Friends of Perdido Bay
10738 Lillian Highway
Pensacola, FL 32506
Tidings The Newsletter of the Friends of Perdido Bay
November 2002 Volume 15 Number 5 Jackie Lane -Editor
The Plan is out
On October 1, 2002, International Paper submitted its modified permit application to Florida's DEP. This discharge permit application requests that DEP grant them a permit with an order (Consent Order ?) to allow them to move their outfall to the Rainwater Tract. The Rainwater Tract is approximately a 2000 acre piece of property eight miles southwest of the mill. This tract of land was purchased by the paper mill back in the early 1990's for possible disposal of their effluent (as told to us by paper mill people). At that time, the paper mill realized that it was not going to be able to get a valid permit in Eleven Mile Creek. In the permit application, IP outlines its plans for improving their effluent by upgrading their wastewater treatment system, piping their effluent to the Rainwater Tract, and discharging their effluent onto approximately 1600 acres of the Rainwater Tract. These parts of the IP plan will be discussed in more detail in the next sections of the newsletter.
The much touted "pipeline" will be paid for using public funds borrowed from Florida's State Revolving Loan Fund. Normally this fund is used for public projects such as improving domestic wastewater, however this fund became available to IP, a private company, through its "partnership" with Escambia County Utilities Authority (ECUA), a public utility. IP will repay 80% of the loan and ECUA will pay the rest. ECUA will also be receiving property on the IP paper mill site to construct a new wastewater plant sometime within the next five years. The new ECUA plant will be built to process 5 million gallons of sewage a day (MGD) which will also be discharged through the pipeline to the Rainwater Tract. The Rainwater Tract is owned by IP.
In the IP permit renewal application, IP is seeking the following things: issuance of an order with a Compliance Schedule which allows the mill to operate while the improvements are being made, an exemption from the freshwater water-quality standards for pH and salt in the receiving wetlands, recognition that stormwater may continue to be discharged to Eleven Mile Creek from time to time, approval for an anti-degradation review for the moving of their outfall, and establishment of water-quality based effluent limitations for the tidal portion of Eleven Mile Creek. They are also seeking renewal for their solid waste facility permit. In order to construct their pipeline, they are going to be disturbing 23 acres of wetlands for which they will need a permit. Further, we understand that IP is going to seek a modification to their air permit so that they can increase production to 1600 tons of air dried pulp a day. IP is also seeking interim permit limits for BOD (Biological Oxygen Demand) while they are constructing their new wastewater treatment system. The new BOD limits they are asking for are maximum daily limits of 10,200 pounds per day. This number is two times their current winter maximum.
The time table for this ambitious project depends on when all permits are approved. The treatment system upgrade and the pipeline and wetland construction will occur together. IP estimates the construction of both treatment system and pipeline/wetlands will take 20 months, after approval of the permits. The effluent will be introduced to the wetland in 25% increments over 12 months. So approximately 32-36 months after the project begins, IP effluent should come out of Eleven Mile Creek. This is something we are all anticipating greatly.
Improvements to the Wastewater Treatment System
The system which IP currently uses to treat their waste is rather crude in many respects. Their treatment system has to remove huge amounts of very small wood fibers, sugars and alcohols from trees, calcium carbonate, and many natural products from the very large amount of trees processed. IP removes all the products which it can sell and make a profit. Among those products which it removes from its effluent are tall oil, turpentine, soap, and DMSO. Everything else goes into the effluent which they call the sewer. In the first part of the treatment system, solids settle out. Currently, IP has two ponds in which they allow solids to settle. There is a dredge which continually removes these settled solids to another area which they call a dewatering area. In the dewatering area, fluid leaches from the solids and goes back into the treatment system. At some point, the dewatered solids are hauled off to their landfill. The system probably works O.K. until it rains. IP is planing to replaces their two solids settling basins with two large underground tanks. Solids will settle in these tanks and continuously be removed by conveyor to a solid press. The press will then press water out of the solids and the solids will be taken to their landfill. This is a much cleaner and controlled operation than what is now present.
From the settling basins, the effluent proceeds to a big, three-acre pond (called Pond 1) where degradation of the large amounts of organic matter begins. Because wood makes up a large part of paper mill waste, degradation of these wood products requires a long time. Even after three months, paper mill waste is still not entirely degraded. Bacteria and other microorganisms are used to break down the organic matter. Bacteria which require oxygen to live, are much more efficient at breaking down organic matter than bacteria which live where no oxygen is present. Because oxygen is very necessary for efficient treatment of the wastes, big mixers and aerators are required in this big, treatment pond. Removal of organic matter (which is measured as BOD) is nearly directly correlated with amount of aeration and oxygen which can get into the system. Proper amounts of aeration are also necessary for getting solids to settle in later settling basins. If insufficient oxygen is provided, the solids will not settle in latter basins and will be washed out along with the effluent. In order to achieve the Total Suspended Solids (TSS) limits which IP now has for Eleven Mile Creek (8,000 pounds per day in summer and 11,600 pounds per day in winter), IP will need to add an additional 8 -150 HorsePower aerators. IP will be adding 1,380 more horse power to their system.
