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					                                            FACT SHEET
                                                FOR
                          FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION
                               INDUSTRIAL WASTEWATER FACILITY PERMIT


NPDES Permit No.: Fl0300195-004 (MINOR)             Permit Writer: Kelli Edson

Application No.: 0300195-002
Application Date: September 10, 2008

1. SYNOPSIS
    a. Name and Address of Applicant:
       South Florida Water Management District
       3301 Gun Club Road
       West Palm Beach, FL 33406

      For: Stormwater Treatment Area 3/4 (STA-3/4)

   b. Type of Facility:

      Primary SIC: 3822 Environmental Controls
      Secondary SIC: Standard Industrial Codes not available

      The facility is a designed and engineered flow through marsh system which utilizes natural biological processes to remove
      excess phosphorus in stormwater runoff from the S-7/S-2 and S-8/S-3 Basins. STA-3/4 is a stormwater management
      system (SMS) as defined in 373.403(10), F.S. At the present time, vegetation improvements and enhancements are
      underway in accordance with the Everglades Protection Area Tributary Basins Long-Term Plan for Achieving Water
      Quality Goals (Long-Term Plan), to optimize performance as needed to achieve the phosphorus criterion in the Everglades
      Protection Area (EPA). Enhancements shall be completed in accordance with the schedules in the Long-Term Plan, and in
      the accompanying Administrative Order (AO-015-EV). Additional enhancements to STA-3/4 may occur as part of the
      adaptive implementation process envisioned in the Long-Term Plan.

   c. Design Capacity of Facility:

      STA-3/4 is designed to provide 16,543 acres of effective treatment area and treat a long-term average of approximately
      576,000 acre-feet of stormwater runoff annually. The inflow to STA-3/4 consists almost entirely of agricultural
      stormwater runoff and regulatory releases from Lake Okeechobee, and as such, varies considerably on a daily, monthly,
      seasonal, and annual basis. The STA may be subject to an increase in inflow source loads beyond what was anticipated in
      the design of the facility or due to meteorological variability or violations of federal, state or District rules, laws,
      regulations or permits by persons other than the District.

   d. Applicant’s Receiving Water

      Monitoring Group D-001: Discharges to L-5 Canal, Class III Fresh waters, via the G-376 A-F structures.
      Latitude: 26° 20’ 08” N Longitude 80° 33’ 21” W
      Monitoring Group D-002: Discharges to L-5 Canal, Class III Fresh waters, via the G-376 A-F structures.
      Latitude: 26° 20’ 06” N Longitude 80° 34’ 42” W
      Monitoring Group D-003: Discharges to L-5 Canal, Class III Fresh waters, via the G-379A-E structures.
      Latitude: 26° 20’ 07” N Longitude: 80° 36’ 26” W
      Monitoring Group D-004: Discharges to L-5 Canal, Class III Fresh waters, via the G-379 A-E structures.
      Latitude: 26° 20’ 23” N Longitude: 80° 37’ 25” W
      Monitoring Group D-005: Discharges to L-5 Canal, Class III Fresh waters, via the G-381 A-F structures.
      Latitude: 26° 21’ 35” N Longitude: 80° 38’ 55” W
      Monitoring Group D-006: Discharges to L-5 Canal, Class III Fresh waters, via the G-381 A-F structures.
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 2 of 11

        Latitude: 26° 21’ 48” N Longitude: 80° 40’ 24” W

     e. Associated Documents

          The following documents are associated with the NPDES Permit No. FL0300195-004

        1. Administrative Order (Order) AO-015-EV- This Order details a compliance schedule for achieving the conditions set
            forth in NPDES Permit No.: FL0300195-002 and EFA Permit No.: 0192895-013.

        2. Exhibit A1: Technical Support Document: Derivation of the Water Quality Based Effluent Limit (WQBEL) for
        Phosphorus in Discharges to the Everglades Protection Area.- This document establishes the WQBEL for discharges to the
        Everglades Protection Area.

        3. Exhibit B: Technical Support Document for the STA-3/4 TBEL2- This document establishes TBEL limits and
        identifies factors which may impact flows and loads associated with the treatment system,

        4. Exhibit C: Dissolved Oxygen Site Specific Alternative Criteria Technical Support Document 3- This document
        establishes an alternative criterion for dissolved oxygen in the EPA pursuant to Subsection 62-302.800, F.A.C.

        5. Exhibit D: Stormwater Treatment Area 3/4 Pollution Prevention Plan (PPP)4- The PPP provides a summary of
        operations for STA-3/4, and describes factors which may impact those operations.

        6. Exhibit E: The Everglades Protection Area Tributary Basins Long-Term Plan for Achieving Water Quality Goals 5- The
        Long-Term Plan includes structural, vegetative, and operational improvements and enhancements which will aid in the
        optimization of the hydraulic distribution and phosphorous removal of the project. The Long-Term Plan also includes
        detailed schedules associated with the identified improvements and enhancements. Revisions to the Long-Term Plan are
        available on the District’s webpage for the Long-Term Plan: http://www.sfwmd.gov/sta.

