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Sunday, 27 February 2011 04:39

Cocoa Bch: ASR Well Public Meeting March 3rd

Written by  Save Our Aquifer

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Updated Mar. 2, 2011

COCOA BEACH PUBLIC MEETING: PROPOSED ASR WELL

City of Cocoa Beach and Florida Department of Environmental Protection

Proposed ASR Well

10am Thurs. Mar. 3, 2011

LOCATION: Cocoa Beach City Hall, 2 South Orlando Ave, Cocoa Beach FL 32932

The public is encouraged to attend, ask questions, and submit comments regarding the proposed ASR injection well. The Florida Dept. of Environmental Protection (FDEP) permit would allow the construction of the main ASR injection well and associated monitoring wells. The permit would also allow for cycle testing the wells. The injection wells are proposed to be constructed at the Cocoa Beach Wastewater Treatment Facility (WWTF) 1600 Minuteman Causeway.  

SUBMIT COMMENTS on Draft Permit No. 05-0224301-002-UC to:
Duane Watroba at FDEP email: This email address is being protected from spambots. You need JavaScript enabled to view it.

EASY ACTION: Save Our Aquifer has made it easy to submit your comments or the current petition, click here:
http://www.saveouraquifer.org/cocoa-beach-take-action-now/

DEADLINE FOR COMMENTS: All comments must be received by FDEP by the end of the March 3 public meeting.
(If you have already submitted your comments, thank you!)

On Friday, February 18, 2011, Save Our Aquifer, Inc. installed a political sign regarding the proposed Cocoa Beach Aquifer Storage and Recovery (ASR) reclaimed wastewater injection well. The sign stands at the southwest corner of 520 and Tropical Trail on Merritt Island.

Save Our Aquifer is opposed to the ASR well for the following reasons:

1.   The applicant is not proposing to construct a monitoring well near the base of the Underground Source of Drinking Water (USDW). The monitoring well described in the permit is at a shallow depth of 200-350 ft below ground surface. The USDW is predicted to be as deep as 1100 ft below ground surface (City of Cocoa Beach ASR System Application Report, Gordon P. Kennedy, 2010). There should be a monitoring well near the base of the USDW to ensure protection of this drinking water resource.  "...all USDWs represent a valuable resource for future use" (EPA 2004).   Pollutants from the injectate could rise 650 feet into the USDW before they would be detected by the monitoring well. This is unacceptable.  According to data from EPA’s 2003 Risk Assessment of Management Options for Treated Wastewater, travel time of the injectate in Brevard County from the injection zone at 1200 feet to the base of the USDW 100 feet above would be between 7 and 27 years. “Regarding the shallow monitoring well (SMW-1), the Department would prefer to monitor a zone deeper than proposed. A monitor zone within 200 feet of the base of the USDW (1,100 feet BLS) is suggested and perhaps within the Avon Park Permeable Zone (APPZ).” (Comment by Ms. Christianne C. Ferraro of FDEP, Response to Request for Additional Information, Brevard County – UIC, Cocoa Beach Reclaimed Water ASR, WACS No. 99135, October 14,2010).

2.   The injection zone is only 100 feet below the USDW.  The injected reclaimed water will seek to flow upward as a result of being less dense and warmer than the native groundwater (EPA 2003) and is likely to reach the USDW. The so called Middle Confining Unit (MCU) that the applicant proposes will prevent upward migration to the USDW is considered by some to be semiconfining or leaky. “The MCU is considered by some workers as semiconfining or leaky and has been termed the “middle semiconfining unit” by O’Reilly et al (2002). The unit generally consists of micritic limestones (wackstone to mudstone), dolomitic limestones or dolomite that occur in the Avon Park Formation.”(City of Cocoa Beach ASR System Application Report, Gordon P. Kennedy, 2010).

3.   All alternatives to the ASR well have not been presented to the City of Cocoa Beach. There are other ways to eliminate discharges of sewage contaminates to the Banana River. For example, Inflow and Infiltration of stormwater into the sewage pipes, the main source of sewage discharges, could be reduced by lining or replacing faulty pipes to essentially eliminate wet season discharges of sewage into the Banana River. “The primary factor affecting capacity at Cocoa beach’s Water Reclamation Facility (WRF) is related to the effects of inflow and infiltration (I/I)” (City of Cocoa Beach ASR System Application Report, Gordon P. Kennedy, 2010).  Another example is a wetlands filtration system could used in conjunction with the 166 acre, 27 hole golf course grounds owned by the City of Cocoa Beach adjacent to the sewage treatment plant.

