Monday, June 3, 2019

Sierra Florida to FDEP: Sarasota wastewater management system is in disarray

Letter from Sierra Club to FDEP regarding Sarasota County's wastewater treatment failures:

Sierra Club Florida supports the original mitigation in FDEP’s draft consent order requiring that Sarasota County upgrade their wastewater treatment plans to meet advanced wastewater treatment (AWT). We oppose Sarasota County’s (County) counter offer to delete this mitigation requirement in favor of connecting more wastewater flows from onsite sewer treatment and disposal systems (OSTDS). In fact, the state of Sarasota County wastewater management system is in such disarray with excessive discharges, nutrient concentrations, and spills that we would support FDEP limiting any additional flows being accepted from OSTDS or new development until the County has at least committed to upgrade to AWT. 

Full letter from Cris Costello of the Sierra Club here (also below the image)


Among the points made:

Sarasota County acquired several AWT facilities, shut them down, and diverted that water to its own non-AWT facilities

5. Based upon Sarasota County’s 2001 Bee Ridge Water Reclamation Facility (WRF) WRF Expansion Facilities Plan, the Bee Ridge WWTF was originally AWT but was converted to secondary treatment with filtration. In addition, it is our understanding that Sarasota County has purchased and decommissioned at least four WWTFs (Siesta Key Utilities, South Gate, Gulf Gate, and Aqua Utilities) that were previously meeting AWT standards. This wastewater, formerly treated to AWT standards, has been diverted to the County’s non-AWT plants where the resulting effluent now has significantly higher nutrient concentrations. 
ii. The County’s discharge of 205,197,000 gallons of reclaimed water between 8/16/18 and 10/22/18 had an average nitrogen concentration of 19.3 mg/L, based upon County Discharge Monitoring Reports (DMRs) submitted to FDEP, equates to 33,101 pounds of nitrogen discharged directly to Phillippi Creek.
. . . nitrogen levels in Sarasota’s bays have been documented, by Sarasota County, as increasing over the past 20 years. This increase has been accompanied by a documented decrease of seagrass coverage in recent years. 



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Entire Text:


June 3, 2019
Jon Iglehart Director, South District Florida Department of Environmental Protection
2295 Victoria Avenue
Suite 364
Fort Myers, FL 33901
RE: Consent Order to Sarasota County Utilities

Dear Mr. Iglehart:

Please accept this as an interjection in the matter of FDEP’s consent order to Sarasota County Utilities on behalf of Sierra Club Florida. Specifically, Sierra Club Florida supports the original mitigation in FDEP’s draft consent order requiring that Sarasota County upgrade their wastewater treatment plans to meet advanced wastewater treatment (AWT). We oppose Sarasota County’s (County) counter offer to delete this mitigation requirement in favor of connecting more wastewater flows from onsite sewer treatment and disposal systems (OSTDS). In fact, the state of Sarasota County wastewater management system is in such disarray with excessive discharges, nutrient concentrations, and spills that we would support FDEP limiting any additional flows being accepted from OSTDS or new development until the County has at least committed to upgrade to AWT. We present the following in support of this position:

1. A “preliminary planning level” estimate of costs to upgrade to AWT and cap on costs by the end of the year as proffered by the County does not appear to be a good faith effort to address the issue.

2. The County’s proposed mitigation seems counter-productive at this point; the County is not in a position to take on more flows without satisfactorily addressing their disposal capacity and nutrient issues.

3. Since the County seems to want to estimate nitrogen loads regarding OSTDS:

i. Based upon information from the Florida Department of Health cited by Dr. Mary Lusk
with the University of Florida-IFAS Extension (Septic Systems 101), the average gross and net nitrogen loadings for an OSWDTS are 11.2 and 7.8 grams of nitrogen per person per day, respectively. These would equate to gross and net loadings of 19.8 and 13.8 pounds of nitrogen per household per year, respectively, assuming 2.2 people per household. The net 13.8 pounds of nitrogen per household per year is still conservative since it does not consider denitrification, which likely occurs due to the unique hydrogeology of areas like Sarasota County. The County’s 25 pounds reflects the gross nitrogen load, and basically assumes that all of the OSTDS are failing. Therefore the County’s estimated nitrogen load reduction of 35,000 pounds from 14,000 OSTDS should actually be 19,230 pounds, which is still conservative since it does not consider denitrification.

ii. The County’s discharge of 205,197,000 gallons of reclaimed water between 8/16/18 and 10/22/18 had an average nitrogen concentration of 19.3 mg/L, based upon County Discharge Monitoring Reports (DMRs) submitted to FDEP, equates to 33,101 pounds of nitrogen discharged directly to Phillippi Creek. This event loading is greater than the annual loading from all the OSTDS that the County is proposing to hook up as mitigation. Ironically, the majority of this direct loading to Phillippi Creek also occurred during the County’s fertilizer “restricted period” of June 1 through September 30, in conflict with intent of the County’s own fertilizer ordinance to limit nitrogen loads.

iii. The County’s discharge of 227,287,000 gallons of reclaimed water between 12/23/18 and 3/24/19 had an average nitrogen concentration of 14.9 mg/L, based upon County DMRs submitted to FDEP, equates to 28,235 pounds of nitrogen discharged directly to Phillippi Creek. This event loading is also greater than the annual loading from all the OSTDS that County is proposing to hook up as mitigation.

