor management
tools". With emphasis on avoiding adverse environmental and
hydrologic impacts, specify why they are considered by the applicants
as poor management tools. How would the applicants propose to avoid
adverse impacts to water resources if no regulatory level is applied?
At what potentiometric or water table elevation would pumpage be
decreased?

Reuse
10. The region within which the City's wellfields are located has been
determined by the District to be stressed, and has been designated a
WUCA. Therefore, the City must begin to explore options to optimize
the water resources that are currently available to it, for example
it's reclaimed water supply. The District appreciates the City's
reclaimed water efforts to date, and strongly recommends that these
efforts be continued in the future to offset the projected increase in
potable demand.

Provide current progress on, and a plan for exploring the following
items which will allow the City to optimize reclaimed water as a
resource. Include but do not limit your discussion to the items
listed below.

A. Metering and charging for the amount of water used.
B. Limiting irrigation hours to other than 10 a.m.- 4:00 p.m.
C. Eliminating existing, or nonconsideration of future irrigation
of areas that do not require irrigation.
D. Limiting the available water to reasonable quantities for the
intended use.
E. Replacing potable water use for cases where potable water is
used but is not required.
F. Maximizing the available reclaimed water.
G. Expanding the reclaimed water user base so that during high
reclaimed water flow periods, the water could be reused rather
than injected or disposed of in some other less beneficial
manner.
H. Eliminating the reported high saltwater infiltration rates to
sewer systems.











Mr. Hogg and Mr. Wiley
Page 4 of 14
September 17, 1992

I. Returning of reclaimed water to interior areas to rehydrate
areas stressed by wellfield withdrawals.
J. Other potential methods to minimize potable water demands and/or
mitigate water deficit stress in wellfield areas.
K. A combination of the above.

11. The response to Item II.A.1. (Wastewater Treatment and Reuse)
indicates that during the dry spring months actual flow into the
wastewater treatment plants is at a minimum. Please provide an
explanation of the causes) of this reduction and indicate the months
that are considered the dry spring months. In addition, please
provide the total treated wastewater flow versus total reuse flow
distribution records on a month-to-month basis for the previous 5
years in order to illustrate the stated low flow periods that cause
the pressure reductions within the reuse distribution system.

12. Of the 20.7 MGD of reuse utilized during 1991, how much of the reuse
actually replaced potable water use (e.g., landscape irrigation with
City water replaced by reuse), how much replaced local groundwater
sources, and how much was supplied to a new use? Please provide
sufficient documentation to back-up your determination.

13. As required by WUCA conditions and not reported in your WUCA report,
provide the quantity of water provided to all reuse connections
greater than 4-inches in diameter or greater. Also, where the water
is used for irrigation, provide the acreage irrigated through each
connection.

14. Why is wastewater flow not expected to increase appreciably in the
future due to limited growth of sewer service and increased water
conservation? Please provide a detailed explanation to justify this
statement. Include the final means of disposal for the actual
projected increase in water use above what is currently used. Will
the wastewater generated by the increased water use be disposed of by
the City's WWTPs or other plants? If other than the City's WWTPs,
will the treated wastewater be available to the City of St.
Petersburg?

15. What specifically is the problem with the saltwater infiltration into
the sewer systems which feed the reclaimed water system, and where do
the problems occur? What steps are or will be taken to avoid
continuation of high saltwater infiltration rates and their adverse
affect on the reclaimed water system? When will the problem be
resolved? How much potential reclaimed water is lost due to this
problem? what is the chloride, sulfate, and TDS concentration of this
water, as opposed to other City reclaimed water?

16. Please provide the District with a synopsis of nature of the problems
with the City's injection wells, and what the DER has discussed with
the City to consider as potential resolution of this problem? Provide
a contact at DER familiar with the situation. When will the problems
be resolved? Is all water not used for reclaimed purposes injected?
If not, where is the other water disposed of, and what are the average
quantities?