Further, to aid in the break down of organic matter and proteins, living bacteria found in settled solids of latter settling basins will be recycled back to Pond 1. Recycling bacteria will help remove some of the ammonia from the system which is a real problem for IP.
From the big Pond 1, the effluent will go to another big pond (actually called Pond 3) where solids produced during the breakdown stage in Pond 1 will settle. Small amounts of aeration will occur in part of the pond to further break down ammonia. The effluent will then go to another pond (actually IP calls it Pond 4) where further settling of solids will occur, before going into a large basin where ECUA's and IP's effluents will mix. The combined effluents will go into the pipe to be transported to the wetlands.
In order to achieve the target effluent limits given in Table 1 which are presently part of the old permit, and which will become part of the new permit, IP will have to maintain enough depth in their ponds. i.e., they will have to dredge them, to have solids remain and be treated for 10 to 14 days. From time to time, they may also have to add polymers to get the solids to settle properly. To control un-ionized ammonia, acid will have to be added to adjust the pH of the effluent to make it more neutral.
Table 1. Target Effluent Limits after wastewater improvements
|Parameter||Monthly Average||Daily Maximum|
|BOD (1) - -Summer||4,500 Pounds/day||6,885 Pounds/day|
|BOD - Winter||5,100 Pounds/day|
|TSS (2) - Summer||8,000 Pounds/day||27,000 Pounds/day|
|TSS - Winter||11,600 Pounds/day|
One very good aspect of the plan is IP's ability to store up to 125 MGD of storm water in old ponds which are now used for settling basins. This storm water can then be released at a constant rate into the treatment system.
The Pipeline is a 48 " gravity flow pipe designed to carry 37.5 million gallons of effluent a day. It will start at a mixing basin at IP's last pond, and follow the west side of Eleven Mile Creek for several miles. The pipeline will cross under I-10 near the Florida Welcome Station and Hwy. 90 and continue south along the west side of Gibbs property and the old Beulah Landfill. Once the pipeline reaches Mobile Hwy., it will turn west and go to the Rainwater discharge site. The total length of the pipeline will be slightly less than 10 miles.
The Rainwater Discharge Site
The topography of the Rainwater site is composed of both uplands and wetlands. The 2000 acre site is roughly triangular, bounded on the west by Hurst Hammock Road, on the east by Eleven Mile Creek, Oaks Road to the North and Perdido Bay to the south. The effluent will only impact 1600 acres of the Rainwater Tract as the engineering has been very careful to keep the effluent from flowing into the Perdido River. Most of the time the effluent will flow over the 1600 acres and only during very dry times will the effluent go into the ground. Groundwater studies in the early 1990's indicated that residential wells in the Hurst Hammock area would not be affected.
The pipeline will discharge the effluent into a 1.25 mile swale (ditch). The effluent will flow out of the swale through 18" pipes and "sheet" flow south. A series of four horizontal berms with 18" gated pipes will slow the overland flow of water down. In most of the 1600 acre area, effluent will not accumulate. However along the most southern two berms the effluent is projected to accumulate up to 6' in depth. It will take approximately 5 days from the time the effluent leaves the pipe to reach either lower Eleven Mile Creek or swamp along Perdido Bay. In that 5-day journey, BOD and TSS levels will be reduced to "background" (5 mg/liter), and total nitrogen and phosphorous will be reduced about 18% and 9% , respectfully, from levels applied. Salts will not be reduced. Our preliminary assessment of the project is that it is good, if built as planned. It will definitely improve water quality in Perdido Bay.
Some Problems with the Plan
After reviewing the plan, I wrote some comments to DEP about some of the small problems which hopefully will be solved before a draft permit is issued. One, rather unacceptable aspect of the plan is the request for temporary maximum BOD limits of 10,200 pounds of BOD a day. This amount is extremely high especially for a small stream and bay. Hopefully, during construction of the treatment system, better safe guards can be implemented to keep this level of BOD from getting into Eleven Mile Creek.
The permit renewal application also highlights discrepancies between BOD and TSS values which they are now reporting and target BOD and TSS values which are being projected after improvements to their treatment system. For June, 2002, IP reported having a BOD value of 2,039 lbs/day and 2,839 lbs/day of TSS. Yet after they improve their treatment system and add 1,380 more additional horsepower, they are only projected to get 4,500 lbs/day BOD and 8,000 lbs/day TSS. What is going on? Something is wrong here.
