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 Front Cover
 Title Page
 Table of Contents
 Introduction
 Methodology
 Regulatory agencies
 Applicable rules and regulatio...
 Overview of permitting process
 Summary and conclusions
 References






Title: Investigation of demineralization concentrate management
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Title: Investigation of demineralization concentrate management
Alternate Title: Technical Memorandum B.5 Applicable Rules and regulations for concentrate management: Task B.5 Applicable rules and regulations: Investigation of demineralization concentrate management
Physical Description: Book
Creator: Reiss Environmental, Inc.
Publisher: St. Johns River Water Management District
Publication Date: 2002
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Subject: Saline water conversion
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Bibliographic ID: WC08459002
Volume ID: VID00001
Source Institution: Conserve Florida Water Clearinghouse
Holding Location: University of Florida
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Table of Contents
    Front Cover
        Front Cover
    Title Page
        Page i
    Table of Contents
        Page ii
        Page iii
        Page iv
    Introduction
        Page 1
        Page 2
    Methodology
        Page 3
    Regulatory agencies
        Page 4
        Page 5
        Page 6
        Page 7
        Page 8
        Page 9
        Page 10
        Page 11
        Page 12
    Applicable rules and regulations
        Page 13
        Page 14
        Page 15
        Page 16
        Page 17
        Page 18
        Page 19
        Page 20
        Page 21
        Page 22
        Page 23
        Page 24
        Page 25
        Page 26
        Page 27
        Page 28
    Overview of permitting process
        Page 29
        Page 30
        Page 31
        Page 32
        Page 33
        Page 34
        Page 35
        Page 36
        Page 37
        Page 38
        Page 39
        Page 40
        Page 41
    Summary and conclusions
        Page 42
    References
        Page 43
        Page 44
Full Text















Special Publication SJ2004-SP13

Applicable Rules and Regulations
for Concentrate Management
Task B.5.

for the
Investigation of Demineralization
Concentrate Management





















Technical Memorandum B.5
Applicable Rules and Regulations for Concentrate Management


Task B.5
Applicable Rules and Regulations


Investigation of Demineralization Concentrate Management


by

Reiss Environmental, Inc.
2487 Aloma Avenue, Suite 200
Winter Park, Florida


St. Johns River Water Management District
P.O. Box 1429
Highway 100 West
Palatka, Florida


January 2002









Contents


CONTENTS


IN TRO D U CTIO N ................................................... ............................. 1
P project O overview ......................................................................... ........... 1
Purpose and Scope........................................................................... ..... 1

M ETH O D O LO G Y ....................................................................................... 3

REGULATORY AGENCIES ................................................ ................ 4
U.S. Environmental Protection Agency............................................. 6
U.S. Army Corps of Engineers......................................... ............. 6
Occupational Safety and Health Administration............................... 7
U.S. Geological Survey ................................................................ 7
U.S. Fish and Wildlife Service......................................... .............. 8
National Marine Fisheries Service..................................................... 8
Florida Department of Environmental Protection........................... 9
St. Johns River Water Management District ................................. 10
Florida Department of Transportation ............................................ 10
Florida Fish and Wildlife Conservation Commission................... 11
O th ers................................................................................................ 11
Summary ............................................................. 12

APPLICABLE RULES AND REGULATIONS...................................... 13
Regulatory Development ................................................................. 13
Current Regulations ................................... ................ ............... 14
62-4: Perm its.............................................................................. 17
62-160: Quality Assurance ........................................ ........... .. 18
62-301: Surface Waters of the State........................................ 18
62-302: Surface Water Quality Standards................................ 18
62-302.400: Classification of Surface Waters, Usage,
Reclassification, Classified Waters ....................................... 18
62-302.530: Table: Surface Water Quality Criteria.................. 19
62-302.700: Special Protection, Outstanding Florida
Waters, Outstanding National Resource Waters.................. 19
62-330: Environmental Resource Permitting............................... 20
62-340: Delineation of the Landward Extent of Wetlands
and Surface Waters ............................................. ........... ... 20
62-341: Noticed General Environmental Resource Permits...... 20
62-343: Environmental Resource Permit Procedures................. 20
62-520: Groundwater Classes, Standards, and Exemptions..... 20
62-522: Groundwater Permitting and Monitoring
Requirements..................................... ............................ 22
62-528: Underground Injection Control..................................... 22


Applicable Rules and Regulationsfor Concentrate Management









Contents


62-550: Drinking Water Standards, Monitoring, and
R ep ortin g .............................................................................. .... 25
62-600: Domestic Wastewater Facilities..................................... 25
62-610: Reuse of Reclaimed Water and Land Application........ 25
62-620: Wastewater Facility and Activities Permitting............ 26
62-650: Water Quality Based Effluent Limitations................. 27
62-660: Industrial Wastewater Facilities.................................. 27
Proposed and Pending Regulations........................................... 27

OVERVIEW OF PERMITTING PROCESS ............................................ 29
Underground Injection................................................................. 30
Surface Water Discharge.................................. ........................ 32
O cean O utfalls ..................................................... .......................... 36
Brackish Wetlands Discharge............................. ..................... 37
Blending with Wastewater ............................................ ........... ... 37
O th er M ethods................................................................................. ... 39

SUMMARY AND CONCLUSIONS .................................... .......... .. 42

REFEREN CES ......................................................... ............................. 43


Applicable Rules and Regulations for Concentrate Management









Tables


TABLES


1 Summary of agencies potentially requiring permits, approvals,
or authorization for concentrate management projects .................... 5

2 State regulations from the Florida Administrative Code..................... 16

3 Definition of groundwater classes........................... .............. .. 21


Applicable Rules and Regulationsfor Concentrate Management









Introduction


INTRODUCTION


PROJECT OVERVIEW

The St. Johns River Water Management District's (SJRWMD) water supply
plan, titled District Water Supply Plan, outlines water supply options to
meet projected water needs through the year 2020. Currently, the Floridan
aquifer provides most of the region's existing water needs for public
supply. The high quality, economical and reliable characteristics of this
groundwater source have made it the water supply of choice. However,
the Floridan aquifer cannot provide all future water supply needs in the
region without damaging water resources and related natural systems.
Therefore, SJRWMD investigated the feasibility of alternative water
supply strategies and identified brackish groundwater, brackish surface
water, and seawater as potential sources of supply to meet future
demands. These alternative water sources will require treatment using
demineralization technologies. These technologies are primarily pressure
driven membrane processes that include reverse osmosis or nanofiltration.
During this process, minerals in the source water, including salt, are
removed, producing potable water as well as a byproduct known as
demineralization concentrate.

Developing acceptable management strategies for demineralization
concentrate is the goal of this project, Investigation of Demineralization
Concentrate Management (the Project). A primary component of the
Project will be the development of a Demineralization Concentrate
Management Plan. The plan will outline environmentally acceptable
options for concentrate management. Currently, some available
concentrate management options include deep well injection, land
spreading, discharge to surface waters, discharge to domestic wastewater
treatment facilities, and various forms of reuse (including blending with
reclaimed water). This project is part of SJRWMD's water supply plan
implementation to meet future water supply needs. Prior to development
of the plan or implementation of the concentrate management alternatives
mentioned, it is important to have an understanding of applicable rules
and regulations governing concentrate management.

PURPOSE AND SCOPE

The purpose of this technical memorandum is to identify and summarize
relevant demineralization concentrate management rules and regulations.
The contents of this technical memorandum will be used to support the
Project and the development of the Demineralization Concentrate
Applicable Rules and Regulations for Concentrate Management 1









Introduction


Management Plan. Addressing this topic is very important since
demineralization concentrate management and the associated regulations
are primary considerations associated with the development of
demineralization facilities within SJRWMD.