Desalination
17. The consultant who undertook the preliminary portions of the
desalination investigation project recommended further hydrogeologic
evaluation to finalize the determination of the feasibility of
desalination. In addition, the USGS' results also state that further











Mr. Hogg and Mr. Wiley
Page 5 of 14
September 17, 1992

study of the effects of pumping on the quality of brackish water is
needed.

What is the status of the Authority's investigation of the feasibility
of desalination within the Pinellas Peninsula, and specifically within
the St. Petersburg service area? when will the recommended future
investigation be undertaken? Will the Authority undertake such a
program for Hillsborough or Pasco Counties? Consider that such an
investigation will be a WUCA requirement in the future.

Demand
18. The submitted application states that the projected water use is based
on the District's Needs and Sources document (N&S) However, the
population data submitted does not match the N&S population data.
Please provide an explanation of your population projection
methodology and include appropriate supporting documentation.
Wholesale public supply customers shall be listed separately to
justify the water use quantities requested for these wholesale
customers.

The submitted application indicates that there are other water users
such as South Pasadena, Lealman, Bear Creek, Gandy, and Bay Pines,
that are in the St. Pete service area and receive water at retail
rates. Have these been included in the service area population? If
they have not been included, include them.

Note that Unisys and Tri-County Business Park are not wholesale
customers as defined by the District's Basis of Review. Any other
large non-population based customers should be examined for possible
designation as a significant use, and included as such for District
WUCJA reporting purposes.

19. The submitted application states that the projected water use is based
on the District N&S, but the water use numbers presented in the
application do not match up with N&S projections. Please explain why
these do not match.

20. Provide an explanation of how the quantities (current and projected)
for recreational irrigation and for fire fighting/testing were
derived. Are the fire fighting quantities also included in the
unaccounted-for use?

21. In order to verify the current and projected per capital use values,
the current and projected quantities for the wholesale users must be
known in order to subtract them out of the calculation. Please
provide these numbers and also provide supporting information on
population. Include the Unisys current and projected demand also if
not assumed to be constant.


22. Please explain why the treatment losses are as high as they are at the
Cosme treatment plant. Include a description of the specific
processes involved and relative percentage of the contribution of each
to the total. The projected figures are assuming that no percentage
decreases in treatment losses would occur over a 20-year period; this
is the same as saying that no techniques would be employed to reuse or
recycle (water conservation) any of this water over this 20-year
period.











Mr. Hogg and Mr. Wiley
Page 6 of 14
September 17, 1992

.The District understands that the sludge has been shipped to the
Lakeland Power Plant for the last 12 years. what were the treatment
losses (average annual) when the sludge was being deposited onsite at
the wellfield? What are they now that the sludge is going to Lakeland
and some of the water is being recovered before the sludge is shipped?

23. What are the total quantities (Average Annual) treated at the Lake
Park facility and what are the treatment losses (Average Annual)?

24. Provide a listing of the quantities (average annual) received at the
Cosme Plant from the Gunn Highway wells on the 206676 permit for the
last six years.

25. In comparison to the ten and twenty year projections, why does the
population per year increase so much in the first six years compared
to the subsequent years? Justify the greater magnitude in the six
year projection.

26. Using actual pumpage, and documented populations, provide the per
capital rate for each of the last five year;.

27. On the submitted Public Supply application Part III. Section A.,
number 3 "Other Metered Uses", the 1992 current quantity of 776,476
gpd is supposed to have the Oldsmar use included (as stated in your
footnote). However, the N&S quantity for Oldsmar alone is
significantly larger than the number presented. Please explain this
discrepancy and correct it if necessary.

On the 1998, 2002, and 2012 quantities for "Other Metered Uses" the
totals are closer to the N&S Oldsmar quantities. However, where is
Gulfport's water use included?

28. On the unaccounted-for water calculation, any of the numbers used in
the current application that contribute to the total demand figure
will affect the final calculation of the percentage unaccounted-for
water. If any of these supporting numbers change by virtue of a
response to one of the above questions, then the unaccounted-for water
calculation will have to be corrected. Please provide this corrected
number with all calculations included if necessary.

