Environmental Protection Commission of Hillsborough County Extending Piney Point Emergency Permit November 3, 2003

TIME LINE SOME BACKGROUND REASONS TO SUPPORT EXTENSION REQUEST

September 11, Piney Point Update Agency on Bay Management September 18, EPC voted unanimously to send a letter to FDEP Secretary Struhs requesting they explore extending the EPA Emergency Permit September 29, 2003 – EPC Chairman sent request letter to Secretary Struhs EXTENSION REQUEST TIME LINE

October 13, 2003 – Secretary Struhs contacted EPC Chairman Platt and advised that FDEP would formally request EPA extend the Emergency Permit October 16, EPC voted unanimously to send a letter to EPA Region 4 Administrator Palmer urging approval of the permit extension request from FDEP TIME LINE

October 21, 2003 – FDEP sent letter to EPA formally requesting an extension of the Emergency Permit October 21, EPC sent a letter to EPA urging approval of the extension request from FDEP November 3, 2003 – Consideration of ABM support for FDEP Extension Request TIME LINE

Reduce Inventory of Process Water and Initiate Closure Activities Long Term Water Management Plan (WMP) Closure Plan – Dewater, Line, Isolate, and Close Pond Storage Compartments PRIMARY OBJECTIVE Piney Point Closure

Site has Received Excessive Rainfall during the last 12 months Average Rainfall Adds 160 MGal to the Site each year Closure Activities Delayed 2004 Dry Season Closure Plan – Close one stack compartment and prepare to close two additional compartments MEETING WMP OBJECTIVE

600 MGal Ponded Process Water 600 MGal Pore Water Increase Storage so that Significant Closure Work can be Accomplished Prior to the 2004 Rainy Season Must Discharge “Double-Lime” Treated Water WATER MANAGEMENT CHALLENGE

Water Balance Model Recalibrated Increase Target Wastewater Removal Rates (2 MGD to Over 4 MGD) Time Period – Minimum 3 to 5 Months Increase Storage so that Significant Closure Work can be Initiated AMENDED WMP

Double Amount of Water Removed From 2 MGD to 4 MGD Increase Amount of Reverse Osmosis Water 0.6 MGD to a Minimum of 1.0 MGD (By 10/15/2003) Increase Amount of Double-lime Aeration Water Minimum of 3.0 MGD (By 10/15/2003) Resumption of Double-lime Aeration Water to Bishop Harbor Target Ammonia Nitrogen Loading Rates (WQ Modeling Report) – 308 Pounds Per Day (15 Day Rolling Average) – 600 Pounds Per Day (Maximum) EMERGENCY ORDER FIFTH MODIFICATION SEPTEMBER 5, 2003

Potential Bishop Harbor Load LTB Load Reduction Target Overall Tampa Bay Load Reduction Target N Load (pounds per day)

Risk of a Catastrophic Accident Remains until Site is Permanently Closed Immediate need to Reduce Water On-Site to Initiate Closure Activities RO is not the only Solution “Double – Lime” Treated Water must be Discharged somewhere REASONS TO SUPPORT EXTENSION REQUEST

Only Current High-Volume Alternative to Discharge to Bishop Harbor is Gulf Dispersion Extension will Reduce Discharges and Nitrogen Loading to Bishop Harbor Extending the Permit Removes an Additional 70 to 75 MGal per month from the Site Additional Water off-site improves Water Balance, Dam Safety and Minimizes the Risk of Accidental Discharges REASONS TO SUPPORT EXTENSION REQUEST

FDEP has met Current Conditions of Emergency Permit No Adverse Environmental Impacts to Marine Water Quality or Marine Life Continued Ocean Dispersal should be Part of a Multi-Faceted Treated Wastewater Reduction Plan REASONS TO SUPPORT EXTENSION REQUEST

SHARE THE LOAD… USE OTHER HIGH VOLUME ALTERNATIVES AS LONG AS POSSIBLE… MINIMIZE THE LOAD TO BISHOP HARBOR AND TAMPA BAY !!!! BOTTOM LINE

Environmental Protection Commission of Hillsborough County Extending Piney Point Emergency Permit November 3, 2003