Long But Worthwhile - Help Stop Sewage Outfall Damage to Boynton Reefs

The following is the history of issues relating to the DelRay Beach sewerage
outfall. The outfall pumps partially treated sewage directly upcurrent from
some of the best reefs in Florida . . . make that reefs that used to be some
of the best in Florida. I think the following speaks for itself. If you,
like I, think this has gone on long enough, I encourage you to contact the
following to make your feelings known. Tell the Florida Department of
Environmental Protection that enough is enough. The South Central Regional
Wastewater Treatment & Disposal Board (SCRWTDB) has been given ample
opportunity to comply with FDEP requests to come into compliance with the
"Clean Water Act". Tell them you want the pollution stopped and that you
expect maximum fines to be levied for continued noncompliance.

Florida Department of Environmental Protection
Southeast District
400 N. Congress Ave., Suite 200
West Palm Beach, Florida 33401
Attention: Timothy W. Powell, P.E., Supervisor
Wastewater Permitting Section
RE: DEP File No. FL0035980-020-DWP1-NRSCRWTDB NPDES Permit

U. S. EPA, Region 4
Water Management Division
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
Attention: Roosevelt Childress, Section Chief, NPDES Permits

Fred McManus
US-EPA, Region IV
Wetlands Branch
61 Forsyth St.
Atlanta, GA 30303-8960
Mcmanus.fred@epa.gov

_____________________________________________


Palm Beach County Reef Rescue
www.reef-rescue.org
561 699-8559

Summary of Events
Delray Beach Ocean Outfall

· March 2002 local recreational scuba divers witness the beginning
of a Lyngbya, cyanobacteria algae bloom on Gulf Stream Reef (GSR), Boynton
Beach. The bloom continued and spread smothering nearly the entire 2 ¾ mile
long reef by November 2002. The group of divers observed and mapped the
spread of the algae.

· September 2003 after a year and a half it became obvious the
bloom was not abating and had done extensive damage to soft corals on GSR,
such as Sea Fans. One of the divers, retired environmental scientist, Ed
Tichenor prepared a report "Occurrence and Distribution of Cyanobacteria on
the Gulf Stream Reef System, Boynton Beach, Florida" to alert the regulatory
community. The report detailed reef conditions and recommended research to
identify potential nutrient pollution sources, which may be responsible for
fueling the algae bloom. No response to the report was received and no
action was taken.

· February 2004 the group issued a second report "Results of Phase
II Investigations", which summarized their public records search identifying
potential nutrient discharge points, a review of Discharge Monitoring
Reports (DMR) and further mapping of the Lyngbya algae bloom. The report
demonstrated a connection between an increase in nutrients discharged from
the Delray Beach ocean sewer outfall pipe and the appearance and spread of
Lyngbya on down current reefs. The report concluded the National Pollution
Discharge Elimination System (NPDES) permit under which the Delray/Boynton
sewer plant operates did not comply with the requirements of Section 403 of
the federal "Clean Water Act".

As a result of this report, the federal EPA and NOAA's Atlantic
Oceanographic and Meteorological Laboratory (AOML) contacted the group. The
group was invited to AOML in Miami to give a presentation. Subsequently
NOAA's Dr. John Proni accompanied them to Boynton Beach to advise Mayor
Jerry Brown of the findings.

· April 2004 the group issued a supplemental data package
containing photographs documenting the extensive loss of coral habitat on
GSR caused by the Lyngbya bloom.

· September 2004 the group issued the report "Correlation Between
Waste Water Treatment Plant Effluent Quality and Cyanobacteria Proliferation
on Gulf Stream Reef, Boynton Beach, Florida". This report examined chemical
and physical analytical results for 3 ½ years of data reported by the
Delray/Boynton sewer authority for the effluent discharged from the ocean
outfall pipe. The report concluded :


"There is a clear correlation between the WWTP effluent quality and
cyanobacteria proliferation Gulf Stream Reef. It is difficult to deny a
connection between the discharge of treated sewage and the cyanobacteria
bloom found immediately down current of the WWTP outfall. There is a cause
and effect between the increase in nutrients and the beginning of the bloom;
the decrease in nutrients and the [algal] die-off; and the return to
elevated nutrient levels and the re-emergence of the cyanobacteria.

