ACTION ALERT ACTION ALERT ACTION ALERT ACTION ALERT
Clean Water NOW! Help Promote AWT to Protect Underground Sources
of Drinking Water and Coastal South Florida.
***** Write Today and Attend Meeting *****
The U. S. Environmental Protection Agency is proposing a new rule on injection wells to protect underground drinking water supplies and coastal waters in South Florida. For over 20 years, municipalities in Florida have used underground injection to dispose of secondarily treated sewage from domestic wastewater treatment facilities. Through Class I wells, drilled 1000 to 3000 feet into the ground, this waste was supposed to be confined to deep aquifers and not move upward. Unfortunately, in South Florida, the porous geology of the area allows the injected waste to migrate through cracks and fissures, upwelling into fresh water aquifers and coastal areas that contain coral reefs. This lack of confinement of sewage wastes violates current rules for deep well discharge.
South Florida now injects about 450 million gallons of waste a day into these wells, accounting for about one third of the wastewater generated in the state. South Florida is also entirely dependent upon underground sources for drinking water. Coral reefs, too, need clear, clean nutrient-free waters to thrive and an overabundance of nutrients has led to massive macroalgal blooms along the Palm Beach coast and to the nutrient eutrophication of Florida Bay.
The first option of the proposed new rule would require all facilities using Class I Wells to provide Advance Waste Treatment (AWT) immediately, to clean the water so that it meets primary drinking water regulations and other health based standards before it is injected into the ground. Once treated to this high standard, the increased value of this clean water will encourage reuse so that less effluent is injected into the ground. Reef Relief supports this proposal and, in fact has recommended AWT of sewage waste leading to reuse to protect the coral reef environment since 1995! A second, weaker option would wait 15 years to study the problem before requiring AWT.
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Stand up for clean water now and for our future. Write today. Thank you.
For more information, contact Reef Relief (305) 294-3100
Reef Relief's Official Comments to the EPA:
Nancy H. Marsh
U. S. EPA Region 4
Sam Nunn Atlanta Federal Center
61 Forsyth St., SW
Atlanta, GA 30303
Subject: Revision to the Federal Underground Injection Control (UIC) Requirements for Class I - Municipal Wells in Florida; Proposed Rule.
Dear Ms. Marsh:
The following comments on the above referenced Proposed Rule Change for 40CFR Part 146, which appeared in the Federal Register Vol. 65, No.131 pp.42234-42245 on Friday, July 7, 2000, are provided on behalf of REEF RELIEF, a non-profit membership organization dedicated to preserve and protect living coral reef ecosystems through local, regional and global efforts.
Our organization has been actively involved in addressing the environmental and public health problems of domestic wastewater disposal in south Florida through injection wells since 1994. We were the first organization to recognize and point out the serious problem of effluent migration from shallow wells in the Florida Keys to nearby surface waters and the reef and worked with the State of Florida to address this concern. We have participated with the EPA and State in a variety of forums and workshops to help find a comprehensive solution to the growing problem of municipal wastewater disposal in our unique hydrogeologic region. In the Florida Keys, we have worked with the EPA Water Quality Steering Committee, municipalities, county government and citizens to educate and ensure that Advanced Waste Treatment (AWT) was the standard for any and all new or upgraded facilities dealing with wastewater disposal. Through the years, our message and policy has been simple and consistent - advance treatment of the waste leading to reuse.
It is obvious to us that if the quality of the effluent is raised to meet or exceed primary drinking water standards through advanced treatment, the economic and social value of the treated effluent will lead to its reuse and eventually remove the need for Class I well disposal altogether. With our state's high dependence on underground sources for drinking water (USDW), the high degree of scientific uncertainty of confinement of fluid movement through deep well injection in our unique carbonate geology, and the steady increase in population and demand for water consumption and disposal, it seems the only viable and long-term option available.
We are, therefore, pleased to see that EPA has chosen to pursue this approach in options to this rule change to address fluid movement into USDW. However, there are certain points we wish to make to ensure that the solution to this seemingly technical problem by some, is a more comprehensive, enforceable, and safe method of managing Florida's wastewater disposal and potable water needs for the future. The following comments more specifically address the questions you posed in the Federal Register Notice for the proposed rule change.
Preferred Option
Of the two options proposed by EPA, Reef Relief highly recommends and supports
Option 1-Advanced Wastewater Treatment with Non-endangerment Demonstration.
This option, although initially more costly, essentially addresses the problem of
potential contamination of USDW at the surface, where it can be more cost effectively
monitored and corrected if problems occur, than once the effluent is injected into
the ground. As EPA has so aptly pointed out, because of the complex lithology within
the carbonate rock layers of much of Florida, the porosity and permeability of any
given area cannot be predicted with any high degree of certainty. Therefore, the ability
to use carbonate rocks as injection or confining zones, even with the in-depth hydrogeologic
demonstration requirement considered in Option 2, is problematic. It would be better for
all concerned; the regulators, regulated industry and public, to have the surety and
confidence of moving to AWT and eventual reuse now, than to spend an inordinate amount
of time and energy in hydrogeologic surveys simply to delay the inevitable goal of
AWT by 2015.
The technology exists today to upgrade the many plants to AWT that are in violation or potentially will violate the Safe Drinking Water Act- Part C if allowed to continue to inject secondarily treated sewage. We view this rule change as an interim measure, which if properly implemented, will lead most municipalities to complete reuse of the treated effluent, reducing deep well injection to a backup alternative, if used at all for disposal.