29. Please provide a copy and describe in detail the Regional Loop System
Contract to which you refer in your submitted application. How does
this contract affect the transfer of water into or out of the St. Pete
wellfield system?

Also please provide a copy of the most recent "gallon-for-gallon"
exchange contract between St. Pete and Hillsborough County for the
Gunn Highway wells pumpage on the 206676 permit.

30. Please describe in detail the "take or pay" contract that Bill Johnson
mentioned in our pre-application meeting. How does this contract
affect the transfer of water into or out of the St. Pete wellfield
system? Provide some historical transferal data or pumpage figures.
Does the contract result in significantly greater quantities being
pumped from any or all of the three wellfields?

31. Please provide documentation of the 7% seasonal population
fluctuation. Was this number derived from a document or a
calculation? Note that the quantities in the N&S document already
have the seasonal component included in them.











Mr. Hogg and Mr. Wiley
Page 7 of 14
September 17, 1992

32. In regards to the maps showing the City of St. Petersburg service
areas (Attachment VI.C.7.), part A does not show the interconnection
to the NWHRWF. Please revise this figure to show the interconnection
and wellfield. Part B does not show the City of Oldsmar, Unisys and
the Tri-County Business Park. Note, the District does not consider
Unisys and the Tri-County Business Park as wholesale customers.
Please provide a map which shows these service areas or revise the
figure.

33. Please provide a tabular breakdown, in million gallons per day, of the
sources of water available to the city versus the water demand centers
where the water is needed. On table should be prepared for each of
the following scenarios.

A. Annual average withdrawals versus annual average demand at
existing quantities and as projected for six, ten and twenty
years.

B. Peak month average day withdrawal versus peak month average day
demand at existing quantities and as ,projected for six, ten and
twenty years.

Sources of water should include in addition to the Cosme-Odessa,
Section 21 and South Pasco Wellfields, the regional system operated by
the West Coast Regional Supply Authority and any other sources that
the city may have such as contracts and/or agreements with other
entities. Demand centers should include and identify not only the
direct retail customers of the city but also each wholesale customer
as well as other water demands, such as required for mitigation of
environmental impacts and quantities to offset rotational
requirements.

34. Please provide a breakdown of the percentage of water supplied to each
demand center from each source in tabular form as for above.

35. Please identify and explain any changes and/or discrepancies between
the above items and prior information submitted by the West Coast
Regional Water Supply Authority in support of other permits which also
provide service to the city especially as in Cypress Bridge Wellfield.
This will help to address any concerns over the dynamic planning
process necessary for the city and WCRWSA to provide the water supply
required in the future.

Water Conservation
36. Has the City of St. Petersburg adopted a water conserving rate
structure? If so, provide a description of the structure, any
supporting documentation, and a report on the effectiveness of the
rate structure. If not currently adopted, note that under the WUCA
conditions all of the above will be required by January 1, 1993.

Lake Auamentation
37. Provide details of the City's intentions with regard to augmentation
of significantly affected lakes, both external and internal to the
wellfields. Include whether this would be done through wells
constructed by the City offsite from the wellfields. Keep in mind
that aesthetic augmentation is not allowed within a WUCA. The
feasibility of augmentation as a mitigation method will have to be
discussed. Augmentation, if allowed, would only be allowed for
environmental purposes. Include discussion of lakes located within
the wellfields.











Mr. Hogg and Mr. Wiley
Page 8 of 14
September 17, 1992

38. Has Starvation Lake ever been augmented? If so, how much, when, and
from what source?

Environmental Monitorina Program
It is strongly recommended that you discuss the requested information with
the District's environmental scientists prior to finalizing the proposed
environmental monitoring plan.

39. At the end of your submitted application, starting with Appendix A-
Regional Monitoring program, there are a series of attached memos. In
the introductory cover page there is no specific indication on how
these memos are to be interpreted relative to the application
questions (for memos dated 6-1-92 and 6-2-92). District must assume,
unless directed otherwise, that the proposals and recommendations
stated in the attached memos are the Applicant's current position with
regard to current hydrologic and environmental conditions.