        7. Exhibit F: Treatment Wetlands6- This document provides background into the characteristics of wetland treatment
        systems.

        8. Exhibit G: STA 3/4 Operations Plan

     f. Facility Description
        The individual Everglades Construction Project (ECP) components included in STA-3/4 are as follows: the G-371 and G-
        373 Diversion Works, Inflow Pump Stations G-370 and G-372, Supply Canal Works, Interior Treatment Works, associated
        Long-Term Plan Enhancements, Public Use Facilities, West L-5 Canal Enlargement, Crown Castle Tower Site Flood
        Improvements, PSTA demonstration project, Discharge Canal, the Seepage Collection System and US 27 Bridges..
        Collectively, these components are referred to as the District’s STA-3/4 Project (STA-3/4).


        -Diversion Works
        The G-371 Structure is installed in the North New River Canal downstream of G-370 and diverts canal flows to Inflow
        Pump Station G-370, located in the northeast corner of STA-3/4. This structure also allows Pump Station S-7, located in
1
  Exhibit: Garry Payne, Kenneth Weaver, and Frank Nearhoof, Florida Department of Environmental Protection, XXXXXXX, 2008.
2
  Exhibit: Goforth, G., N. Iricanin, S. Hill, S. Xue, T. Piccone, F. Nearhoof, and Ken. Weaver, Technical Support Document for the STA-3/4 TBEL. October 20,
  2008.
3
   Exhibit: Weaver, Ken, Florida Department of Environmental Protection, Dissolved Oxygen Site Specific Alternative Criteria Technical Support Document,
   January 2004.
4
  Exhibit: South Florida Water Management District, Stormwater Treatment Area 3/4 Pollution Prevention Plan, December 2003 and subsequent revisions.
5
  Exhibit: South Florida Water Management District, Everglades Protection Area Tributary Basins Long-Term Plan for Achieving Water Quality Goals, October
   2003 and subsequent revisions.
6
  Exhibit: Kadlec, Robert and Robert Knight, Treatment Wetlands, Boca Raton, pg. 474-475, 1996.




                                                                             2
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 3 of 11

      the southeast corner of STA-3/4, to be used as an outflow pump station. Under normal STA-3/4 operating conditions, G-
      371 will be in the full-closed position. G-371 can be operated to move water from the WCAs to the EAA for water supply.
      G-371 may also be operated for any of the following conditions:

      a) Full or partial diversion around STA-3/4 during runoff events in the S2/S7 Basins;
      b) Full or partial diversion around STA-3/4 during periods of regulatory releases from Lake Okeechobee to the North
         New River Canal;
      c) Diversion around STA-3/4 during periods of water supply releases from Lake Okeechobee intended for delivery to
         communities and other users in Broward county via the North New River Canal; and
      d) Full or partial diversion around STA-3/4 when all or portions of the STA are unavailable due to maintenance or other
         conditions, including but not limited to when interior water conditions may damage existing treatment cell marsh
         vegetation.

      The G-373 Structure is installed in the Miami Canal downstream of G-372 and diverts canal flows to Pump Station G-372.
      This structure also allows Pump Station S-8, located 8 miles west of the southwest corner of STA-3/4, to be used as an
      outflow pump station. Under normal STA-3/4 operating conditions, G-373 will be in the full-closed position. G-373 can
      be operated to move water from the WCAs to the EAA for water supply. G-373 may also be operated for any of the
      following conditions:

      a) Full or partial diversion around STA-3/4 during runoff events in the S3/S8 Basins;
      b) Full or partial diversion around STA-3/4 during periods of regulatory releases from Lake Okeechobee to the Miami
         Canal;
      c) Diversion around STA-3/4 during periods of water supply releases from Lake Okeechobee intended to delivery to
         communities and other users via the Miami Canal; and
      d) Full or partial diversion around STA-3/4 when all or portions of the STA are unavailable due to maintenance or other
         conditions, including but not limited to when interior water conditions may damage existing treatment cell marsh
         vegetation.

      - Inflow Works

      Untreated water from the North New River and the Miami Canals is directed into the STA at its north boundary by means
      of Pump Stations G-370 and G-372.

      1.   Inflow Pump Station G-370 is one of two inflow pump stations. G-370 draws water from the North New River Canal,
           and has a design capacity of 2,775 cfs. The 35-year period of record estimated a long-term annual average inflow of
           approximately 258,000 acre-feet.

      2.   Inflow Pump Station G-372 is the second inflow pump station for the project, G-372 draws water from the Miami
           Canal and has a design capacity of 3,700 cfs. The 35-year period of record estimated a long-term annual average
           inflow of approximately 318,000 acre-feet.

