Professional Perspective of the City's STRP

Dear Marco Island City Council and Residents,

The purpose of this letter is to express our concern and dismay to learn that you are proceeding with a new waste water treatment facility that utilizes both ASR and Class I Underground Injection Control (UIC) wells as essential components in disposing of your waste water. Both of these methods of disposal have proven to be environmentally unsound and your use of them suggests that you may not understand the current state of knowledge of the drawbacks of such systems.

UNDERGROUND INJECTION WELLS: Adoption of this unproven technology had been based on the premise that there was an impenetrable confining layer between the injection zone and the aquifer above it. The theory was that partially treated waste water could be injected below this layer and the waste water would either stay below that layer or migrate great distances where it would be disbursed and diluted enough that it would not have an adverse impact if it ever surfaced. Until very recently, there was no official concern that injectate would rise to pollute coastal waters.

This theory has proven to be false.

1. The “confining” layer is porous, according to the EPA (EPA 816-F-00-022, June 2000). In many instances, water from injection wells has far more rapidly than predicted worked its way into the aquifer under the very communities that were persuaded to inject it.
2. The “confining” layer is not impervious to the corrosive effects of the mixture of native water and effluent that is injected below it. Specifically, it is comparable to storing salt water in an iron bucket. You know it will ultimately rust out, you just don’t know how soon.
3. Deep water injection wells have failed throughout Florida, the only state where Class I UIC municipal injection is legally permitted. Injection wells are known sources of pollution, particularly in coastal areas.
4. The Miami-Dade Water and Sewer Department (WASD) announced ( Miami Herald 12/17/2006 (*)) that it will greatly increase the level of its wastewater treatment, including micro-filtering membranes, reverse osmosis, advanced oxidation and ultraviolet disinfection. It is likely this more-than-a-billion-dollar improvement may be in response to the Sierra Club filing suit over its current, failed injection practices. http://www.sierraclub.org/pressroom/releases/pr2005-02-17.asp

The plan is, instead of deep injection, to “reuse” the effluent.

Reuse also raises potential water quality issues -- particularly for Biscayne Bay, where reclaimed water is targeted for use in a project designed to replicate original freshwater flows from the Everglades. The project, part of the $11 billion Everglades restoration effort, would filter treated wastewater through coastal wetlands and mangroves to make the now-salty southern bay into the thriving estuary it once was.

AQUIFER STORAGE AND RECOVERY WELLS (ASR WELLS): The discredited theory was that excess water could be injected into shallow wells for the purpose of storage and future recovery. It was believed that these wells would contain the injected water in a sort of expanding ”bubble”( See LEAF Powerpoint “Burst The Bubble). In the short term, the water could be pumped back up and used. It was theorized that a recovery rate of 70% of the water could be achieved.

In practice, these wells have proven to be far more porous than anticipated with the following adverse consequences:

1. Their use in the Florida Keys has been a major factor in the destruction of sea life and the coral reef. Tests have proven that this partially treated water surfaces in a matter of hours, not days. The effects have been catastrophic.

Tests done in the late 1990’s by the operators of the waste water system on Marco Island, Florida Water, reflect that the average recovery rate was around 30% with the highest being 50%. It should be pointed out that these tests were conducted by the operator who had a vested interest in proving the highest recovery rate possible. (http://fl.water.usgs.gov/Abstracts/wri02_4036_reese.html Tables 1 & 5)

These results were among the highest in the state. Even at this level, 50% to 70% of the water was not recovered and escaped into the receiving aquifer where it could conceivably migrate to your canals.

2. Again, the limestone that receives the effluent is eroded by the process and the formation become more porous allowing a faster outflow which further intensifies the problem. (Not to mention the acceleration of deformation leading to possible sinkholes)

Two of the main by products of the breakdown of effluent are nitrogen and phosphorus. These are also two of the main pollutants suspected of supporting the flourishing of red tide. It is our concern that the efficacy of your treatment program may not be revealed until several years of contamination have occurred. At that point the damage will have been done and you could find your island surrounded by a sea of red tide.

We would like to have the opportunity to review the above with the council and citizens of Marco Island and request that you conduct a symposium at which these concerns can be addressed. If you are going to take this path, you at least need to inform yourselves as to its possible destination.

Sincerely,

John Glenn

The layer that South Florida has relied upon to completely confine all fluid movement is not preventing the wastewater from three facilities from moving into the lower Underground Source of Drinking Water (USDW). About 40 other Florida facilities inject wastewater into similar geological formations and the injected fluids may move into the lower USDWs in the future.(EPA 816-F-00-022)