40. On a recent (1991-1992), high quality, 1"=1000' (or larger scaled, for
instance, 1"=500') aerial map, illustrate the limits of the
estimated 1' surficial groundwater drawdown, area provided by the
District (see attached figure). On the same map, identify all
wetlands larger than 1/2 acre, ponds, streams, and lakes within the
contour. This map will be used to locate all water resources that
may be affected by the wellfields.

41. Provide an overall location map of the study area that clearly shows
the location of and identifies each current environmental monitoring
station (using the I.D. number or letter used in the monitoring
reports). Also provide a detailed site-specific map of each current
environmental monitoring site that includes the authorized access
route, and locates transects, quadrats, vegetation zones, and any
other mappablee" parts of the information required for the
environmental monitoring program.

42. Per Chapter 40D-2, F.A.C., Basis of Review, environmental monitoring
is necessary when there is..."potential for significant adverse
impacts to environmental features associated with the water resources
of the District." (page B-49). It is presumed "...that a withdrawal
of water will not cause unacceptable environmental impacts if the
withdrawal of water...does not lower the water table at the wetland by
more than one foot." (page B-35).

It is apparent from the applications that you intend to modify the
environmental monitoring program currently in use for the Northwest
Hillsborough Regional Wellfield (permit number 206766) for the
monitoring that will be required for the three St. Petersburg
wellfields. Our review of the current monitoring program indicates
that parts of it could be useful in monitoring the health of the
wetlands within the three subject wellfields' influence if: 1) the
presentation of the currently-collected information was revised, 2)
each site was monitored more thoroughly, and 3) if additional sites
were added. Following are modifications to the current program that
are required to form it into a more useful wetland evaluation tool.
Provide an outline of the proposed environmental monitoring program
which incorporates the following and addresses items 1, 2, and 3
above, and thoroughly describes the proposed monitoring procedures.
Please note that the following is necessary not only for currently
monitored sites but also for all additional sites.










Mr. Hogg and Mr. Wiley
Page 9 of 14
September 17, 1992

a. On a semi-annual basis, provide monitoring results for. each
wetland. The collected data should be sorted by wetland rather
than by category (each monitored wetland should have a set of
information presented in one location in the report). Also,
provide narrative summaries of trends in and current status of
each monitored wetland in addition to an overall summary of
trends throughout the wellfield region. The key information
required should include:

-monthly water levels
(convert all relative elevations to NGVD;
include both surface and ground water measurements;
provide a reference elevation such as existing grade,
previously-established or historic pool elevations, old
lichen lines, etc.)
-monthly extent of inundation
(measure the areal extent of pooled water and illustrate
the extent on a scaled drawing)
-semi-annual (May and September) soil condition and
levels (oxidation or subsidence) ,
-semi-annual (May and September) plant communities
-semi-annual (May and September) canopy conditions
-semi-annual (May and September) fire effects
-other useful information (recent land use changes near
each wetland, for instance)

b. Hydroperiod information (duration of inundation) for monitored
wetlands is also necessary. Please provide a hydroperiod
monitoring plan for all monitored wetlands.

c. Identify several representative control wetlands that will be
used to help evaluate wetlands within the influence of the
wellfield, and document why they are appropriate. These must be
monitored the same as the wetlands within the wellfield area.

d. Photographic documentation at regular intervals at each
monitoring site will be required. Provide initial photos for
each site and then photograph each site at every semi-annual
monitoring event. The photos will be most useful if they are
panoramic possibly following vegetation transect lines.

e. Infra-red photos (1"=2000') covering at least the land within
the estimated 1' surficial groundwater drawdown area should be
provided. Provide detailed interpretation of the photos by a
qualified interpreter. The interpretation should address
percent canopy closure, vegetative conditions, areal extent of
surface water, and disturbance factors for wetlands identified
within the estimated 1' surficial groundwater drawdown area. A
trend analysis describing the changes in the canopy, vegetation,
extent of surface water, and disturbance factors over time
should also be addressed. After permit issuance, the entire 1'
surficial groundwater drawdown area should be photographed and
interpreted twice a year (May and September).