      - Supply Canal Works
      The STA-3/4 Supply Canal begins downstream of G-372 and is adjacent to the north boundary of the Holey Land Wildlife
      Management Area and joins the Inflow Canal at the northwest corner of the STA. The G-383 Structure provides flexibility
      in managing incoming flows before distribution into the treatment cells. The G-383 Structure is situated in the Inflow
      Canal immediately north of the intersection of the Inflow Control levee with Interior Levee 1. This structure is normally
      open and provides operational flexibility, such as controlling flow between the Eastern flow-way and the Central and
      Western flow-ways.

      - Interior Treatment Works
      STA-3/4 is located between US 27 to the east and the Holey Land Wildlife Management Area to the west in Broward
      County and Palm Beach County. The facility consists of a wetland marsh system which utilizes biological treatment
      technology in the removal of nutrients from stormwater entering the facility. Wetland vegetation within STA-3/4 is
      managed in conjunction with hydrologic operations to maintain optimal performance levels within the facility. The



                                                              3
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 4 of 11

      structural works (See Figure 1) involved in the operation of STA-3/4 consist of inflow and discharge conveyance canals,
      treatment cell divide levees, gravity flow control structures, pump stations, and independent treatment paths (Flow-ways 1-
      3).

      Stormwater is pumped into the Supply Canal via Inflow Pump Stations G-370 and G-372. Inflow to the north cells is
      controlled by a series of gated hydraulic structures, G-374 A-F, G-377 A-E and G-380 A-F, which allow water to pass
      from the Inflow Canal to the treatment cells. The hydraulic gradient is such that water flows in a southerly direction within
      the cells. The treatment works consist of three parallel flow-ways. The Eastern flow-way treats inflows to the STA through
      treatment Cells 1A and 1B in series and subsequently releases treated water from Structures G-376 A-F into the Discharge
      Canal. The Central flow-way treats inflows to the STA through treatment Cells 2A and 2B in series, releasing treated
      water through Structures G-379 A-E into the Discharge Canal. The Western flow-way, treats inflows to the STA through
      Cells 3A and 3B, releasing treated water through the G-381 A-F Structures into the Discharge Canal.

      Enhancements to the Interior Treatment Works include the addition of 3 small forward-pumping stations along the interior
      levees between cells in series to permit withdrawal from upstream emergent marsh cells to maintain stages in the
      downstream SAV cells. Supplemental flows can be transferred from Cell 2A to Cell 1 A through Structure G-382A, and
      between Cell 2A and Cell 3B through Structure G-382B.

      -Discharge Works
      The Eastern Discharge Canal (EDC) is located at the southern boundary of the Eastern and Central flow-ways and is
      connected to the Griffin Borrow Pits at its western end. The eastern end of the EDC connects to the L-5 Borrow Canal,
      west of the existing Pump Station S-7. The Western Discharge Canal (WDC) is located along the southern boundary of the
      Western flow-way and the western boundary of the Central flow-way. The northern end of the WDC starts at the Western
      flow-way and joins the Griffin BorrowPits, which in turn connects to the L-5 Borrow Canal.

      Treated water from STA-3/4 is discharged into the L-5 Borrow Canal from the G-381 A-F, G-379 A-E and G-376 A-F
      Structures, and then released to WCA-2A or WCA-3A. Pump Station S-7 discharges to WCA-2A; Structure S-150 and
      Pump Station S-8 discharge to WCA3A, and Pump Station G-404 discharges to western WCA-3A via the L-4 Borrow
      Canal, the South L-4 Levee Gap and L-3 extension canal. Pump Station G-404 is part of the STA-5 permit, but functions
      to move water from both STA-3/4 and 5. Treated water from STA-3/4, once discharged into the L-5 Canal can also be
      released to WCA-3A via Structure S-150 when water levels in the North New River Canal are higher than the downstream
      water level in WCA-3A.

      - Seepage Collection Works
      Seepage control is accomplished by routing water collected by the project’s north seepage collection canal back to the
      inflow Pump Stations G-370 and G-372 via (3) 75 cfs seepage return pumps at each station. Seepage collected is routed
      back to the treatment cells by the inflow canal system.

      Construction associated with the EAA A-1Reservoir project required backfilling of a section of the seepage collection
      canal along the east side of Holey Land Wildlife Management Area (WMA) and connection of the perimeter areas to the
      STA-3/4 seepage collection canal for stormwater purposes. The G-370 seepage return pumps control the water levels for
      the section of the north seepage collection canal along STA-3/4; G-372 controls water levels along the north side of Holey
      Land. Water levels within the reservoir perimeter areas are controlled through weirs or ditch plugs with the seepage return
      pumps also serving as stormwater pumps during larger events


      -US 27 Bridges
      A canal crossing at US 27 conveys water from the North New River Canal (L-18) to the G-370 Inflow Pump Station at
      STA-3/4. This section of the G-370 intake canal allows water to pass from the eastern side to the western side of US 27.
      Correspondingly, northbound and southbound bridges were previously constructed to carry US 27 traffic over the canal
      section.