There are no demonstrable impacts to GSR from non-point sources or from the
Boynton Inlet located several miles down current of GSR. There appears to be
no reasonable alternative but to conclude that the discharge of treated
sewage from the Delray ocean outfall is the principal source of nutrients
controlling cyanobacteria proliferation on Gulf Stream Reef."

· September 2004 the group incorporated as the 501(c)3 non-profit
corporation "Palm Beach County Reef Rescue" to provide a framework to
receive donations to offset the costs associated with investigations and
report preparation.

· October 2004 Dr. Janet Phipps of the Palm Beach County Department
of Environmental Resource Management (ERM) invited Palm Beach County Reef
Rescue (Reef Rescue) to give a presentation to ERM personnel.

· April 2005 Reef Rescue prepared and submitted a proposed sampling
plan to ERM designed to establish up current background water quality and
ascertain what nutrient influence the outfall may exert on the down current
coral reef environment. The county subsequently provided funding to Reef
Rescue in conjunction with Harbor Branch Oceanographic Institute and the
University of Maryland, Chesapeake Biological Laboratory to collect and
analyze sea water samples for nutrients in south Palm Beach County; the
first program of its kind.

· May 2005 Reef Rescue issued their fifth report "Environmental
Conditions Status Report, Cyanobacteria Proliferation, Gulf Stream Reef".
The report summarized prior investigations and recommended maximum nutrient
discharge limits needed in the Delray outfall NPDES permit to prevent
further degradation to the coral reef habitat. The report detailed the
factors to be used, pursuant to section 403, Ocean Discharge Guidelines (40
CFR Part 125, Subpart M [45 CFR 65942], October 3, 1980), which must be
considered by NPDES permit writers.

The report concluded " A three year program of concentrated onsite
investigations has delineated the full extent of the Lyngbya cyanobacteria
bloom on the reef tracts of South Palm Beach County. The bloom is confined
to the coral reef biological community found immediately down current from
the Delray Beach ocean outfall pipe. There is sufficient data to document
that the cause of the Lyngbya bloom on Gulf Stream Reef is the discharge of
nutrients from the Delray Beach outfall. While the outfall is likely not the
only source contributing nutrients to the coastal waters of South Palm Beach
County, it is unquestionably the trigger which tips the balance creating a
eutrophic environment in the down current biological community.

Reef Rescue submitted this report to the Florida Department of Environmental
Protection (FDEP) along with letters from concerned stakeholders and a
petition with 1000's of signatures, demanding the State of Florida enforce
the federal Clean Water Act on the Delray ocean sewer discharge.

· June 2005 Delray/Boynton sewer authority applied for renewal of
the outfall NPDES permit, due to expire December 2005. The application was
rejected by the FDEP as incomplete as it did not meet all the requirements
of the Clean Water Act. The FDEP stated:

"A group of recreational divers, Palm Beach County Reef Rescue (PBCRR), have
been monitoring periodic algae blooms (Lyngbya spp.) on the Gulf Stream Reef
immediately north of the outfall. Their reports have documented that the
blooms are occurring on this reef, which is generally downstream (north) of
the discharge, but not on the reef to the south (generally upstream) of the
outfall. These observations warrant serious consideration of the impacts
that the outfall may be causing or contributing to. Under the Clean Water
Act and Florida law, wastewater discharges must not degrade receiving
waters. The Department needs additional monitoring data to have reasonable
assurance that the discharge is not causing or contributing to these algae
blooms and subsequent harmful impacts on the reef system. Therefore we are
requesting the utility to propose a monitoring program in the receiving
waters which will provide additional information to evaluate the potential
impacts of the outfall. The program shall consist of routine sampling
locations near the outfall and reef system at various locations and depths.
The proposal shall also include dye or tracer studies which will track the
discharge plume both near the outfall, and at sufficient distance far away
from the outfall to determine vertical mixing throughout the water column."

The sewer authority was given 45 days to address the deficiencies in the
NPDES application.

· July 2005 The sewer authority dismissed the FDEP directive and
attributed the Lyngbya bloom, found only down current of the outfall, to
".loss of algae consumers in the food chain, global warming, atmospheric
deposition, terrestrial discharge, groundwater discharge and deep ocean
upwelling.