Applicable rules and regulations have been collected, reviewed and
summarized as they relate to demineralization concentrate management.
In addition, recommendations have been provided regarding potential
actions to support an environmentally sound, logical, and clear regulatory
process.

The information presented herein does not represent a legal or binding
interpretation of Florida laws and statutes. Legal counsel is the
responsibility of the user.


Applicable Rules and Regulations for Concentrate Management









Methodology


METHODOLOGY


This technical memorandum was prepared by identifying agencies that
have a direct or indirect impact on permitting of demineralization
concentrate management, followed by the collecting and summarizing of
specific rules and regulations. Information was obtained through a
literature search and by contacting regulatory agency officials, other
experts in the field, and utilities currently using demineralization
processes.


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


REGULATORY AGENCIES

Demineralization concentrate management projects require permits,
approvals, or authorizations from a number of governmental agencies.
The need for interaction with these agencies may not be self evident when
considering a demineralization project and associated concentrate
management strategy. In considering the issues related to
demineralization concentrate management, there are a number of agencies
that would be considered "secondary," as their review is related to
ancillary facilities for concentrate disposal, such as pipelines and outfall
structures. Clearly, the Florida Department of Environmental
Regulation is the primary agency responsible for the review and
issuance of permits for demineralization concentrate management.

This section identifies agencies that may have review and approval
requirements for any portion of a demineralization concentrate
management project. Agencies responsible for approval of components of
a demineralization facility other than concentrate are also referenced if the
agency's authority or the language of its governing regulations is broad
enough to allow expansion of the review process into the area of
demineralization concentrate management.

Agencies are summarized in Table 1 below, followed by brief descriptions
of each organization and its potential role in approval of a
demineralization concentrate management project. The order in which
these agencies are listed does not represent their relative level of
importance, nor does it represent functional hierarchy related to a
demineralization concentrate management project.


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


Table 1. Summary of agencies potentially requiring permits, approvals,
or authorization for demineralization concentrate management
projects


Responsible Agency
Federal
U.S. Environmental Protection Agency, Region IV
U.S. Army Corps of Engineers
Occupational Safety and Health Administration
U.S. Geological Survey
U.S. Fish and Wildlife Service
National Marine Fisheries Service
State
Florida Department of Environmental Protection (Primary Agency)
Florida Department of Transportation
Florida Fish and Wildlife Conservation Commission
Regional
Water management districts
Local
Health department
Local pollution control
Environmental resource management department or Natural resource
management department
City/county building and/or zoning departments
CSX Railroad Corporation


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


U.S. ENVIRONMENTAL PROTECTION AGENCY

The U.S. Environmental Protection Agency (EPA) mission is to protect
human health and to safeguard the natural environment (air, water, and
land) upon which life depends. EPA is structured into 10 regions with
Region 4 responsible for Alabama, Florida, Georgia, Kentucky,
Mississippi, North Carolina, South Carolina, and Tennessee.

EPA Region 4 office information is as follows:
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3104
Telephone: (404) 562-9900 or (800) 241-1754
www.epa.gov

EPA has given full delegation to the Florida Department of Environmental
Protection (FDEP) for the regulation of underground injection and surface
water discharge permitting of demineralization concentrate and the
associated management issues. However, EPA does participate in the
review of demineralization concentrate management permits and related
topics concerning demineralization concentrate subject matter in
cooperation with FDEP. An EPA member sits on the Technical Advisory
Committees for proposed underground injection control projects.
Although the EPA's permitting authority is delegated to FDEP, their
oversight and technical input are important factors in FDEP consideration
of permitting for demineralization concentrate disposal.

U.S. ARMY CORPS OF ENGINEERS

The U.S. Army Corps of Engineers (USACE) is made up of civilian and
military men and women, which include a diverse workforce of biologists,
engineers, geologists, hydrologists, natural resource managers, and other
professionals. The USACE mission is to provide quality, responsive
engineering services to the nation, including planning, designing,
building, and operating water resources and other civil works projects
(navigation, flood control, environmental protection, disaster response,
etc.); designing and managing the construction of military facilities for the
Army and Air Force (military construction); and providing design and
construction management support for other defense and federal agencies
(interagency and international services).

USACE involvement in a desalination project and concentrate disposal
would revolve around construction in navigable waterways of the United


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


States, for example, construction of ocean outfall; intracoastal waterway
pipe crossing that requires dredge and fill permitting procedures; wetland
modifications; construction, operation, or abandonment of facilities on
land under federal jurisdiction; or actions requiring major federal action.

USACE district office information is as follows:
400 W. Bay Street or P.O. Box 4970
Jacksonville, FL 32202
Telephone: (904) 232-2568 or (800) 291-9405
www.usace.army.mil

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

The Occupational Safety and Health Administration (OSHA) was created
under the Occupational Health and Safety Act to monitor health and
safety in the work environment and to prevent work-related injuries,
illnesses, and death. This agency may play a role in any construction
aspects related to a demineralization project, especially concerning any
trenching and confined-spaces issues encountered during the construction
phase.

OSHA Region 4 office information is as follows:
St 61 Forsyth Street, SW
Atlanta, GA 30303
Telephone: (404) 562-2300
www.osha.gov

U.S. GEOLOGICAL SURVEY

The U.S. Geological Survey (USGS) serves the nation by providing reliable
scientific information to describe and understand the Earth; minimize loss
of life and property from natural disasters; manage water, biological,
energy, and mineral resources; and enhance and protect our quality of life.
USGS would play a role in concentrate discharge related to a
demineralization project when the discharge concerns underground
injection. USGS is part of a Technical Advisory Committee that is
established by FDEP to evaluate the permitting of underground injection
control projects.


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


USGS Florida office information is as follows:
227 N. Bronough St., Suite 3015
Tallahassee, FL 32301
Telephone: (850) 942-9500
www.usgs.gov

U.S. FISH AND WILDLIFE SERVICE

The U.S. Fish and Wildlife Service (FWS) serves the nation by working,
with others, to conserve, protect, and enhance fish and wildlife and their
habitats for the continuing benefit of the American people. Major
responsibilities of FWS involve managing migratory birds, endangered
species, certain marine mammals, and freshwater and anadromous fish;
conserving wetlands; and restoring nationally significant fisheries. In
addition, FWS enforces federal wildlife protection laws, such as the
Endangered Species Act (ESA).

The ESA allows the listing of species as either "endangered" or
"threatened." A species classified as endangered means it is in danger of
extinction throughout all or a significant portion of its range. A threatened
classification means a species is likely to become endangered within the
foreseeable future. All species of plants and animals (i.e., plants,
mammals, birds, fish, reptiles, and cams/mussels), except pest insects,
are eligible for listing as endangered or threatened. Therefore, the purpose
of the ESA is to conserve "the ecosystem upon which endangered and
threatened species depend" and to conserve and recover these listed
species.

FWS and the National Marine Fisheries Service share the responsibility for
administration of the ESA. The primary responsibility of FWS is for
terrestrial and freshwater species, while NMFS responsibilities are mainly
for marine species such as salmon and whales. Therefore, FWS could
become involved if the proposed demineralization project could
potentially impact listed species such as marine mammals (e.g., manatees)
or other fish and/or wildlife habitats.

FWS Southeast Regional Office information is as follows:
1875 Century Blvd., Suite 400
Atlanta, GA 30345
Telephone: (404) 679-4000
www.fws.gov


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


NATIONAL MARINE FISHERIES SERVICE

The mission of the National Marine Fisheries Service (NMFS) is
stewardship of the nation's living marine resources. Through conservation
and wise use, these resources and their habitat are managed by NMFS to
benefit the nation without jeopardizing options for the future. In addition,
NMFS shares the responsibility with USFWS for administration of the
Endangered Species Act. The agency could become involved in a similar
role as USFWS if the proposed demineralization project could potentially
impact marine resources such as fish and/or marine habitats.