      -Recreational Facilities




                                                                4
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 5 of 11

        In fulfillment of the public access and recreation requirements of the EFA, Paragraph 373.4592(4)(a) F.S., and as further
        described in Paragraph 373.1391(1)(a) F.S. and (b), recreational facilities were constructed at STA-3/4. The recreational
        facilities were designed to ensure compatibility with the restoration goals of the ECP and the water quality and
        hydrological purposes of the STAs. The Harold A. Campbell Public Use Area, is an STA-3/4 recreational facility, located
        south of and adjacent to Treatment Cell 2B. This location minimizes public access past the STA’s water control structures
        and data equipment. The Harold A. Campbell Public Use Area includes road improvements, a boat ramp, an asphalt
        parking area, an information kiosk, landscaping, a multi-purpose bridge and a composting toilet. A second STA-3/4
        public use facility is located on an approximately 1-acre upland site in the southeastern portion of STA-3/4. The public use
        facility includes vehicle barrier gates, access road, guard rails, parking area, fencing, an information kiosk, a composting
        toilet and landscaping

        Structural, Operational and Vegetation Enhancements
        In accordance with the EFA, the District has completed structural, operational and vegetation enhancements to STA-3/4
        designed to achieve compliance with state water quality standards. These are described in detail in the District’s Long-
        Term Plan and are summarized below:

               Subdivision of Cell 3
               An overhead power distribution line extended along the new levee across Cell 3
               Construction of new small forward-pumping stations along the interior levees
               Treatment of vegetation
                 Herbicide treatment of Cells 1B, 2B, and 3B for removal of emergent macrophyte vegetation to permit
                     development of SAV
               Acceleration of vegetation recruitment
                 Inoculation of SAV from STA-2 into STA-3/4 by helicopter to accelerate vegetation recruitment
               Full-scale PSTA demonstration project
               Conversion of Cell 1B from an emergent marsh to an SAV marsh; vegetation conversion is ongoing and is
                 scheduled to be complete by December 2011.


     -Crown Castle Tower Site Flood Improvements
     Crown Castle Tower Site Flood Improvements provide positive drainage outfall for the site, through two 24-inches culverts
     under the L-5 Levee drain into the L-5 Canal. The culverts are at invert elevation of 9.0 NGVD and have flap gates on the
     discharge end to prevent water from the L-5 Canal from backing up through the culverts. To facilitate routing the water to the
     culverts, a ditch that runs north/south on the site allows the water from the tower area to drain to the L-5.

     STA Operations Summary
     Assuming normal operating conditions, the following treatment path culminates with discharge into the L-5 Borrow Canal,
     and is then released into WCA-2A via S-7, or to WCA-3A via S-150 and/or S-8. STA-3/4 provides treatment for inflows from
     the Miami Canal (via Pump Station G-372) and the North New River Canal (via Pump Station G-370). These inflows are
     comprised of contributions from a number of sources, including: Agricultural runoff and discharges from the North New River
     Canal Basin (S-7/S-2 Basin); agricultural runoff and discharges from the Miami Canal Basin (S-8/S-3 Basin); Lake
     Okeechobee; Agricultural runoff and discharges from the C-139 Basin (episodic inflows through Structure G-136 and the L-
     1E Canal to the Miami Canal); Pumping Station S-236 discharges to be diverted from Lake Okeechobee to the Miami Canal
     for delivery to STA-3/4. Water is directed along a southerly flow path through a series of flow-ways for treatment, prior to
     discharging through a series of structures to the Discharge Canals.


2.    BASIS FOR EFFLUENT LIMITS AND MONITORING REQUIREMENTS
      The following table provides the basis for Part I.A. provisions.




                                                                 5
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 6 of 11

                                              Table 1. Basis for Provisions of Part I.A: Outfall D-001:

     Parameter                          Units       Limit                  Statistical Basis           Rationale
     pH                                 SU 6.0                 Daily Minimum                           Rule 62-302.530(52), F.A.C.
     pH                                 SU 8.5                 Daily Maximum                           Rule 62-302.530(52), F.A.C
     Phosphorus, Total (as P)           ppb17 ppb7 8           Report                                  Section 373.4592, F.S; Rule 62-302.540
                                           See I.A.5                                                   F.A.C.; Rule 62-302.530(48)(b), F.A.C.
                                           See I.A.6
     Oxygen, Dissolved (DO) mg/l           See I.A.7 and See attached                                  Rule 62-302.800, F.A.C.
                                           Report              DO SSAC
     Flow                       CFS        See I.A.6           Daily Average
     The following were used as the basis of the permit limitations/conditions:

     A. FAC refers to various portions of the Florida Administrative Code.
     The effective dates of FAC Rule Chapters cited in the permit and in this document are as follows:

     Chapter                           Effective Date
     62-4                              04-21-09
     62-160                            12-03-08
     62-302                            04-02-08
     62-620                            02-17-09
     62-650                            12-26-96
     62-660                            05-10-05

     B. FS refers to various portions of the Florida Statutes

     C. CFR refers to various portions of the Code of Federal Regulations, Title 40

     D. BPJ refers to Best Professional Judgment



     The Department has concluded that the most appropriate way to measure whether the STA-3/4 project is achieving the design
     goal for phosphorus requires consideration of the known characteristics of wetland treatment systems. Wetland treatment
     systems reach optimal performance only after initial periods called “start-up” and “stabilization” phases. This conclusion is
     consistent with the findings of Kadlec and Knight (Exhibit F, pg. 474 – 475).

