VIEWPOINT: Holley-Navarre wastewater dumping will worsen Sound pollution
by: Linda Young, Florida Clean Water Network
Editor’s Note: Holley Navarre Water System is proposing to install a Rapid Infiltration Basin (RIB) system near Williams Creek and Santa Rosa Sound, in Navarre. The system, composed of percolation ponds, is designed to dispose of treated effluent from the existing wastewater treatment plant by seeping it into the ground. Santa Rosa Commissioners tabled a decision on permitting the facility at the April 28 meeting to allow more study time.
Linda Young, President of the Florida Clean Water Network, provided the following correspondence to Santa Rosa Commissioners regarding the proposed disposal project:
April 28, 2016
RE: Proposed RIBS at Williams Creek
Dear Commissioners:
I just learned a couple of days ago of the proposal by Holley-Navarre Water System to exercise the use of their reuse permit for two RIB systems on property adjacent to Williams Creek here in Navarre. I live in the neighborhood that is adjacent to the creek as it enters Santa Rosa Sound. I am extremely concerned and opposed to the proposal and request that you look for other more suitable locations for disposal of waste water from the HNWS WWTP and potentially from Navarre Beach WWTP.
I haven’t had time to do extensive legal research into the implications of this proposal but from my 25 years of working on water quality in Florida I know that there are several obvious problems that merit your scrutiny and ultimate rejection of this plan:
1. Williams Creek is already impaired due to the development that has been permitted in its watershed, particularly the wetland areas. A new discharge (yes, RIBS are a new discharge) of pollutants that the water body is already impaired for is not allowed under Florida laws. DEP has bio-recons in their database going back into the mid-90’s documenting the various problems.
2. The reuse permit for HNWS would allow up to 500,000 gallons per day of partially treated wastewater to be discharged into these RIBS. (1)
3. HNWS has no limits in its permit for nutrients. They also are not required to monitor for nutrients. If the RIBS are built and activated, then the permit sets a limit of 12 mg/l for nitrates to the RIBS but NO limits on total nitrogen (N) or phosphorus (P). 12 mg/l is designed to meet the groundwater standard of 10 mg/l with a zone of discharge (loophole). This is a staggering amount of nitrogen for a waterway such as Williams Creek and will have an extremely adverse effect on Santa Rosa Sound. (2)
4. Apparently the RIBS are adjacent to the wetlands that are adjacent to the creek. It will take that wastewater a few hours to reach the creek and with it will go the nutrients, heavy metals, pharmaceuticals, toxics, viruses, etc. that are in the effluent.
5. There is a legal issue as to whether Williams Creek has pollution limits that must be protective of Santa Rosa Sound, which is impaired, however I’m fairly certain that whatever new pollution source is permitted for Williams Creek, it must be protective of Santa Rosa Sound as well.
Santa Rosa Sound is already under extreme stress from the untreated and ever increasing polluted stormwater that is flowing into it. This is made even worse by the daily destruction of wetlands in our county which results in less treatment of runoff and faster travel across the land surface and into the water.
This is a bad idea on its face and if you dig a little deeper you will see that it is also illegal under state and federal laws. I have said this at your Commission meetings before but I’ll say it again: The Florida DEP no longer makes even the slightest effort to protect our environment. We cannot depend on their permits or enforcement to guide our actions. You the county commissioners are the only protection that we have. If you don’t make the tough decisions that are sometimes necessary to protect the very things that make our community a wonderful place to live, then they will not get protected.
Below are a few links to recent news stories about the terrible crisis that the Indian River Lagoon is in. The once internationally acclaimed estuary is almost dead. The fish, dolphins, manatees and turtles are diseased or dead. It is a tragedy that unprecedented except maybe on Escambia Bay, when it essentially died in the late 60’s and early 70’s. We don’t want this to happen to Santa Rosa Sound, but it will if we continue to use it for a toilet where were dump everything that we are too cheap to dispose of properly. Please take a minute to glance over these articles and then ask yourself what are we doing to prevent this from happening in our backyard?
http://creative.news-journalonline.com/troubledwater/
http://www.cctv-america.com/2016/04/23/floridas-indian-river-lagoon-is-on-life-support
http://www.floridatoday.com/story/opinion/columnists/bob-gabordi/2016/04/22/indian-river-lagoon-scorecard-shows-failures-brevard-county-florida/83360320/
I look forward to the meeting tonight and hearing your thoughts on this issue. At a minimum you should postpone this decision until more people in the community have an opportunity to study and comment on it. I’m certain that everyone in my neighborhood will be concerned when I go door to door telling them about it, which I will be doing over the next few days.
FOOTNOTES:
1. This permitting action is the issuance of a wastewater permit renewal to allow continued operation ofthe 2.99 MGD MADF [2.37 MGD AADF) WWTF and Part III public access (Hidden Creek golf course, HBTS Recreation Center and aesthetic ponds) reclaimed water use systems with a capacity of 4.405 MGD. Allow expansion of the application sites to include a Part IV rapid-rate infiltration basins (Greskovick property) with a capacity of 0.500
MGD AADF.
2. Natural background levels are: 0.3 milligrams/liter Total nitrogen and 0.1 micrograms/liter Total phosphorus. The Panhandle sand and gravel aquifer is composed of naturally sterile quartz that does not bond nutrients or other chemicals onto its surface.
Sincerely,
Linda Young
******
May 2, 2016
Dear Commissioners – I guess I was trying so hard to be brief at the meeting Thursday night, that I forgot some important points that may be of interest to you if you are not already aware.
I pointed out that the permit, which is now 10 years old, allows for a discharge of 500,000 gallons per day. HNWS said that is a mistake and they would get it changed. They have made other changes to their permit over these years which is accomplished very easily. A simple letter to DEP asking for the correction would do the trick. I find it puzzling that they never requested this change if indeed it is something that they planned to do.
The other point, WHICH IS WAY, WAY MORE IMPORTANT, but also related is that the 500,000 gallons is an annual average. That means that they can have 800,000 (for some strange reason) for three or four days and then only 100,000 for six or eight days and averaged out over the year, it would not create a permit violation. However, if they did dump an enormous amount of water, maybe during a high rainfall event, and the disposal ponds were overflowing into the roads, etc. and they felt there was no other alternative except to discharge the excess to the Williams Creek RIBS, then the impact on the surrounding homes, all the way down to the Sound could be devastating.
Homeowners may have a hard time proving or even knowing what caused the flooding. There would be nothing they could do since the discharges would be perfectly legal.
This is just food for thought. I hope it is helpful.
Warm regards,
Linda Young
from floridacleanwaternetwork.org:
The Florida Clean Water Network opened its doors in November 1994 as part of the national Clean Water Network in Washington, DC. It grew in membership from a handful of mostly national affiliate groups located in Florida to over 300 local, state and national groups all based in Florida and working together to protect clean water. In November 2005, the CWN of FL became a separate, independent entity, and a project of the Tides Center. Over the past 18 years since the Clean Water Network of Florida began operation, there has been a concerted effort by polluter-backed political forces to undermine environmental laws on a state and local level, more quietly and covertly, where there is often less sophistication and fewer resources to recognize and resist these efforts. The Florida CWN has been on the front line for the past 18 years in Florida, defending clean water laws on both the state and federal levels; educating the public about the importance of these laws; working with local communities and teaching them to effectively participate in decision-making in their communities; and bringing groups together across the state and in coordination with national groups to win some of the most significant environmental victories in Florida in the past decade or more.