NMFS Southeast Regional Office information is as follows:
9721 Executive Center Drive North
St. Petersburg, FL 33702
Telephone: (727) 570-5301
www.nmfs.noaa.gov

FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION

The Florida Department of Environmental Protection (FDEP) is the state
agency whose mission is to "protect, conserve, and manage Florida's
environment and natural resources." The FDEP accomplishes this mission
through an established regulatory program of permitting, compliance,
and enforcement actions for activities that could have a negative impact
on public health and the natural environment. FDEP is also responsible
for purchase and conservation of environmentally significant lands,
management of the state park system, and outreach and environmental
education. FDEP also provides water quality data on many surface waters
throughout the state and coordinates the monitoring activities associated
with ambient sampling with other agencies. FDEP has received federal
delegation of the underground injection control (UIC) and surface water
discharge (NPDES) permitting programs.

The state of Florida is divided into six regulatory districts: Northwest
District, Northeast District, Southwest District, Central District, South
District, and Southeast District. Headquarters of the FDEP are located in
Tallahassee. The Central District and Northeast District cover the area that
is within SJRWMD. FDEP office information for these two districts is as
follows:


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


Northeast District Central District
7825 Baymeadows Way, Suite 200B 3319 Maguire Boulevard, Suite 232
Jacksonville, FL 32256-7590 Orlando, FL 32803-3767
(904) 448-4300 / sc 880-4300 x201 (407) 894-7555 / sc 325-2290
Fax (904) 448-4366 / Fax (407) 897-2966 /
scfax 880-4366 scfax 342-2966
www.dep.state.fl.us

ST. JOHNS RIVER WATER MANAGEMENT DISTRICT

SJRWMD is one of five water management districts in the state of Florida
dedicated to the preservation and management of Florida's precious water
resources. Duties of SJRWMD include:

Issuing permits for various water use activities and/or activities that
have the potential to adversely impact ground or surface water
resources and adjacent lands
Buying land to preserve or restore vital wetlands and water resources
Conducting research about the quality and quantity of ground and
surface water resources
Mapping ground and surface water resources
Conducting outreach and public education programs

SJRWMD is responsible for issuing many types of permits; however, some
of the most common are the consumptive use permit (CUP) and the
environmental resource permit (ERP). These source water permits include
evaluation of environmental impacts and public water supply, which
could include evaluation of impacts from the concentrate management
component of a demineralization project. In addition, artificial recharge
permitting could become an issue relating to injection wells associated
with demineralization projects if the water is not being beneficially used
or if the injection could adversely affect existing beneficial uses of water.
Artificial recharge is addressed under the District's 40C-5 permitting
program.

SJRWMD headquarters office information is as follows:
P.O. Box 1429
Palatka, FL 32178-1429
Telephone: (386) 329-4500
www.sjrwmd.com or sjr.state.fl.us


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


FLORIDA DEPARTMENT OF TRANSPORTATION

The Florida Department of Transportation's (FDOT) responsibilities
impact nearly every facet of transportation from highways to railways
and airports to seaports. FDOT's mission is to provide a safe
transportation system that ensures the mobility of people and goods,
enhances economic prosperity, and preserves the quality of our
environment and communities. Therefore, FDOT involvement with a
demineralization project would be associated with transportation of any
oversized structures or pipes on state or federal roadways during the
construction phase, and/or any construction that takes place in state or
federal road right-of-way would require utilization permits. Multiple
permits could be required for various activities proposed in FDOT right-
of-way.

FDOT office information is as follows:
605 Suwannee Street
Tallahassee, FL 32399-0450
Telephone: (850) 414-4100
www.dot.state.fl.us

FLORIDA FISH AND WILDLIFE CONSERVATION COMMISSION

The Florida Fish and Wildlife Conservation Commission's (FWC)
responsibility is to manage fish and wildlife resources for their long-term
well being and the benefit of people. The agency could become involved if
the proposed demineralization project could potentially impact listed
species such as manatees or other fish and/or wildlife habitats. In
addition, this agency is provided the opportunity to comment on
proposed FDEP NPDES permits.

FWC Northeast Region Office information is as follows:
1239 S.W. 10th Street
Ocala, FL 34474-2797
Telephone: (352) 732-1225
www.floridaconservation.org

OTHERS

The remaining agencies that could be involved in concentrate discharge
from a demineralization project include local city and county government
agencies. Depending on the location and extent of the project, many
different departments from the local county and/or city could be


Applicable Rules and Regulations for Concentrate Management









Regulatory Agencies


involved. Some of these departments include building and zoning, health,
local drainage, and environmental resources management or natural
resource management. These departments' involvement is associated with
permits for construction, changes in zoning, public health and welfare,
easement acquisitions, issues concerning rights-of-way as well as to
restore, enhance, conserve and manage the air, water, and land resources
in the local area. In addition, CSX Railroad Corporation, which is
responsible for operating the rail network in the eastern United States,
could require permits for any pipelines associated with a demineralization
project when these pipelines cross over/under properties and/or tracks
related to the rail network.

The degree of involvement and the compliance requirements from the
agencies will differ depending on the city and/or county; however, their
involvement has to be addressed because depending on the situations or
different circumstances such as location, source regime, discharge regime,
capacity, etc., could lead to methods requiring additional time, effort,
policy decisions, and/or compliance requirements affecting the
demineralization project. No contact information is provided since it will
be based on location.

SUMMARY

As defined above, a large number of agencies could directly or indirectly
affect permitting of demineralization concentrate management. However,
the requirements of the EPA and the FDEP are the most pertinent to
demineralization concentrate management and represent the critical test
of the viability of any demineralization concentrate management project.
Given that FDEP has primacy, the role of EPA is secondary and consists of
review and comment on FDEP draft NPDES permits and associated
information about the project. However, EPA can object to an FDEP-
issued permit, which emphasizes the importance of both agencies in
demineralization projects. Given that the focus of this technical
memorandum is demineralization concentrate regulations, the following
rules and regulations section specifically delineates the FDEP regulations
that affect demineralization concentrate management.


Applicable Rules and Regulations for Concentrate Management









Applicable Rules and Regulations


APPLICABLE RULES AND REGULATIONS

FDEP regulates demineralization concentrate management based on the
Florida Statutes (FS) and the associated Florida Administrative Code (F.A. C.).
In general, the Florida Statutes is an edited compilation of general laws of
the state and the Florida Administrative Code is a compilation of the rules
and regulations of state agencies that have been filed with the Department
of State pursuant to the provisions of the Florida Statutes.

The federal acts that contributed to the development of these regulations
were researched and are presented herein. In addition, the sections of the
Florida Administrative Code that govern demineralization concentrate
management have been identified and summarized.

REGULATORY DEVELOPMENT

The regulations that govern demineralization concentrate in the state of
Florida have evolved with the increase in numbers of demineralization
plants within the state, the availability of more detailed information on
concentrate characteristics, and the promulgation of new federal
regulations. Florida regulations have incorporated the federal
requirements and, in some cases, have developed more stringent
requirements consistent with the unique characteristics of Florida's
natural environment.

Federal acts that impact demineralization concentrate management
include the Clean Water Act (CWA), the Safe Drinking Water Act
(SDWA), and the Resource Conservation and Recovery Act (RCRA). The
role of each federal act is described below.