4.   Reclaimed water should not be used for cycle testing. FDEP should require that potable water be used for cycle testing to reduce potential hazards to the aquifer from contaminates associated with reclaimed water.

5.   A location to contain the discharge waters from cycle testing has not been established.  Due to Arsenic mobilization, this should be determined before the permit is issued.

6.   The injected water will probably not stay in the location of injection and will travel through the aquifer. Fluid movement of injected sewage wastewater has been found at the nearby Class I injection wells in Brevard County at Sykes Creek, South Beaches, and D.B. Lee (EPA 2003). Low recovery rates have been recorded at ASR wells across the state (EPA 2003).

MAIN POINTS:

1. The Cocoa Beach ASR injection zone is proposed at 1,200 feet below land surface, in the lower Floridan aquifer and only 100 feet below the Underground Source of Drinking Water (USDW), a highly protected drinking water aquifer.  The less dense and less saline injected reclaimed wastewater will seek to flow upwards in the Floridan aquifer and may pose a threat to the USDW.

2. Rules should not be relaxed because the proposed injection zone would be 100 feet below the USDW.  Rules should be the same as those for USDW because it is only 100 feet below the drinking water aquifer.

a)  Due to the fact test injections would take place directly below the USDW, the applicant has not enacted a 2-mile radius well ban that would affect more than 400 private wells in the area.  

b) There are no down-gradient monitoring wells at the property boundary.  Down-gradient monitor wells in the storage zone near the property boundary should be required, as was pointed out by District staff. There should also be a down-gradient boundary well at the bottom of the USDW.

c) The Applicant is not required to treat the reclaimed wastewater to full drinking water standards because they would inject 100 ft. below the USDW.

3.  The Applicant also intends to to keep their permit to discharge into the Banana River.

4.   The Banana River Aquatic Preserve surrounds the injection area. The Banana River Aquatic Preserve was created by the legislature to protect valuable submerged lands that are critical to water quality. The marine environment and economic well-being of marine-based businesses could be impacted by this ASR well. The injectate of deep disposal wells in the south beaches of Brevard County and South Florida have risen into the USDW. “Two of the WWTP's on the barrier islands in Brevard County utilize deep-injection discharge of secondarily effluent to 1000m depth below the barrier island. The south beaches central wastewater treatment facility, with a permitted capacity of 36 million liters/day has been identified in a recent USEPA risk assessment as a facility with 'potential for significant vertical migration of effluent into the overlying drinking water aquifer' (USEPA 2003)” (Barile, P.J., 2004).

5.  Arsenic, a dangerous and highly carcinogenic contaminant, would be released into groundwater by injecting oxygen rich water. Cycle testing of ASR wells in Cocoa, Port Canaveral and around the state caused arsenic releases at levels above EPA groundwater standards.

6. Cycle testing could use potable water, but to save money the City is planning to use reclaimed water.  This sewage wastewater, containing birth control chemicals, prescription drugs, fecal coliform, personal care products, plasticizers, endocrine disruptors, and a long list of carcinogenic contaminants, would be injected approximately 100 feet below the USDW.

7. Our drinking water resources should not be put at risk to irrigate lawns and dispose of sewage wastewater.

8.  Injection wells do not represent a viable solution for the barrier island's fragile ecosystem. ASR wells are incompatible with sustainable coastal water quality and environmental health.  

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Save Our Aquifer, Inc., situated at Rockledge, Florida, is organized to protect the Floridan aquifer system and Underground Sources of Drinking Water (USDW), promote awareness, educate the public, elected officials and agency staff, and conduct other such related activities necessary to its mission. Through awareness and education, Save Our Aquifer is working to protect the aquifer and the lagoon for ourselves and future generations.

SAVE OUR AQUIFER
Website: www.saveouraquifer.org
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.    
Address: PO Box 251, Cocoa, FL 32923

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Thanks to SAVE OUR AQUIFER for compiling this information!

Last modified on Wednesday, 02 March 2011 07:11
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