43. The currently proposed list of sites to be monitored ("Table 1"
included in Section 21's permit application listed 57 proposed sites
for all three wellfields) is not adequate to assess environmental
impacts that are caused by the three wellfields. Additional
environmental monitoring sites will be required by the District.
Locations will depend on review of the estimated 1' surficial drawdown











Mr. Hogg and Mr. Wiley
Page 10 of 14
September 17, 1992

area, field reviews, and review of the current list of environmental
monitoring stations and review of the monitoring program and
methodology. Also note that some of the currently-monitored sites may
not be acceptable for evaluating impacts from the wellfields and
should not be included in the environmental monitoring program. The
aoal of the monitoring olan is to have a sufficient number of wetlands
monitored thoroughly in order to definitively evaluate wellfield
impacts.

To consider sites as "representative" of others and thus allow some
wetlands within the estimated 1' surficial drawdown area to be omitted
from monitoring, it must be demonstrated that the representative sites
are actually representative of relatively equal soil conditions,
underlying geological conditions (ground penetrating radar might be
appropriate for this), drainage basins, depth of surficial water,
vegetation, size, etc.

Contact the project environmental scientists (Julie Sternfels for
Section 21, Alberto Martinez for Cosme-Odessa, and John Post for
South Pasco) for a field meeting to visit representative existing
environmental monitoring sites and to visit any that may need to be
added. Note that several future field meetings will be necessary
after review of additional information.

44. Provide guarantees that access to the existing and additional
environmental monitoring sites will be maintained in perpetuity.
This guarantee may be in the form of a legal easement. Describe how
you will overcome any problems that could potentially prevent
permanent access.

45. Please provide an assessment plan that will allow monitored wetlands
to be ranked by health, and trends in their health to be easily
observed. The plan should rank wetlands according to several key
criteria (water levels, soil condition, canopy condition, fire
effects, and plant and animal life). Once the assessment plan is
approved by the District, all monitored wetlands must be initially
ranked, and from then on each time a site is visited for monitoring,
it should be ranked again, and all results and trends should be
included in the semi-annual environmental monitoring reports.

Environmental Adverse Imoacts
46. Provide discussion of how "adverse impacts" will be identified.
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.

47. 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 monitoring nests, ground-penetrating
radar, and some information that is collected under the environmental
monitoring program.

48. 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 used to differentiate between the effects of land use
versus water production on biological communities?











Mr. Hogg and Mr. Wiley
Page 10 of 14
September 17, 1992

area, field reviews, and review of the current list of environmental
monitoring stations and review of the monitoring program and
methodology. Also note that some of the currently-monitored sites may
not be acceptable for evaluating impacts from the wellfields and
should not be included in the environmental monitoring program. The
coal of the monitoring olan is to have a sufficient number of wetlands
monitored thorouchlv in order to definitively evaluate wellfield
impacts.

To consider sites as "representative" of others and thus allow some
wetlands within the estimated I' surficial drawdown area to be omitted
from monitoring, it must be demonstrated that the representative sites
are actually representative of relatively equal soil conditions,
underlying geological conditions (ground penetrating radar might be
appropriate for this), drainage basins, depth of surficial water,
vegetation, size, etc.

Contact the project environmental scientists (Julie Sternfels for
Section 21, Alberto Martinez for Cosme-Odessa, and John Post for
South Pasco) for a field meeting to visit representative existing
environmental monitoring sites and to visit any that may need to be
added. Note that several future field meetings will be necessary
after review of additional information.

44. Provide guarantees that access to the existing and additional
environmental monitoring sites will be maintained in perpetuity.
This guarantee may be in the form of a legal easement. Describe how
you will overcome any problems that could potentially prevent
permanent access.

