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Memorandum

DATE: October 21, 2003
TO: Interested Media
RE: Letter to U.S. Environmental Protection Agency Region IV Administrator James Palmer regarding the Ocean Dispersal of Treated Piney Point Water

Please find attached a letter from Allan Bedwell, Florida Department of Environmental Protection Deputy Secretary for Regulatory Programs, to U.S. Environmental Protection Agency Region IV Administrator James Palmer requesting an extension of the emergency permit for ocean dispersal of treated water from the abandoned Piney Point phosphate plant.

If you need further information, please call the Department’s Press Office at (850) 245-2112.

###

October 21, 2003

Mr. James Palmer
Administrator
Region IV
United States Environmental Protection Agency
61 Forsyth Street, S.W.
Atlanta, GA 30303-8960

Re: Emergency Permit No. OD-03. Request for Time Extension

Dear Mr. Palmer:

The Florida Department of Environmental Protection requests an extension of the Emergency Permit authorizing ocean dispersal of treated water from the abandoned phosphate plant at Piney Point. Additional time will allow the Department to disperse the total volume of treated water approved by the Environmental Protection Agency earlier this year.

Florida’s primary concern is averting a catastrophic accident at Piney Point. The risk to the public and the environment will remain until the abandoned phosphate plant is permanently closed. According to an analysis by an independent engineering firm, an additional 3 to 4 million gallons of water per day must be removed over the next four to five months to provide enough storage capacity to begin closing the site. Attached is a copy of their report.

Since ocean dispersal commenced, the barge, New York, has removed over 120 million gallons of treated water from the site. Although more than 600 million gallons of water was safely removed over the last year, unprecedented rainfall generated 300 million gallons of additional wastewater -- well above the amount anticipated. The above predicted rainfall set our efforts back significantly, resulting in a net gain in site storage equal only to about 85 million gallons.

Over the last 2 years, trucks have removed more than 120 million gallons of process water. Nearby communities have accepted a total of 46.5 million gallons of the treated water (City of Tampa, 22 million gallons; Manatee County, 23 million gallons; Hillsborough County, 1.5 million gallons). Companies have also accepted more than 77 million gallons of the process water (CF industries, 43.5 million gallons; Cargill, 32.7 million gallons; FPL, 0.9 gallons). The use of reverse osmosis technology, a first for this type of wastewater, has removed over 160 million gallons. Because of this success, the Department is increasing its capacity.

An independent scientific analysis, as well as the Department’s monitoring, confirms that the highly treated water is not causing adverse impacts to marine water quality or marine life. The Department, therefore, views continued ocean dispersal as a feasible component of the multi-faceted operation to safely and quickly remove water from the site.

Using the barge New York, the Department expects to disperse an estimated 200 million gallons of water by the current permit expiration, November 30, 2003. Because recent plant improvements have increased our capacity to treat water, the Department is securing a second vessel, which will increase the volume by an estimated 50 million gallons.

Extending the permit will allow the Department to remove an additional 70 to 75 million gallons of water per month from the site, reducing the volume of water that is discharged into Bishop Harbor and allowing closure activities to resume.

To meet the requirements for closure without an extension for ocean dispersion, the Department may need to discharge as much as 3 million gallons per day of highly treated water into Bishop Harbor during December and January. While advanced treatment technology called “break-point chlorination” and improvements to the existing ammonia removal ponds should reduce the nutrient content of discharges to levels below the recommended loading capacity, the Department prefers to continue ocean dispersion to alleviate the volume of discharges into Tampa Bay.

Thank you for your consideration of this request.

Sincerely,

Allan Bedwell
Deputy Secretary
Regulatory Programs and Energy

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Last updated: June 15, 2004

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