     As treatment cells are constructed and managed to optimize performance, they undergo two operational phases, each with
     different levels of performance. At the present time, there is no plan for expanding the STA-3/4 facility beyond its current
     footprint; therefore, the initial start-up phase maynot be applicable for this facility and is included only as informational
     material.

           Start-Up Phase. During the initial Start-Up Phase of a new cell or new flow-way,, the permittee shall monitor
           phosphorus concentrations within the facility to demonstrate that the project is achieving a net reduction in phosphorus.


7
 Monitoring results for this parameter shall be reported as a monthly average and as an annual average. The “monthly average” is a flow-weighted mean of the
weekly effluent samples. The “annual average” shall be computed for each water year (May - April) and is equal to the flow-weighted mean concentration for the
water year.

8
  The South Florida Water Management District is currently preparing a plan of study in accordance with 62-650 F.A.C. in an effort to develop a more
comprehensive Water Quality Based Effluent Limit. Pending Department approval of the methodology and subsequent results of the plan of study, the
Department may establish a revised WQBEL as a major modification to this permit prior to December 31, 2016.



                                                                               6
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 7 of 11

        Portions of STA-3/4 may operate independently of each other. Under those circumstances, Start-Up Phase operation and
        monitoring within the treatment area shall be performed as follows:

             i. Establishment of Marsh Vegetation. The permittee shall manage water depths in the treatment cells to
                facilitate the recruitment of marsh vegetation in accordance with the Operations Plan, which may include
                recirculating waters within the STA.

            ii. Start-Up Monitoring. On a weekly basis, the permittee shall monitor total phosphorus at the upstream side of
                inflow structure(s). Total phosphorus shall also be monitored on a weekly basis on the upstream side of the
                outflow structures.

            iii. Phosphorus Start-Up Test. The Phosphorus Start-Up Test for an individual flow-way or cell is based on when
                 the above samples demonstrate, over a four-week period, a net reduction in phosphorus occurs. This net
                 reduction shall be deemed to occur when the 4-week geometric mean total phosphorus water column
                 concentration from samples collected at the applicable outflow structures is less than the 4-week geometric
                 mean total phosphorus water column concentration collected at the applicable inflow structure(s).

            iv. Discharge Operations. Discharge operations, from an individual flow-way or cell that has passed the
                Phosphorus Start-Up Test described above, may commence once Initial Start-Up Phase documentation and all
                supporting data and analyses are submitted to the Department via regular or electronic mail. For flow-ways that
                have not met these tests within six months after issuance of the permit, the permittee shall submit status updates
                regarding progress toward and identifying strategies and timelines to achieve this test.

             v. Initiation of Flow-through (Stabilization and Routine Operation) Discharges and Monitoring. Once flow-
                through operations begin, the permittee shall initiate routine water quality monitoring for that flow-way
                consistent with the monitoring program described in Part I.A.1-7 of the NPDES permit.

            Flow-through Operations: There are two categories of flow-through operations:

                i. Stabilization–During the Stabilization Phase, treatment vegetation is maturing and STA performance will
                generally improve toward achieving the permit effluent limit. However, the overall performance of the STA is
                extremely difficult to evaluate and predict. It is anticipated that the treatment vegetation will require one to three
                years after flow-through operations begin for the affected cells to achieve optimal performance. During the
                stabilization phase the permit effluent limitation shall apply. Once the facility achieves the permit effluent
                limitation it shall enter the Routine Operations Phase.

                ii. Routine Operations Phase – Occurs subsequent to the aforementioned stabilization phase. During the routine
                operations phase, discharges from the STA are achieving the permit effluent limitation as described in Section 6
                below.

3.   ADDITIONAL MONITORING REQUIREMENTS

      In addition to the monitoring requirements set forth in Section I.A. of the permit, the following site specific monitoring
      requirements are also included in the accompanying Order.

      As a condition of the Order AO-015-EV, all flows, including those diverted through the G-371 and G-373 Diversion
      Structures shall be monitored and reported consistent with the requirements of the permit. The submitted notification shall
      include a description of the circumstances related to the diversion and a projection of the anticipated duration of the
      diversion. All diversions occurring through the G-371 and G-373 Diversion Structures will be monitored for the
      parameters listed in the table below.