45. Please provide an assessment plan that will allow monitored wetlands
to be ranked by health, and trends in their health to be easily
observed. The plan should rank wetlands according to several key
criteria (water levels, soil condition, canopy condition, fire
effects, and plant and animal life). Once the assessment plan is
approved by the District, all monitored wetlands must be initially
ranked, and from then on each time a site is visited for monitoring,
it should be ranked again, and all results and trends should be
included in the semi-annual environmental monitoring reports.

Environmental Adverse Imoacts
46. Provide discussion of how "adverse impacts" will be identified.
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.

47. 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 monitoring nests, ground-penetrating
radar, and some information that is collected under the environmental
monitoring program.

48. 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 used to differentiate between the effects of land use
versus water production on biological communities?











Mr. Hogg and Mr. Wiley
Page 11 of 14
September 17, 1992

49. Please provide a mitigation plan for adversely impacted wetlands that
are detected and determined to be caused by the wellfields.
Investigate other forms of mitigation beyond the currently recognized
forms such as wellfield rotation or augmentation by groundwater, for
instance, augmentation by advanced treated waste water. Wetland
creation in areas located outside of the wellfields' influence may be
considered in certain circumstances, but only if appropriate. For
additional compensation beyond on-site mitigation, preservation of
upland and wetland habitat areas or restoration of degraded wetlands
out of the wellfields' influence may be considered.

Hydrologic Monitoring
50. Propose a hydrologic monitoring program which will be synergistic with
the environmental monitoring program. This should include monitoring
nests which include surficial and Floridan aquifer monitor wells, as
well as lake staff gages. The applicants will need to install staff
gages in any unmonitored lakes, and may need to read District staff
gages in currently monitored lakes as part of this program. These
stations would be used to provide correlations of these water levels
and pumpage in annual reports. Coordination with District staff will
be necessary prior to your submittal to ensure that an acceptable
program is submitted.

51. Provide the details (e.g. well names, locations, casing and total
depth, frequency and method of sampling collection, parameters
analyzed) and address the adequacy of the current water quality
monitoring program for these three wellfields in avoiding adverse
impacts due to saltwater intrusion to the wellfield.

52. Provide an analysis of water quality data collected from the "E-
series" wells (E-101, E-102, E-103, and E-105). Provide a recommended
program for future transition zone monitoring including proposed well
modification plans and sampling procedures as discussed at our May 6,
1992, meeting. Assuming changes to the sampling procedures will be
proposed, it is recommended that parallel sampling be performed to
relate prior data to future data.

Impacts
53. On your submitted application, under Part V. Impacts, your response to
these questions was "none anticipated". Several supporting statements
referencing the previous Cosme-Odessa, Section 21 and South Pasco
Wellfields staff reports, model evaluations, and SWFWMD Orders 84-3
and 82-19 were given. The District will assume, unless directed
otherwise, that these statements are the only basis for the
Applicant's current position with regard to current hydrologic and
environmental conditions.

54. Please provide a study of the occurrence of sinkholes in and around
each wellfield. The study should include not only an inventory of
sinkholes but also time of occurrence, frequency of occurrence,
environmental conditions and wellfield operations (pumpage quantities)
prior to and at the time of occurrence.

55. Please provide a table listing dates, investigations, and activities
undertaken to mitigate any adverse effects to adjacent user. This
should include wells and surface water features.

Wellfield Manaaement Plan
The following items regard wellfield management plans for all three
wellfields, unless specifically stated otherwise. The goal of the wellfield











Mr. Hogg and Mr. Wiley
Page 12 of 14
September 17, 1992

management plans will be to interface with the environmental and hydrologic
monitoring programs in a manner which will prevent adverse impacts. The
following questions should be addressed with this goal in mind.

56. The application for the Cosme-Odessa Wellfield indicates that pumpage
is distributed evenly to spread impacts over the full wellfield
property. Review of the District's data base does not verify this
statement. Please address the following:

A. District pumpage data reflects that production wells on the
south side of the Cosme-Odessa Wellfield, in section 27, have
been pumped at a relatively lower rate than other wells.
Provide an explanation as to why this has been occurring, and
address whether pumpage from these wells can be increased to a
level comparable to the other production wells.