The Federal Water Pollution Control Act, enacted in 1972, was amended
in 1977 with the Clean Water Act (CWA). This act addresses the discharge
of pollutants to surface water of the United States. The CWA established a
National Pollutant Discharge Elimination System (NPDES) under which
the administrator of EPA may issue permits for discharge of pollutants
from a point source into waters of the United States that meet applicable
CWA requirements. These requirements include effluent limitations,
waste load allocations, monitoring and entry provisions, toxic and
pretreatment effluent standards, and guidelines for ocean discharge
criteria, among others. The CWA directly affects discharge of
demineralization concentrate to surface waters and municipal wastewater
treatment plants that subsequently discharge to surface waters, via the


Applicable Rules and Regulations for Concentrate Management









Applicable Rules and Regulations


NPDES permitting process. However, there is no known, specific
reference to demineralization concentrate in the CWA.

The Safe Drinking Water Act (SDWA), enacted initially in 1974, contains
provisions for the protection of groundwater. Subtitle C is designed to
prevent endangerment of underground drinking water sources. It
contains the Underground Injection Control (UIC) program provisions
and the sole source aquifer provision, which are the only provisions of the
SDWA specifically addressing groundwater protection. The UIC program
directs EPA to establish minimum requirements for state regulation of
injection of liquids into wells. This program directly affects deep well
injection of concentrate, via the UIC permitting process.

The Resource Conservation and Recovery Act (RCRA), enacted in 1970,
provided legislation for solid waste management that includes guidelines
and standards for solid waste storage, treatment, and disposal of
hazardous and non-hazardous wastes. RCRA requirements would apply
to the disposal of solid or crystallized concentrate in landfills. There is no
known specific reference to demineralization concentrate in the RCRA.

In summary, the CWA and the SDWA provide the primary basis for
federal criteria that apply to the most common demineralization
concentrate management methods (underground injection control
alternatives and the various surface water discharge options). The RCRA
provides criteria related to disposal of materials to landfills and would
encompass solidified demineralization concentrate.

Under federal regulations, demineralization concentrate is a category of
industrial wastewater. The state of Florida has enacted legislation and is
developing regulations specific to demineralization concentrate. State law
classifies concentrate as a drinking water treatment byproduct, which is
permitted as an industrial wastewater through the Industrial Wastewater
Permitting Section of FDEP.

CURRENT REGULATIONS

Current FDEP regulations that affect demineralization concentrate
permitting are listed in Table 2 and summarized below. The table includes
regulations that directly affect the disposal of concentrate, such as the
State Water Quality Criteria in 62-302, as well as regulations that may
have secondary or indirect effects on a concentrate disposal option such as
ERP review in section 62-330. These sections from Chapter 62, F.A.C.,
include all known references to demineralization concentrate as well as


Applicable Rules and Regulations for Concentrate Management









Applicable Rules and Regulations


the sections generally used by FDEP as part of concentrate permitting
efforts.

The purpose of this information is to provide a reference point for rapid
identification of pertinent sections of the Florida Administrative Code.
However, permitting of concentrate management alternatives is site-
specific and complex. As with most regulations, a step-wise checklist of
permit feasibility cannot be gleaned from the regulations due to the
numerous factors that are considered in permitting of discharges to the
environment. Therefore, more detailed comparison of regulations with
project-specific factors is necessary on a case-by-case basis to more
accurately determine viable options for concentrate management.


Applicable Rules and Regulations for Concentrate Management










Applicable Rules and Regulations


Table 2. State regulations from the Florida Administrative Code

Reference Description Keyword
Surface water discharge, ocean outfall,
62-4 Permits underground injection control, non-
surface water discharge, mixing zones
62-160 Quality Assurance Sampling, analyses, laboratories, surface
62-160 Quality Assurance
water, ground water, wastewater
62-301 Surface Waters of the State Surface water, ocean outfall
62-302 Surface Water Quality Standards Toxicity, Outstanding Florida Waters
Environmental Resource
62-330 nirn t e e Dredge and fill, pipelines
Permitting
Environmental Resource Permit
62-343 ro e e Dredge and fill, pipelines
Procedures
62-520 Ground Water Classes, G d w r
62-520 Ground water disposal
Standards, and Exemptions

62-522 Ground Water Permitting and Ground water disposal
Monitoring Requirements
62-528 Underground Injection Control Underground injection control wells

62-550 Drinking Water Standards, Land
Monitoring, and Reporting
Reuse of Reclaimed Water and
62-610 o clai at an Reuse, land application
Land Application

62-620 Wastewater Facility and Industrial wastewater, permit
Activities Permitting applications
62-60 Water Quality Based Effluent S r
62-650 .Limitations Surface water discharge
6Limitations
Industrial wastewater, effluent
62-660 Industrial Wastewater Facilities Industrial wastewater, effluent
limitations


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62-4: Permits

Chapter 62-4, F.A. C., outlines procedures for obtaining permits of all types
from FDEP. This regulation contains Part 1 General, Part 2 -Specific
Permits; Requirements, and Part 3 Procedures for General Permits.

Part 1 Generally identifies procedures and fees associated with permits
and includes 62-4.001 through 62-4.160. The majority of this information
consists of administrative procedures and fees related to permit issuance,
renewal, transfer, and revocation.

Part 2 Specific Permits; Requirements includes Rule 62-4.200 through
Rule 62-4.250 and specifies criteria that are important for determining the
viability of a concentrate management project that involves a discharge to
surface waters. Sections of particular interest are described below.

Rule 62-4.242, F.A. C. Antidegradation Permitting Requirements;
Outstanding Florida Waters; Outstanding National Resource Waters;
Equitable Abatement. This regulation includes criteria to balance the value
of a project with the associated impacts to surface waters to determine if
issuance of the permit is clearly in the public interest. In addition, the
regulation requires confirmation that no other viable alternative exists in
lieu of the proposed surface water discharge. Specific water quality
criteria are not presented but are contained in other, referenced
regulations. This regulation is a critical test of the viability of a surface
water discharge option for concentrate disposal and can be a primary
permitting focus point. Anti-degradation requirements are applicable to
new and/or expanding surface discharge projects.

Rule 62-4.244, F.A. C. Mixing Zones: Surface Waters. Requirements for
mixing zones, including dilution ratios, water quality requirements, and
toxicity requirements are identified. This section is critical to many
demineralization concentrate management projects discharging to surface
waters, including open ocean waters, in those situations where the
demineralization concentrate does not meet water quality criteria
established for the classification of the water body.

Rule 62-4.246, F.A. C. Sampling, Testing Methods, and Method
Detection Limits for Water Pollution Sources. A portion of this section
addresses method detection limits (MDLs) and practical quantification
limits (PQLs). It is possible that FDEP would deem the PQL of a
parameters) to be the necessary and acceptable effluent limit for issuance
of a permit. It is important to ensure that laboratories conducting analyses
Applicable Rules and Regulations for Concentrate Management 17









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for a permit, in addition to being certified, are able to meet the MDLs and
PQLs established through this regulation.

62-160: Quality Assurance

Chapter 62-160, F.A. C., applies to all programs, projects, studies or other
activities that involve the measurement, use or submission of
environmental data or reports to FDEP. The section address quality
assurance plans, laboratory and field procedures, record keeping
requirements, sampling and analytical requirements for FDEP programs,
which would govern monitoring procedures for demineralization
concentrate projects.

62-301: Surface Waters of the State

This chapter defines the landward demarcation of surface waters of the
state. This connection point to Surface Waters of the State is where the
state's jurisdiction and thus application of rules and water quality
standards begins. This demarcation is also used for permitting of
pipelines and other physical improvements that may be associated with
construction of a demineralization concentrate outfall.