                                                                 7
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 8 of 11

                                          Table 3. Required Monitoring for All Diversions
        Parameter/ Station                         Units       Sample Type                        Frequency
        Total Phosphorus collected at G-371 and    mg/l        Grab                               Weekly if Flowing
        G-373 Gated Spillways
        Flow at G-371 and/ or G-373                CFS         Calculated                         Daily Average

       As a condition of the associated Administrative Order, the District is required to provide an annual assessment as to
       whether the facility is operating within or outside the operational envelope. It is assumed that the facility will operate
       routinely around the average values identified within STA 3/4 Operations Plan Exhibit G. In order to provide the
       Department with a tool for monitoring operation within this “operational envelope”, the District shall submit an assessment
       based on annual inflow volumes and phosphorus loads in comparison to the corresponding average flow and load values
       contained in the operational envelope (See Exhibit G). If the annual inflow volumes or phosphorus loads exceed the
       corresponding average values of the operational envelope during an annual compliance period, the District shall conduct a
       review of potential causes and include this review in the annual report.

       In addition to the operational envelope requirements of the Order, the permit requires that if annual inflow volumes or
       phosphorus loads exceed the corresponding maximum values of the operational envelope during an annual compliance
       period, the District shall conduct a review of potential causes. This review shall include a comparison of the relationships
       between rainfall, runoff, and phosphorus loads from the compliance year with the rainfall/runoff/load relationships derived
       from historical data.

4.   REQUESTED VARIANCES OR ALTERNATIVES TO REQUIRED STANDARDS

     Pursuant to the Everglades Forever Act (EFA, Section 373.4592(4)(e), F.S.), the Department and the District must evaluate
     existing water quality standards applicable to the EPA and Everglades Agricultural Area (EAA) canals. Annual assessments
     of the water quality standards within the EPA determined that DO concentrations below the current Class III standard of 5
     mg/L (62-302.530, F.A.C.) commonly occurred in all areas of the EPA. These frequent excursions below the DO standard
     were not unexpected since it is widely recognized that DO concentrations in macrophyte dominated wetlands are normally
     low due to natural marsh processes. In response to these characteristics, the Department adopted the Everglades Marsh
     Dissolved Oxygen Site Specific Alternative Criteria (DO SSAC) which was adopted by Secretarial Order on January 26,
     2004 and approved by the U.S. Environmental Protection Agency as a revision to the Florida’s water quality standards on
     June 16, 2004. Compliance with the DO SSAC shall be evaluated annually, and reported consistent with the requirements of
     Section I.E. 7 of the permit, using a statistical analysis to compare DO levels within the marsh to predicted model values.
     The specific methods for determining compliance are set forth in the DO SSAC (Exhibit C). Discharge concentrations from
     the facility will be assessed annually to determine whether discharges may have influenced an individual marsh site(s) by
     comparing marsh data, historical data and monitoring information for dissolved oxygen required in table I.A.1.



5.   ADMINISTRATIVE ORDER AND PERMIT SCHEDULES

       This permit is accompanied by an Administrative Order (Order) AO-015-EV, effective XXXXXX, 2009 which includes a
       schedule of compliance. This Order is hereby incorporated by reference.

       While significant reductions of phosphorus loads in water delivered to the EPA are anticipated to continue improving along
       with technological advancements, the Department recognizes that additional time is required in order to further optimize
       the STA-3/4 facility and develop and implement future phosphorus reduction measures (if necessary) in order to achieve
       the effluent limit in the permit. Based on information collected to date identifying performance levels of the ECP
       components, the ongoing planning and design of regional water management projects, and the mechanism for identifying
       future improvements and enhancements through the Process Design and Engineering (PDE) component of the Long-Term
       Plan, the Department has determined that the issuance of the accompanying Order is necessary to provide the relief
       required for the continued operation of the STA-3/4 facility. The accompanying Order provides a 7 year compliance
       schedule, until December 31, 2016, for discharges from STA-3/4 to come into compliance with the water quality based



                                                                 8
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 9 of 11

      effluent limit (See Exhibit A). Pending Department concurrence that additional time is required for completion of the
      projects identified in Paragraph 19 of the accompanying Order and/or upon finding that additional projects are necessary in
      order for the District to achieve compliance with the effluent limit in the permit, the conditions set forth in the
      accompanying Order may be extended until December 31, 2016.

      Pursuant to Subsection 403.088(2)(f), F.S, the Order accompanying this permit establishes a schedule for achieving
      compliance with all permit conditions. The Order establishes schedules for the completion of vegetation enhancements,
      reporting, compliance with permit conditions from transitional effects occurring as a direct result of vegetation
      enhancements to the facility and/or any major event that effects the structural integrity of the facility or section(s) of the
      facility, and schedules for the planning and design of regional water management projects which will directly affect the
      STA-3/4 facility. In addition, the Order recognizes the permittee’s inability to achieve the established phosphorus water
      quality standard and thereby provides relief in the form of a technology based effluent limit (TBEL, See Exhibit B).