4. Based upon the DMR’s submitted by Sarasota County to FDEP, the average nitrogen concentrations in 2018 from the Bee Ridge, Central County, and Venice Gardens Wastewater Treatment Facilities (WWTFs) were 18.3 mg/L, 7.66 mg/L, and 14.2 mg/L, respectively. These reflect the average nitrogen concentrations of the “treated” wastewater or reclaimed water. This is not just reflective of the nutrients that might be directly (and illegally) discharged, but of those which are being put into the environment to irrigate lawns, landscapes and golf courses. The application of the County’s effluent reclaimed water is resulting in the application of significant and year-round nitrogen in addition to nitrogen fertilizer to the environment. This is in direct conflict with the intent of the Sarasota County’s own fertilizer regulations that bans the application of nitrogen fertilizer between June 1 and September 30; and limits the total nitrogen application to 4 pounds per 10,000 square feet per year. Sierra Club believes that upgrading their WWTFs to meet the AWT for nitrogen of 3 mg/L, or even better the nutrient numeric criteria for freshwater streams of 1.65 mg/L, would put Sarasota County in a position to eliminate nitrogen loads to the extent practical. It is noted that the City of Sarasota’s wastewater is currently meeting the numeric nutrient criteria for both nitrogen and phosphorus, so such a goal is in fact practical and achievable.

5. Based upon Sarasota County’s 2001 Bee Ridge Water Reclamation Facility (WRF) WRF Expansion Facilities Plan, the Bee Ridge WWTF was originally AWT but was converted to secondary treatment with filtration. In addition, it is our understanding that Sarasota County has purchased and decommissioned at least four WWTFs (Siesta Key Utilities, South Gate, Gulf Gate, and Aqua Utilities) that were previously meeting AWT standards. This wastewater, formerly treated to AWT standards, has been diverted to the County’s non-AWT plants where the resulting effluent now has significantly higher nutrient concentrations. Conservatively assuming that the combined flow from these 4 WWTFs was 4.0 million gallons a day (the combined permitted capacity of these 4 WWTFs exceeded 8 mgd) and given the average 2018 nitrogen concentration difference between the Bee Ridge Plant of 18.3 mg/L and the AWT limit of 3 mg/L, equates to an additional annual nitrogen load of 187,000 pounds. This represents not only a huge step backwards but results in an increased nitrogen load to the environment that is almost 10 times greater than that of the County’s proposed but misdirected and inadequate mitigation (19,320 pounds).

6. Finally, nitrogen levels in Sarasota’s bays have been documented, by Sarasota County, as increasing over the past 20 years. This increase has been accompanied by a documented decrease of seagrass coverage in recent years. It is not unreasonable to conclude that the increase in nitrogen is in part due to Sarasota County’s poor wastewater planning and misdirected public investments, resulting in illegal spills and discharges of nitrogen-rich wastewater to the waters of the State as well as to the landscape that drain to state waters. Since the City of Sarasota’s existing WWTF exceeds AWT standards; the Bee Ridge WWTF met AWT prior to being downgraded by Sarasota County; and numerous private WWTFs were meeting AWT prior to being purchased and deactivated by Sarasota County, the technology to meet AWT is both practical and possible. Therefore, it is demonstrated both possible and practical for Sarasota County to convert their WWTFs to AWT and the Sierra Club supports FDEP’s consent order to require such for the Bee Ridge and Central County Plants but also advocates the upgrading of the Venice Gardens WWTF to AWT, given its high nitrogen levels, to mitigate for past, present, and future nutrient loads.

Thank you for considering Sierra Club’s concerns and our position in support of a strong Consent Order that will go further than Sarasota County’s proposed amended Draft to assure future compliance with the law. We would appreciate the opportunity for additional review and comment as the Department’s enforcement action matures towards resolution.
Sincerely,

Cris Costello Organizing Manager Sierra Club 2127 S. Tamiami Trail Osprey, FL 34229 941-914-0421 cris.costello@sierraclub.org

cc: Jennifer Carpenter, Assistant Director of District Management, FDEP


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