62-302: Surface Water Quality Standards

Chapter 62-302, F.A. C., defines many water quality-related factors and
requirements important to demineralization concentrate permitting
efforts. This information is material to most permitting efforts and
includes such data as the state water quality standards for each
classification of surface water, thermal surface water criteria, and special
protection requirements for Outstanding Florida Waters and Outstanding
National Resource Waters.

62-302.400: Classification of Surface Waters, Usage, Reclassification, Classified
Waters

This subsection classifies waters of the state according to their designated
use or uses, as follows:

Class I Potable water supplies
Class II Shellfish propagation or harvesting
Class III Recreation, propagation and maintenance of a healthy,
well-balanced population of fish and wildlife
Class IV Agricultural water supplies
Class V Navigation, utility and industrial use


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Water quality classifications are ordered in the degree of protection
required, with Class I generally having the most stringent water quality
criteria and Class V the least stringent. The classification of any water
considered for concentrate disposal is critical in determining the viability
of the project. Most surface waters in the state are Class I, II, or III waters.
Class IV waters are described in 62-302.400(12) as wholly artificial canals
or ditches contained on agricultural lands behind a control structure
which is part of a water control system that is connected to the works of a
water management district and which is permitted by such water
management district. There are currently no Class V waters remaining in
the state of Florida.

62-302.530: Table: Surface Water Quality Criteria

This section includes water quality criteria for different classes of water,
including a differentiation between fresh and marine waters. For tidally
influenced waters, requirements may include dual limits to encompass
both fresh and marine conditions. Over 70 water quality parameters are
listed and represent a significant body of data required for approval of
any surface water discharge of demineralization concentrate. Surface
water discharges must meet all of the water quality criteria established for
the classification of waters or be granted a mixing zone or other
administrative relief by FDEP. Revisions to the water quality criteria are
considered by FDEP every three years (triennial review). FDEP is
currently working on revision to the water quality criteria, including
revisions to the antidegradation permitting requirements and risk-based
assessment of numeric criteria that were established based on human
health.

62-302.700: Special Protection, Outstanding Florida Waters, Outstanding National
Resource Waters

This section lists water bodies designated by the Environmental
Regulation Commission (the Commission) as Outstanding Florida Waters
(OFWs) or Outstanding National Resource Waters (ONRWs). These
waters are designated as worthy of special protection because of their
natural attributes. In addition, the ONRWs are designated as such
exceptional recreational and ecological significance that water quality
should be maintained and protected under all circumstances. Discharge of
demineralization concentrate to OFWs and ONRWs is extremely limited
in scope and will not be acceptable in most instances. Discharges to OFWs
may not degrade the natural background water quality established at the
time that they were classified as an OFW.


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62-330: Environmental Resource Permitting

This chapter authorizes FDEP to adopt by reference certain environmental
resource permit rules of the water management districts to be used in
conjunction with certain regulations, thus giving FDEP independent
authority to regulate surface water management systems including
activities in, on, or over wetlands or other surface waters. The
environmental resource permitting process applies to concentrate
discharge permitting in relation to construction of pipelines and outfalls
within waters of the state.

62-340: Delineation of the Landward Extent of Wetlands and Surface Waters

This chapter defines the landward demarcation of wetlands and surface
waters of the state. This connection point to Surface Waters of the State is
where the state's jurisdiction and thus application of rules and water
quality standard begins. In addition, this information is used for
permitting of pipelines and other physical improvements that may be
associated with construction of a demineralization concentrate outfall.

62-341: Noticed General Environmental Resource Permits

General environmental resource permits are defined in this chapter for a
broad range of activities, primarily related to construction, installation, or
maintenance of various types of infrastructure. While over 25 permits are
included in this chapter, examples that may be pertinent to concentrate
management projects include construction or installation of riprap, fences,
pipelines, and subaqueous utility crossings.

62-343: Environmental Resource Permit Procedures

This chapter provides the procedural requirements for processing
environmental resource permits and for obtaining formal determinations
of the landward extent of wetlands and surface waters. This connection
point to Surface Waters of the State is where the state's jurisdiction and
thus application of rules and water quality standards begins. In
addition, this information is used for permitting of pipelines and other
physical improvements that may be associated with construction of a
demineralization concentrate outfall.

62-520: Groundwater Classes, Standards, and Exemptions

Groundwater classes are defined in this chapter as shown in Table 3
below. Groundwater classifications are ordered in the degree of protection
required, with Class G-I generally having the most stringent water quality


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criteria and Class G-IV the least stringent. Among other requirements,
discharges into Class G-I and G-II groundwaters must meet the primary
and secondary drinking water standards for public water systems. This
standard is difficult to meet for virtually any concentrate stream.
Typically, underground injection of demineralization concentrate occurs
in Class G-IV groundwater aquifers.

Finally, Chapter 62-520, F.A. C., defines exemptions for installations
discharging into groundwater and exemptions from secondary drinking
water standards in Class G-II groundwater.

The standards and requirements in this section relate to percolation
ponds, deep well injection, land spraying, reuse, and any other
concentrate management alternative that could result in migration of
concentrate into underground sources of drinking water (USDWs).


Table 3. Definition of groundwater classes

Class F-I Potable water use, groundwater in a single source
aquifer described in Rule 62-520.460, F.A.C., which has a
total dissolved solids content of less than 3,000 mg/L
and was specifically reclassified as Class F-I by the
Commission
Class G-I Potable water use, groundwater in single source
aquifers which has a total dissolved solids content of
less than 3,000 mg/L
Class G-II Potable water use, groundwater in aquifers which has a
total dissolved solids content of less than 10,000 mg/L,
unless otherwise classified by the Commission
Class G-III Non-potable water use, groundwater in unconfined
aquifers which has a total dissolved solids content of
10,000 mg/L or greater; or which has total dissolved
solids of 3,000-10,000 mg/L and either has been
reclassified by the Commission as having no reasonable
potential as a future source of drinking water or has
been designated by the Department as an exempted
aquifer pursuant to Rule 62-28.130(3), F.A.C.
Class G-IV Non-potable water use, groundwater in confined
aquifers which has a total dissolved solids content of
10,000 mg/L or greater


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62-522: Groundwater Permitting and Monitoring Requirements

Permitting and monitoring requirements for discharge to groundwater are
defined, including general provisions, dimensions of zones of discharge,
permit renewal and modification procedures, exemptions, and monitoring
requirements. These criteria are applicable to percolation ponds, deep well
injection, land spraying, reuse, and any other concentrate management
alternative that could result in migration of demineralization concentrate
into groundwater.

Per 62-522.300.5, F.A.C., concentrate from potable water demineralization
plants is exempt from obtaining a zone of discharge in order to discharge
to groundwater, provided the applicant demonstrates that the receiving
unconfined aquifer exhibits a natural background total dissolved solids
concentration exceeding 1,500 mg/L. Such installations cannot cause
violation of primary or secondary drinking water standards at any private
or public water supply well outside of the installation's property
boundary.

62-528: Underground Injection Control

Chapter 62-528, F.A. C., is the primary regulation governing underground
injection of demineralization concentrate. The UIC regulations protect the
groundwater sources of drinking water within the state and prevent the
degradation of aquifer water quality adjacent to the injection zone that
could potentially be used for other purposes. This chapter governs the
construction and operation of injection wells in such a manner that the
injection fluid remains in the determined injection zone and is not allowed
to interchange between aquifers.

The chapter includes eight sections, defined as follows:

Part I (general information)
Part II Criteria and Standards for Class I and Class III Wells
Part III Class I Well and Class III Well Permitting
Part IV Criteria and Standards for Class IV Wells
Part V Criteria and Standards for Class V Wells
Part VI Class V Well Permitting
Part VII Specific Permits; Requirements
Part VIII General Permits

General descriptions of each class of well are as follows:


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Class I wells are technologically sophisticated wells that inject large
volumes of hazardous and non-hazardous wastes, including municipal
wastewater, into deep, isolated rock formations that are below the
lowermost underground source of drinking water.