Existing and New Wells
We recommend that this proposed rule should apply to new as well as existing wells.
Given the current knowledge of the existing fluid migration problems, future wells
should only be permitted if AWT and non-endangerment demonstration is applied.
Past experience demonstrates that you cannot ensure that adequate confinement
exists so that fluid movement does not occur in this geology. To think otherwise
will only perpetuate the problem we are now facing.
Pretreatment Requirements
To reduce the burden of treatment for certain industrial contaminates that may
enter a municipal or private wastewater facilities treatment system, we recommend
that EPA and the State of Florida require industrial facilities to provide a
pretreatment program. Such a pretreatment program should ensure that certain
contaminates are removed prior to entering wastewater facility plants. This will
reduce public costs and ensure that certain contaminates are sufficiently removed
at the source to prevent concentrations of the contaminant from severely restricting
potential reuse or entering a USDW to exceed drinking water regulations or other
environmental and health based standards.
We further recommend that EPA require pretreatment as an additional condition of authorization under this rule and to extend the pretreatment standards presently required by the State to injection facilities with less than five million gallons per day (MGD) discharge. Collectively, smaller treatment plants with less flow may be significant contributors of USDW contamination if fluid movement occurs. Pretreatment is also a good precursor to eventual water reuse, even for small discharge facilities.
Rule Applicability
We are pleased to see that EPA has broadly applied this rule to counties in Florida
that may experience fluid movement into USDW as a result of Class I well
municipal injected waste, as well as those counties were wells are now experiencing
fluid movement. Since the majority of Florida's population and much of its anticipated
growth and redevelopment occur in these coastal counties, it is extremely important
that every safeguard be taken in this rule to protect present and future USDW.
In addition, since underground migration of fluid movement could potentially reach and contaminate surficial aquifers and nearshore surface waters along and within these coastal counties, we strongly encourage the adoption of high levels of treatment, reuse and monitoring recommended in these comments for Class I injection wells
Additional Monitoring Requirements
We are encouraged by and support EPA's consideration for more specific monitoring
requirements for the effluent and the ground water than specified in SS. 146.13.
We feel, however, that annual monitoring of wastewater contaminates is not sufficient
to ensure public confidence and safety in the treatment process. We recommend that
quarterly sampling be the minimum standard for permit conditions following initial
effluent characterization. Also, we recommend that other environmental contaminates,
in addition to those regulated under the national drinking water regulations and
other health based standards, be tested for in both the initial characterization
and quarterly effluent monitoring and the ambient/ground water monitoring program.
A complete list of these potential contaminates will be provided to you separately.
Additional monitoring wells should be required in any area where there is a question of fluid migration and the treatment facility has not yet reached the AWT standards recommended below.
Operating Conditions
As mentioned above, we strongly recommend Option 1- advanced wastewater treatment with
a non-endangerment demonstration. We are, however, interested in the time frame and
incentives for facilities to comply with this requirement. We appreciate the time and
cost for municipalities and others to upgrade their present facilities to meet this new
level of treatment and wish to work with you and them to insure that it is accomplished
in a safe and expedient manner.
Regarding levels of AWT for Option 1, Reef Relief recommends that EPA specify treatment to < 10 mg/l Biological Oxygen Demand (BOD) with disinfection and nutrient removal. These standards are routinely met with existing and cost effective technologies in south Florida and should be the minimum level of treatment required in your rule. Other contaminates, for both human health and environmental conditions, should be set and removed from the waste stream prior to injection.
We are particularly concerned about nutrient removal. EPA is now in the process of establishing new national nutrient standards for surface and nearshore waters because of increased levels, both in ground and surface waters, causing deleterious effects to aquatic coastal ecosystems. The fate and effect of increased nutrient loading of ground water through wastewater injection in Florida is poorly studied and understood, but, through fluid migration could pose serious long term problems. We, therefore, recommend that this option (nutrient removal) in the level of treatment be required and specified.
Time Frame for Compliance
In Option 2 there is a specified timeframe for compliance with AWT by 2015. We believe
that Option 1, where AWT is a certainty, should also provide a defined compliance schedule.
This compliance schedule should take into consideration the risk of further migration
and contamination by Class I wells in relation to reasonable provisions for the
wastewater treatment facilities to evaluate all of their municipal wastewater reuse
and disposal options and to plan for any construction of treatment facilities needed.
We believe, however, that 15 years is too long. The municipalities and others can save
much time and money by moving directly to AWT, rater than by conducting the in-depth
hydrogeologic demonstration surveys and partial treatment upgrades, which will inevitably
lead to AWT anyway in Option 2.
Cost of Compliance (environmental and economic)
In your analysis of cost of compliance vs. economic and environmental benefits, we
hope you will include and properly balance the extreme social and economic costs
if Florida's future water supplies and aquatic environment is contaminated and
compromised by continuing unconfined injection vs. the holistic benefits of proper
wastewater management and reuse. We are sure, if properly evaluated, there will be
a net gain to the public by moving forward with Option 1 with the conditions
outlined above.
We thank you for the opportunity to provide these comments on your proposed rule and look forward to working with EPA and others on its successful promulgation and implementation.
Sincerely,
Paul G. Johnson
REEF RELIEF
Board of Director
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