· August 2005 the ERM funded water quality study proposed by Reef
Rescue began. Dive boat operators donated their time and boats as Reef
Rescue volunteers collected over 100 ocean water samples in the vicinity of
Gulf Stream Reef, the Delray outfall and the Boynton Inlet. Nine rounds of
sampling were completed by November 2005.

· September 2005 in their second letter to the sewer authority, the
FDEP again found the NPDES permit renewal application incomplete and stated:

".given the lack of any other data to assess the impacts, the [Reef Rescue]
reports offer some compelling observations which must be explained. Foremost
is the fact that algae has not been an observed problem on reefs south of
the outfall, generally considered upstream."

The sewer authority was given 45 days to address the deficiencies in the
NPDES application.

· November 2005 the sewer authority rejected the FDEP request to
perform water monitoring in the vicinity of the outfall, stating:

"We stand by our previous claims that there are a great number of factors
that could impact the reef environment and it is clear that studying a
single factor alone will result in data collection which does not enable
sound scientific conclusions to be drawn".

· December 2005 in their third letter to the sewer authority the
FDEP found the NPDES permit renewal application again incomplete. The sewer
authority was given 45 days to address the deficiencies in the NPDES
application.

On December 15, 2005, the NPDES operating permit for the Delray/Boynton
sewer authority expired, forcing the plant to operate without a valid permit
as required by the federal Clean Water Act.

· January 2006 Reef Rescue presents ERM with the results of the
coastal water quality monitoring performed from August to November 2005. The
results document background water quality up current of the Delray sewer
outfall is degraded with nutrient pollutants as the current flows past the
sewage discharge. Nutrient pollution can be traced from the outfall to down
current reefs. Analysis performed in the vicinity of the Boynton Inlet show
no transport of nutrients from the inlet to the Gulf Stream Reef.

· February 2006 the sewer authority proposed two tracer dye tests
to satisfy the Clean Water Act requirement to assess the impact of the
outfall to the receiving environment.

· March 2006 The FDEP rejects the permit renewal application as
incomplete for the fourth time and states:
Due to the delay in the tracer studies, you need to re-evaluate the need for
implementing a monitoring program in the receiving waters in the vicinity of
Gulfstream Reef. The sampling program should include at least one location
upstream (south) of the outfall and three near the reef - one at the south
end, one at north end, and one near the middle. Sample depths should be at
the ocean surface, at mid-depth and at the bottom. We also recommend at
least one sample to be taken at the Boynton inlet (mid-depth) during
outgoing tide, but this is your option. Parameters should include pH,
Specific Conductance, Nitrite/Nitrate, TKN, Ammonia, Total Nitrogen,
Ortho-phosphorous and Total Phosphorous. The monitoring program needs to
begin as soon as possible (before the first tracer test) on a monthly basis
for at least one year, after which time the sampling frequency could be
reduced (or possibly discontinued, depending on the results of the sampling
program and/or the dye/tracer studies).

The FDEP gives the sewer authority 45 days to address the deficiencies in
the NPDES application.

· April 2006 the sewer authority rejects the FDEP request to begin
monitoring as soon as possible in the vicinity of the sewer outfall and
states:

"Although it is anticipated that the tracer studies will not commence until
August 2006, we propose to maintain the previously presented schedule
identified in our [prior] response."


What you can do to HELP!

Tell the FDEP enough is enough. The South Central Regional Wastewater
Treatment & Disposal Board (SCRWTDB) has been given ample opportunity to
comply with FDEP requests to come into compliance with the "Clean Water Act".
Tell them you expect fines to be levied for continued noncompliance.

Florida Department of Environmental Protection
Southeast District
400 N. Congress Ave., Suite 200
West Palm Beach, Florida 33401

Attention: Timothy W. Powell, P.E., Supervisor
Wastewater Permitting Section

RE: DEP File No. FL0035980-020-DWP1-NR
SCRWTDB NPDES Permit

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Lee's Rule
In any heated discussion, he or she who first resorts to name calling has
run out of meaningful dialog and may be presumed to have lost the point.