Class II wells inject fluids associated with oil and natural gas production.
Most of the injected fluid is brine that is produced when oil and gas are
extracted from the earth.

Class III wells inject super-hot steam, water, or other fluids into mineral
formations, which is then pumped to the surface and extracted.

Class IV wells inject hazardous or radioactive wastes into or above
underground sources of drinking water. These wells are banned under the
UIC program because they directly threaten the quality of underground
sources of drinking water.

Class V wells use injection practices that are not included in the other
classes. Some Class V wells are technologically advanced wastewater
disposal systems used by the desalination industry for disposal of
concentrate.

Under current regulations, concentrate from desalination plants may only
be injected via a Class I or Class V well. Underground injection
regulations are organized almost entirely in this single chapter (62-528,
F.A. C.) and facilitate a cear understanding of the potential acceptability of
subsurface injection of concentrate. Sections of Chapter 62-528 that are
pertinent to Class I and Class V wells are described below.

Part I (Sections 62-528.100-360) provides general provisions, permit
processing information, public notification requirements, and other
general information necessary for all classes of wells.

Parts II and III provide information on Class I and Class III wells. Class I
wells require injection into an aquifer with a total dissolved solids (TDS)
concentration of greater than 10,000 mg/L, acceptable transmissivity, and
a secure confining unit. Concentrate injection wells are most commonly
Class I. Tubing and packer are required. In addition, an emergency
disposal option is required for up to three days of flow. Specific
requirements are contained in Sections 62-528.400-460.

Part V Criteria and Standards for Class V Wells (Sections 62-528.600-
625) and Part VI Class V Well Permitting (Sections 62-528.630-645)


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address Class V wells specifically and include general criteria, exploratory
well and testing permitting information, well construction standards,
operating and monitoring requirements, and other relevant information.
Class V wells apply to aquifers with a TDS of less than 10,000 mg/L and
therefore may not be applicable for direct concentrate discharge.

Section 62-528.600 defines groups of Class V wells based on usage, to
facilitate the determination of permitting, operating, or monitoring
requirements for these wells. A total of eight groups are defined in Section
62-528.300(1)(e). Demineralization concentrate falls under Group 4,
Type d:

Non-hazardous industrial and commercial disposal wells, which
include laundry waste wells, dry wells, injection wells associated
with aquifer remediation projects, desalination process concentrate
wells, and nuclear disposal wells used to inject radioactive wastes,
provided the concentrations of the waste do not exceed drinking
water standards contained in Chapter 62-550, F.A. C.

To obtain a permit for a Class V demineralization concentrate well, an
exploratory well is required to determine the feasibility of the
underground injection at the proposed site. Section 62-528.603 defines
exploratory well construction and testing requirements.

Section 62-528.605 defines construction standards for Class V wells. Both
exploratory and operational Class V concentrate wells are required to
have tubing and packer, among other requirements.

Section 62-528.610 characterizes operational requirements for Class V
wells, including the need for pretreatment of fluids as necessary for the
fluid to comply with applicable water quality standards. Typical
pretreatment of concentrate includes dilution with freshwater and/or
mixing with treated reclaimed water.

Sections 62-528.615-625 provide Class V requirements for monitoring,
reporting, and plugging and abandonment.

In Part VI, 62-528.630-645, specific permitting requirements are defined. A
Class V concentrate well involves a multi-phased approval process. A
permit application must be submitted for construction of an exploratory
well. Following collection and submission of data from the exploratory
well, approval must be granted for construction of the full-scale well.
Following collection and submission of data from the full-scale well,


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approval must be granted for operation of the well. A necessary and
critical measure of the viability of a Class V well is the adequacy and
preservation of the integrity of the confining beds between aquifers. These
criteria are outlined in Part VI.

62-550: Drinking Water Standards, Monitoring, and Reporting

The drinking water standards and associated requirements are defined in
this chapter. This information is relevant to concentrate management for
those alternatives that require compliance with drinking water standards.
Chloride can be one of the most critical parameters, and it is a violation of
Secondary Standards when it increases above a maximum contaminant
level of 250 mg/L. The regulations in this chapter include restrictions on
discharge or migration of concentrate to certain classes of groundwater,
such as Classes G-I and G-II. These concerns would apply to land
spraying, percolation ponds and potentially other alternatives.
Demineralization concentrate generally will not comply with drinking
water standards. Therefore, options that require compliance with drinking
water standards are not typically viable. However, exceptions for up to
three parameters may be granted under the UIC rules. This opens up the
opportunity for dilution and mixing of demineralization concentrate with
treated domestic effluent and for combined disposal.

62-600: Domestic Wastewater Facilities

The requirements for domestic wastewater facilities are defined in this
chapter, including the characteristics of the influent water necessary to
meet the domestic wastewater classification (62-600.200(25), F.A. C.). The
maximum amount of demineralization concentrate that can be discharged
to a domestic wastewater facility is dependent upon the resulting changes
to influent quality and the ability to meet the classification requirements.
In addition, each FDEP office, depending on the type of industrial waste,
may require pretreatment of the waste consistent with Chapter 62-625
prior to mixing. Therefore, at this time the demineralization concentrate
must be mixed with the raw wastewater and receive complete treatment
with the domestic wastewater.

62-610: Reuse of Reclaimed Water and Land Application

This chapter addresses all forms of domestic wastewater reuse, reclaimed
water, and land application. It only applies to demineralization
concentrate when it is blended with domestic reclaimed water. Sections
include the following:


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Part I General
Part II Slow-Rate Land Application Systems; Restricted Public Access
Part III Slow-rate Land Application Systems; Public Access Areas,
Residential Irrigation, and Edible Crops
Part IV Rapid-Rate Land Application Systems (Rapid Infiltration Basins
and Absorption Fields)
Part V Ground Water Recharge and Indirect Potable Reuse
Part VI Overland Flow Systems
Part VII Industrial Uses of Reclaimed Water
Part VIII Permitting
Part IX Forms and Instructions

Parts II and III address slow-rate land application systems such as spray
irrigation. Part IV identifies rules and regulations associated with rapid-
rate land application systems such as rapid infiltration basins and
percolation ponds. These sections provide pertinent information
regarding the requirements for such disposal methods. While the FDEP
office governing the SJRWMD service area has granted permits for
concentrate mixing with reclaimed domestic wastewater and disposal via
rapid infiltration basins and percolation ponds, this practice is limited.

Parts V, VI, and VII are generally not applicable to demineralization
concentrate management.

Part VIII Permitting provides detailed information related to issuance
of domestic wastewater reuse permits. Of most importance is subsection
62-610.865 Blending of Demineralization Concentrate with Reclaimed
Water. Per this regulation, all land application and reuse projects must be
designed to meet the groundwater standards at the edge of a zone of
discharge. These standards, for the most part, are the primary and
secondary drinking water standards. Given the high concentration of
inorganic constituents in concentrate and the relatively limited
opportunity for dilution, the reclaimed water blend normally must come
close to meeting the groundwater standard as it is applied to the land.
This puts practical limits on using large quantities of demineralization
concentrate in a blending operation with reclaimed water.

62-620: Wastewater Facility and Activities Permitting

This chapter addresses permitting requirements for any wastewater
facility or activity that will reasonably be expected to be a source of
pollution. This includes domestic and industrial facilities and is the key
chapter associated with demineralization concentrate permitting. Permit
applications necessary for a demineralization concentrate project are
Applicable Rules and Regulations for Concentrate Management 26









Applicable Rules and Regulations


identified in 62-620.910. This chapter will likely undergo amendment in
pending rule-making efforts, described in the Proposed and Pending
Regulations section of this document.