Another problem is IP's request to use the Livingston report to establish water quality based effluent limitations. Livingston was Champion's consultant who studied Eleven Mile Creek and Perdido Bay for approximately 12 years. He apparently no longer works for IP. Livingston totally ignored the really bad problem with paper mill waste - the high amounts of organic material and concentrated instead on the plant nutrients of nitrogen and phosphorus. Paper mill wastes are typically not high in nitrogen and phosphorus. His water quality based effluent limitation (WQBEL) calculations are only for nitrogen and phosphorus, and not for organic material. His calculations for determining what levels of nitrogen and phosphorus can be discharged with out causing harm to the environment are totally unscientific and based only on the premise that levels of these two nutrients were acceptable in 1987 and 1988. Well any WQBELs based on Livingston's work is not O.K.
The last concern about the plan is the paper mill washing major spills of chemicals into the treatment ponds. The treatment ponds are meant to treat organic material and some nutrients, not diesel fuel and sodium chlorate. Unknown to the public using Perdido Bay for recreation, spills of diesel fuel occurred in 1999, and 2001. In one 1999 event, 40,000 gallons of diesel fuel went into the treatment ponds. In 2002, an even worse spill occurred when 60,000 pounds of a potent herbicide, sodium chlorate, was washed into the treatment ponds. IP must have some way to contain these spills so they don't get into the treatment system and then into the environment. A better containment strategy is necessary.
Another viewpoint of the IP-ECUA project .........By Jim Lane
The IP-ECUA project appears to be one step forward and two steps backward. While there should be some initial improvement in the bay's water quality, the potential for increased damage in the future is clear.
The questions are: How much effluent will be put in Perdido Bay? What quality will the effluent be? How long will the effluent be discharged into the bay? Are there better ways of fixing the problem?
One thing is certain, after spending about $60 million on the pipeline and wetlands, the system will be used for a long, long time - two or three generations. And it will be used to its maximum to get as much out of the $60 million invested as possible. So Perdido Bay can look forward to having wastewater dumped in it for many, many years to come.
The pipeline is approximately twice as large as needed to carry the effluent from IP to the wetlands. The capacity of the pipe as calculated by IP's engineering consultants is 37.5 MGD (million gallons per day). Currently the mill discharges about 20 MGD. The new treatment system proposed by ECUA will discharge about 5 MGD when it reaches capacity in ten years. One of the prosed features of the combined system is that this 5 MGD from the ECUA plant will be used as process water by IP, so the output from the ECUA plant will not really add to the effluent being carried by the pipe to the wetlands. This leaves a reserve capacity in the pipe of 17.5 MGD. This reserve capacity is curiously close to the current output from ECUA's Main Street wastewater treatment plant.
When the project was first announced in the Pensacola News Journal, one of the main features extolled was that it would allow the treated (or untreated) wastewater from the Main Street plant to be piped north to the IP-ECUA site, then used by IP as process water, and then discharged into wetlands which would drain Perdido River. This aspect of the project has been soft-pedaled lately because of flak it received from Perdido Bay users who saw it, rightly, as an attempt to move pollution from Pensacola Bay to Perdido Bay. This also meshes with the effort to shut down the Main Street plant which has been a source of irritation to many downtown interests because of the odor it creates, lowering property values near the plant - particularly the Trillium project which has been the subject of many recent newspaper articles. The possibility is not wild speculation - ECUA has a committee looking at ways of shutting down the Main Street plant and has hired engineering consultants to look at alternatives.
Another very troubling aspect of the project is that the effluent limitations contained in the proposed permit apply when the effluent enters the pipe at the mill. There are no limits on the effluent from the wetlands. So if the wetlands don't function as anticipated, there are no restrictions in the permit that could be used to require modifications to improve the discharge. The wetlands will require maintenance, but there are no permit provisions to assure that the maintenance will be done. The berms which are supposed to control the overland flow could erode away, allowing effluent from the pipe to go wherever it wanted, seriously decreasing any beneficial effect the wetlands were having. Thus, the quality of effluent reaching Perdido Bay is not assured.
If this were truly a project to brag about - as many have claimed, it would not be adding discharge to Perdido Bay. It would be piping the effluent north to be used on agricultural or forest lands. The future of wastewater treatment or "reclamation" as they like to call it, is to reuse it, not dump it in some convenient water body.
Perdido Bay users should be outraged at this attempt to designate it as the official bay to be polluted for many years to
1.BOD - stands for Biological Oxygen Demand or the amount of oxygen consuming potential of the material
2.TSS - Stands for Total Suspended Solids