      40 C.F.R. 122.41(l)(2) and General Condition 17 of the permit require that the permittee give advance notice to the
      Department of any planned changes in the permitted facility or activity which may result in noncompliance with permit
      requirements. Since it is expected that implementation of the Long-Term Plan or any planned maintenance activities may
      have adverse short-term impacts on the facility's performance, the permit and Order require the permittee to provide the
      Department with a description of the anticipated activities; the estimated length of anticipated short term performance
      impacts, to include dates and times; and, strategies and timelines for the facility to achieve optimal performance.

6.   PROPOSED EFFLUENT LIMITS

      Section 373.4592(10), F.S., of the EFA requires the Department and the permittee to take such action as may be necessary
      to implement the Pre-2006 projects and strategies of the Long-Term Plan by December 31, 2006, so that water delivered to
      the EPA achieves state water quality standards, including the phosphorus criterion. The Long-Term Plan is a
      comprehensive program of source controls, STAs (including STA-3/4), and regulatory programs which will work with
      integrated Comprehensive Everglades Restoration Program (CERP) projects to achieve phosphorus reductions for
      discharges to the EPA. The October 27, 2003 Long-Term Plan and subsequent revisions, contain detailed schedules of
      improvements and enhancements that were identified as part of an adaptive management process. These revisions
      identified several structural, vegetative, and operational enhancements for STA-3/4 that will aid in the optimization of the
      hydraulic distribution and phosphorous removal of this project. The Post 2006 improvements, enhancements, and
      strategies, in conjunction with the Pre-2006 projects, will continue being developed through the Long-Term Plan process to
      further optimize the facility’s phosphorus reduction capabilities. The Department has determined that the improvements
      and enhancements identified for STA-3/4, through the iterative adaptive implementation process contained within the
      Long-Term Plan, are the most environmentally appropriate and expeditious means of achieving compliance with the
      phosphorus criterion in the EPA. In addition to the internal enhancements, the phased implementation of the Everglades
      restoration program(s) have numerous regional water management projects underway that will influence the flows and
      phosphorus loads entering STA-3/4, and therefore its performance, over the life of the 5-year permits (2009-2014), and
      beyond.

      In order to satisfy requirements of the EFA, the Department has utilized the methodology presented in Exhibit A to derive
      a Water Quality Based Effluent Limit (WQBEL) for phosphorus, herein also referred to as the permit effluent limitation or
      permit effluent limit. The WQBEL will be applied in all permits requiring discharges to the Everglades Protection Area
      (EPA) to assure that the phosphorus criterion set forth in Chapter 62-302.540, F.A.C. will be achieved in the downstream
      marsh. The derived WQBEL is expressed as a maximum annual flow-weighted mean (FWM) TP concentration that is
      equivalent to the phosphorus criterion, which is expressed as a long-term geometric mean concentration of 10 ppb. In
      addition, the WQBEL contained within this permit satisfies previous conditions within similar EFA and NPDES permits
      requiring the Department to establish a WQBEL prior to December 31, 2010.

      Consistent with the Long-Term Plan and Rule 62-302.540(5)(d), F.A.C.., a TBEL for phosphorus, also referred to as the
      interim effluent limit, has been derived in accordance with state rules, and is consistent with the Federal guidelines for best
      available technology economically achievable (BAT) set forth in 40 CFR Subsection 125.3(d). During Flow-through
      Operations discharges from STA-3/4 via the G-381 A-F, G-379 A-E and G-376 A-F Structures shall meet the TBEL in
      accordance with the accompanying Order. The test for determining achievement of the STA-3/4 TBEL is set forth in



                                                                 9
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 10 of 11

      Order AO-015-EV which accompanies this permit. The Technical Support Document for the STA-3/4 Technology Based
      Effluent Limit (Goforth et al., 2008), further explains the derivation of the STA-3/4 TBEL, when/if individual interim
      period limits apply, and factors which may impact flows and loads associated with the treatment system

      Until such time as the facility can achieve the WQBEL or the Order expires, discharges from STA-3/4, via the G-381 A-F,
      G-379 A-E and G-376 A-F Structures, shall meet the TBEL identified in the Order accompanying this permit. The TBEL
      shall be revised as appropriate, consistent with the iterative implementation of BAPRT and 62-620.620(3), F.A.C., until
      such time that the TBEL becomes consistent with the WQBEL established to achieve the numeric phosphorus criterion in
      the Everglades Protection Area. This is consistent with the requirements of Clean Water Act (CWA) Section 301(b)(1)(C)
      and 40 Code of Federal Regulations (C.F.R.) Part 122.44(d)(5). This is also consistent with Florida's reasonable assurance
      requirements under 62-620.620(1)(g) F.A.C.