62-650: Water Quality Based Effluent Limitations

This chapter contains the procedures for establishing water quality based
effluent limitations (WQBELs) and applies to all surface water discharges.
The intent of the regulation is to ensure that no wastes are discharged to
any waters of the state without first being given the level of treatment
necessary to protect the designated uses of the water. Criteria are
provided to establish discharge water quality requirements based on one
of the following:

Technology based effluent limit
Level 1 WQBEL
Level 2 WQBEL

Criteria for each method of establishing an effluent limit are provided.
Technology based effluent limits do not preclude compliance with surface
water quality criteria. Level 1 WQBELs are based on the availability of
sufficient data to determine that the current quality of the receiving water
body meets standards and will continue to do so with the introduction of
the concentrate. Level 2 WQBELs involve an assessment of the
assimilative capacity of a water body and setting WQBELs by simulating
and predicting water quality impacts.

62-660: Industrial Wastewater Facilities

This chapter contains the procedures for permitting an industrial
wastewater facility. This includes definitions for industrial wastewater
and effluent limitations, both applicable to demineralization concentrate.
In addition, there are specific definitions for exemptions that may apply to
certain demineralization concentrate projects or situations.

Proposed and Pending Regulations

Pursuant to Senate Bill 536, signed in June 2001, Section 403.0882, FS, was
amended. The amended statute states that the Legislature finds and
declares that it is in the public interest to conserve and protect water
resources, provide adequate water supplies and provide for natural
systems, and promote brackish water demineralization as an alternative to
withdrawals of freshwater, groundwater, and surface water. This is to be
accomplished by removing institutional barriers to demineralization and


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Applicable Rules and Regulations


through research to advance water and wastewater byproduct treatment
technology, sound waste byproduct disposal methods, and regional
solutions to water resource issues.

Key changes to Section 403.0882, FS, include:

1. FDEP is to develop rules that will address demineralization
concentrate regulatory issues, including:
a. Permit application forms for demineralization concentrate disposal
b. Specific options and requirements for demineralization concentrate
disposal
c. Specific requirements and accepted methods for evaluating mixing
of effluent in receiving waters
d. Specific toxicity provisions
2. For surface water discharges, failure of whole effluent toxicity tests
predominately due to the presence of constituents to be specifically
identified in the regulations as naturally occurring in the source water
may not be the basis for denial of a permit, provided that the volume
of water necessary to achieve water quality standards is available
within a distance less than or equal to two times the natural water
depth at the point of discharge under all flow conditions
3. Specific permitting requirements for small water utility businesses (i.e.,
those discharging <50,000 gallons per day)
4. Specific permitting requirements for discharge of demineralization
concentrate to Outstanding Florida Waters

Senate Bill 536 will result in revised regulations that should provide a
clearer permitting process for demineralization concentrate management
and discharge. Therefore, the information presented herein regarding the
permitting process will require revision following development of the
new rules.

In addition, and not directly associated with legislation or rulemaking for
demineralization concentrate discharge, FDEP is considering changes to
the surface water quality standards, antidegradation permitting
requirements, identification of impaired waters, and potential
reclassification of certain waters. These changes could ultimately impact
discharges of all types, including demineralization concentrate.


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


OVERVIEW OF PERMITTING PROCESS

Developing a viable demineralization water treatment plant in Florida is
contingent upon obtaining necessary permits for the demineralization
concentrate management component of the project. As described
previously, FDEP represents the primary and most important agency
associated with concentrate management. Demineralization concentrate is
regulated by FDEP through issuance of the appropriate permit for any of
the management alternatives proposed. Various components of the Florida
Administrative Code are integrated into FDEP's evaluation of the permit
application.

Given the varying requirements depending upon application, this section
defines the primary steps associated with a demineralization concentrate
management permitting effort, as determined by the management
approach.

The following demineralization concentrate management options are
addressed:

1. Underground injection
2. Surface water discharge
3. Ocean outfalls
4. Blending with wastewater effluent
5. Brackish wetlands discharge
6. Other methods

The information presented herein is representative of a typical application
and provides an initial guide as to FDEP's permitting requirements and
processes that should be expected. However, site-specific conditions
render every concentrate permit effort unique. In addition, agencies other
than FDEP may become the critical factor in determining the acceptability
of a project, such as projects that would impact endangered or threatened
species.

The regulations contained within the Florida Administrative Code are not
specific to concentrate and in many cases require policy decisions on the
part of FDEP for interpretation of a permit application and issuance of a
permit. Therefore, it is critical to understand the challenges faced by FDEP
industrial wastewater permitting personnel and the need to begin pre-
application permitting efforts well in advance of any demineralization
water treatment plant project.


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Overview of Permitting Process


In addition, the lack of a specific regulation for concentrate permitting
creates an uncertain environment for the municipal water treatment
community. The amendments to Section 403.0882, FS, pursuant to Senate
Bill 536, will result in development of concentrate-specific regulations and
is intended to provide a consistent approach for FDEP permitting
personnel to follow. Therefore, future permitting efforts may differ from
those presented below.

UNDERGROUND INJECTION

Obtaining an FDEP permit for underground injection of demineralization
concentrate begins with the requirements of Chapter 62-528, F.A. C., and
identification of the type of well to be constructed. Class I and Class V
wells are the two viable candidates for concentrate projects.

Primary aquifer considerations for a Class I well are:
Suitable transmissivity
Aquifer TDS greater than 10,000 mg/L
Confining zone is present

If the fluid is non-hazardous, as is typical for demineralization concentrate
streams, and suitable geology exists, then the demineralization
concentrate will not need to meet other water quality standards and the
project has reasonably high probability of being permitted. Class I wells
are most common.

Aquifer considerations for a Class V well are as follows:
Suitable transmissivity
Confining zone is present

If the aquifer TDS is less than 10,000 mg/L or if the fluid can migrate to an
underground source of drinking water (USDW), then fluid must meet
drinking water standards. If the aquifer TDS is greater than 10,000 mg/L
and confined from a USDW or absent of a USDW, then it will not need to
meet other groundwater quality standards. Given the elevated levels of
TDS and other constituents in many concentrate streams, drinking water
standards typically cannot be met.

However, certain projects, such as softening applications or treatment of
fresh or slightly brackish water, may be eligible for a Class V well permit.
In addition, FDEP has the authority to issue an exemption for parameters
that exceed drinking water standards. An exemption will only be granted
if exceeding secondary standards and the state primary standard for


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Overview of Permitting Process


sodium. An exemption is renewable with the permit and requires a fee
that is currently $6,000 per parameter. At least one reverse osmosis WTP
operates a Class V concentrate well, with a TDS less than 10,000 mg/L and
exemptions for certain secondary standards.

Once the class of well has been selected, FDEP will review information
provided by the applicant to determine the steps that will be required for
issuance of a UIC permit. If insufficient information is available on the
hydrogeologic environment, then FDEP may require an exploratory well,
in which case a three-phased permit process would result:

1. Approval for construction of the exploratory well. This well will be
used to obtain additional subsurface information and may eventually
be used as a monitoring well.
2. Approval for construction of the full-scale well. If the information from
the exploratory well is acceptable, the permit for construction of the
full-scale well may be issued. Information gained following
construction of the full-scale well must be submitted as part of an
engineering report and will be used to evaluate issuance of an
operating permit.
3. Approval of an operating permit. Only following receipt of acceptable
information from both the exploratory well and the full-scale well will
an operating permit be issued.