B. Due to the dispersed nature of the wells contained within the
Cosme wellfield, the potential for lessening impacts may be
significant. Document and discuss the feasibility of
redistributing pumpage within the wellfield to lessen drawdowns
in more sensitive areas. Can less efficient wells be
rehabilitated to increase efficiency and decrease drawdowns?

57. Provide information on the current and future ability of the wellfield
operator to remotely control pumpage based on designated water levels
or other remote telemetry data that can assist in avoiding adverse
impacts. How will the hydrologic and environmental monitoring
programs be used to make wellfield operation decisions? What is the
current basis and what will be the future basis used to determine when
the pumpage distribution will be changed or rotated to other
locations?

58. There may be the potential for future coordination between District,
City, and Authority staffs that could allow for increased recharge
potential for the wellfields. Are the applicants amenable to
considering allowing future development drainage in these wellfield
areas to be routed to the wellfields? If so, preliminary discussion
on the feasibility of this, and other similar recharge potential
options should be included in your response.

Drouaht/Inter-Wellfield Rotational Ability
59. The District has been experiencing a prolonged series of dry years.
Droughts are natural occurrences in the State of Florida. The
Authority is directed by Chapter 373.1962 to provide water in such a
manner as will give priority to reducing adverse environmental effects
of excessive or improper withdrawals of water from concentrated areas.
Therefore, the ability to rotate pumpage away and significantly
decrease quantities from the sensitive area that these wellfields are
located within is essential in avoiding adverse wellfield impacts.

with specific emphasis in regard to the issues presented above, please
provide the following information.

A. An analysis of the applicants' current ability to rotate away
from these three wellfields on an individual and cumulative (all
three wellfields) basis, while still meeting demands. Provide
the regional system-wide availability of water under such
circumstances to meet the City's service area demand.











Mr. Hogg and Mr. Wiley
Page 13 of 14
September 17, 1992

B. what specific plans do the applicants have to increase the
ability to rotate away from these wellfields, as well as
decrease overall demands, during such prolonged drought periods?
What rotational quantities are currently permitted, versus
proposed to be permitted? What wellfield(s) will provide the
increased demand? By rotational quantities, the District means
excess that exists within other wellfields which isn't currently
being used.

60. With consideration of the requested quantities, and the already
stressed environmental conditions in the wellfield area, how do you
propose to meet the specific environmental aspects of the Authority's
charter stated in Chapter 373?

Others
61. What is the "Benchmark Lakes" program mentioned in one of the attached
Authority memorandums? What lakes are included in this program, and
what data is collected (type, frequency, etc.)? Has the data been
submitted to the District? If not, please provide it on disk.

62. Provide all drainage-related reports for al' three wellfields and the
surrounding areas prepared for the Authority. Include those done by
Charlie Palmer and Scott Emery for all three wellfields.

63. During a field visit to the Cosme-Odessa and Section 21 Wellfields,
District staff noted a significant number of small diameter wells (1
1/4" to 2") existing at the wellfields which were not listed on the
well summary or shown on the aerials submitted with the current
renewal applications. Please provide a complete list (with all
information shown as in the withdrawal list previously submitted) and
a map showing the locations of all existing wells, regardless of
casing diameters, for the Cosme-Odessa, Section 21 and South Pasco
Wellfields.

64. For the historical monitoring data provided to the District by the
City of St. Petersburg, please provide the names of the lakes
monitored as lakes numbers 1 through 10.











Mr. Hogg and Mr. Wiley
Page 14 of 14
September 17, 1992


To expedite the processing of your application, 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
request. If the requested information cannot be provided within 30 days an
extension may be requested for a reasonable period of time, provided
acceptable justification is given for the extension. Your request for
extension must be received within 30 days from the date of this letter. 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
South Pasco wellfield
Bob Perry, Brooksville Office, 904-796-7211, ext. 4326

Sincerely,


Mark Haberman, Hydrologist
Tampa Permitting Department
Resource Regulation



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



Bob Perry, Hydrologist
Tampa 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
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