      The applicant is being given a reasonable time to comply with the WQBEL through the schedule contained in the attached
      Order. In the interim, compliance with the TBEL is being required. Compliance with the TBEL shall be consistent with
      the provisions of the accompanying Order AO-015-EV. If the permittee achieves effluent levels equal to or lower than the
      WQBEL prior to the end of that schedule, the permittee will be in compliance with the WQBEL. At any subsequent permit
      renewal, because the WQBEL has been determined to be that effluent limit that is as stringent as necessary to provide
      reasonable assurance that the underlying phosphorus criterion will be met in the Everglades Protection Area, the permit
      will continue to require compliance with that WQBEL. There is no basis under the backsliding provisions of CWA Section
      122.44(l) to require an effluent limit more stringent than the WQBEL, even if the permittee has demonstrated that such
      lower effluent limits can be achieved.

7.    DISCUSSION OF PREVIOUS PERMIT EFFLUENT LIMITS

      Based upon BAPRT, the 1994 Conceptual Design of the ECP identified an initial TBEL for phosphorus at a long-term
      flow-weighted mean of 50 ppb. Pursuant to Section 373.4592(4)(e)2 of the EFA, the Department adopted a numeric
      criterion for phosphorus in the Everglades Protection Area, which was approved by the U.S. Environmental Protection
      Agency (USEPA) on January 24, 2005. The compliance methodology for this criterion was revised and adopted by the
      Department on May 5, 2005, and the revised rule was approved by the USEPA on July 27, 2005.

      Prior to the Everglades Marsh DO SSAC being adopted by the Department, the previous permit was accompanied by
      Administrative Order (AO-007-EV) issued in accordance with Subsection 403.088(2)(e), F.S. During the period of
      operation under the aforementioned Order, sufficient data was collected to determine that natural conditions existed within
      unimpacted areas of the Everglades Protection Area which would preclude the attainment of the Class III DO criterion
      within the water body. In response to these characteristics, the Department adopted the Everglades Marsh DO SSAC
      which was adopted by Secretarial Order on January 26, 2004, and approved by the U.S. Environmental Protection Agency
      as a revision to the State of Florida’s water quality standards on June 16, 2004.

8.    NEW OR EXPANDED DISCHARGES TO SURFACE WATERS: ANTIDEGRADATION INFORMATION

      The Department has determined that operation and maintenance of the project is consistent with the anti-degradation
      requirements of Rules 62-4.242(1) and 62-302.300, F.A.C. and is clearly in the public interest pursuant to Subsection
      373.4592(9)(a), F.S. and the requirements of Rule 62-4.242(2), F.A.C.

9.    EFFECTS OF SURFACE WATER DISCHARGE ON THREATENED OR ENDANGERED SPECIES

      The Department does not anticipate adverse impacts on threatened or endangered species as a result of permit issuance.

10.   FDEP CONTACT

      Additional information concerning the permit may be obtained during normal business hours from:

      Kelli Edson
      Florida Department of Environmental Protection



                                                              10
Permittee: South Florida Water Management District
Project: Stormwater Treatment Area 3/4
File No.: Fl0300195-002
Page 11 of 11

      Restoration Planning and Permitting Section
      2600 Blair Stone Road, MS 3560
      Tallahassee, Florida 32399-2400
      Telephone No. (850) 245-8052
      Fax No.: (850) 245-8029

11. THE ADMINISTRATIVE RECORD

      STA-3/4 previously operated under Florida Department of Environmental Protection (Department) Permit No. 0192895-
      001 and NPDES Permit No. FL0300195-001. Additional related permits include General Use and Individual Dewatering
      Permit No. 0289306-001, which authorizes dewatering activities associated with the STAs and Non-ECP structures, and
      the U.S. Army Corps of Engineers 404 Permit No. 199404532

      The Department published a Notice of Draft Permits for STA-3/4 on XXXXXX, 2009. The published notice contained
      specific language allowing for a member of the public to request a public meeting, should one be desired. The notice was
      published in the Florida Administrative Weekly and a paper of general circulation for a period of 30 days prior to the
      Department moving forward with the proposed action. As a component of the notice, the Department announced that,
      absent a public meeting request, a public comment period would be available until XXXXXXX, 2009. All public
      comments will be taken into consideration by the Department prior to issuance of these permits.

      The administrative record including application, draft permit, fact sheet, public notice (after release), comments received,
      and additional information is available by writing FDEP or for public inspection during normal business hours at the
      location specified in item 10. Copies will be provided at a minimal charge per page.




12. PROPOSED SCHEDULE FOR PERMIT ISSUANCE


    Application Complete

    Draft permit to Applicant and U.S. EPA
                                                           XXXXX

    Applicant to Publish Public Notice by                  XXXXX

    End of Public Comment Period
                                                           XXXXX

    Notice of Intent to Issue
                                                           XXXXX

    Proposed Issuance Date of Permit                       XXXXX
                                                     -END OF FACT SHEET-




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