Of great importance is the potential for FDEP to deny further and
subsequent approvals at any point in the process described above. A
municipality may invest funds in an exploratory well and possibly a full-
scale well only to find that FDEP will not issue the operating permit due
to concerns over transmissivity, confining layers, or other issues. The large
capital expenditure (typically over $2M) and the uncertainty and financial
risk associated with deep well injection are such that careful consideration
should be given before a decision is made. Collection of detailed
hydrogeologic information as well as preliminary meetings with FDEP is
recommended.

One specific area of interest to FDEP is the solubility level of the various
constituents concentrated by the desalination process. The main concern is
with the potential for precipitation when some parameters at near
supersaturated levels in the concentrate mix with the same parameters at
nearly saturated levels in the native waters of the receiving formation.
This potential for the creation of precipitates of various concentrated salts
inside the well would endanger the permeability of the receiving aquifer.
FDEP often requires bench studies of solubility and precipitate formation


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Overview of Permitting Process


in mixed media with similar hydrologic characteristics as the receiving
aquifer.

Once an underground injection well has been approved, the mechanical
integrity of the well must be demonstrated every five years. A minimum
of two monitoring wells will need to be constructed to provide monthly
monitoring of the injection well. In addition, an emergency disposal
alternative is required and will need to accommodate at least three days of
flow. In some cases, the redundancy requirements for the continued
operation of potable water treatment facilities can lead to the requirement
for two separate injection wells. Any additional permits associated with
this alternative disposal method must also be procured. This duplicate
permitting effort may also be a critical factor in determining viability of
underground injection alternatives.

Finally, the construction of Class I or Class V wells must follow design
standards outlined by FDEP, which include tubing and packer
construction, testing during drilling and construction, and testing upon
completion of well. Due to high construction costs, with drilling and
construction costs on the order of $2-5M per well, underground injection
is most applicable for larger water treatment plants.

In summary, a feasibility study is recommended prior to pursuing
underground injection. Also, FDEP is required under their primacy
agreement with EPA to form a Technical Advisory Committee (TAC). This
TAC brings into the permit process the opinions of diverse agencies
including EPA, USGS, SJRWMD, the local county health department, and
the local county environmental regulatory agency, in addition to the local
office of FDEP and the FDEP UIC Tallahassee office.

SURFACE WATER DISCHARGE

Discharge of concentrate to a surface water requires an NPDES permit.
The permitting process brings together numerous portions of the Florida
Administrative Code and can be complex. Surface water discharges are
more likely to result in the need for discretionary decisions by FDEP
permitting staff when compared to other alternatives such as
underground injection.

The first and foremost factor associated with a surface water discharge is
the classification of the receiving water. The definition for each class is
presented below.


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Overview of Permitting Process


Class I Potable water supplies
Class II Shellfish propagation or harvesting
Class III Recreation, propagation and maintenance of a healthy,
well-balanced population of fish and wildlife
Class IV Agricultural water supplies
Class V Navigation, utility, and industrial use

While each situation is unique and the regulations are complex, every
surface water permit application is reviewed for compliance in four main
areas:

1. Antidegradation policy and WQBEL (antidegradation is only
applicable to new or increased discharges)
2. Compliance with surface water criteria and mixing zone limitations
3. Impacts of tidal influence
4. Toxicity of demineralization concentrate
5. Whether the demineralization concentrate contributes to an existing
impairment of the surface water/WQBEL

The antidegradation policy is defined in 62-302.300, F.A. C., and requires
abatement of water pollution and conservation and protection of Florida's
natural resources and scenic beauty. The antidegradation policy was
adopted by the Commission in 1989. In addition to requiring compliance
with water quality standards that were originally developed and adopted
in 1979, the policy requires that any degradation of existing background
quality be found to be clearly in the public interest. Revisions to the water
quality standards are considered every three years (triennial review) in
accordance with the Clean Water Act. The water quality criteria are listed
in 62-302.500-530, F.A. C.

FDEP's application of the antidegradation policy includes a variety of
intentionally subjective criteria that are applied uniquely to each specific
permit scenario. There is a "weighing" of various public interest criteria,
including economic and social concerns, against the potential for
degradation of the state's valuable water resources. An excerpt from 62-
302.300, F.A. C., best explains the purpose behind the flexibility:

62-302.300.10.b.1 The Department's rules that were adopted on March
1, 1979, regarding water quality standards are based upon the best
scientific knowledge related to the protection of the various designated
uses of waters of the state.


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Overview of Permitting Process


62-302.300.10.b.2 The mixing zone, zone of discharge, site-specific
alternative criteria, exemption, and equitable allocation provisions are
designed to provide an opportunity for the future consideration of factors
relating to localized situations which could not adequately be addressed
in this proceeding, including economic and social consequences,
attainability, irretrievable conditions, natural background, and
detectability.

62-302.300.10.d Without the moderating provisions described in b.2
above, the Commission would not have adopted the revisions described
in b.1 above nor determined that they are attainable as generally
applicable water quality standards.

While some latitude may exist depending upon site-specific conditions, it
is important to compare the expected concentrate quality with the water
quality standards as soon as possible. Projects that meet all water quality
criteria, although rare, greatly simplify the permitting process.

In addition, the anti-degradation policy requires that the Department
consider and balance four factors, paraphrased below (see 62-4.242,
F.A. C.):

1. Whether the proposed project is important to and is beneficial to the
public health, safety, or welfare
2. Whether the proposed discharge will adversely affect conservation of
fish and wildlife, including endangered or threatened species, or their
habitats
3. Whether the proposed discharge will adversely affect the fishing or
water-based recreational values or marine productivity in the vicinity
of the proposed discharge
4. Whether the proposed discharge is consistent with any applicable
Surface Water Improvement and Management Plan that has been
adopted by a water management district and approved by the
Department

Each permit application is evaluated on an individual basis to ensure that
the Department has reasonable assurance that the proposed facility will
meet applicable water quality standards. Staff members and the
Department must make discretionary decisions, balancing these factors,
with each surface water permit application. Since the majority of
membrane concentrate discharges are related to public water supply
facilities, they are considered to be beneficial to the public health, safety,
and welfare in most, but not all, cases. However, the economic analysis


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


requirements may often point to other alternatives for disposal (e.g.,
underground injection control) that, although more costly, can be
implemented and avoid any degradation of surface waters.

Mixing zones may be granted for dilution of concentrate, if no pre-
dilution takes place at the treatment facility. The applicant must
demonstrate a current and continuing need for the mixing zone. Mixing
zones are commonly needed for concentrate projects due to exceedance of
water quality criteria such as radionuclides and acute or chronic toxicity.
Criteria for mixing zones are complex and are dependent upon the type of
receiving water body. Three categories of water bodies are defined and
addressed differently:

1. Canals, rivers, streams, and other similar water bodies
2. Lakes, estuaries, bays, lagoons, bayous, sounds, and coastal waters
3. Open ocean waters

Open ocean waters are defined as all surface waters extending seaward
from the most seaward natural 90-foot (15-fathom) isobath.

For additional information on mixing zones, 62-4.244, F.A. C., should be
referenced. In addition, the passage in June 2001 of Senate Bill 536 allows
for approval of mixing zones for toxicity due to ionic imbalance in
Outstanding Florida Waters, if certain criteria are met. This expands the
classes of surface waters eligible for consideration.

Tidal influences are addressed via identification of the chloride
concentrations of the water body and flow patterns. Predominately
freshwaters are defined as waters in which the chloride concentration at
the surface is less than 1,500 mg/L. Marine waters are those with chloride
concentrations greater than 1,500 mg/L. In tidally influenced water
bodies, FDEP may require dual limits, addressing both fresh and marine
waters. In addition, tidally influenced water bodies pose difficult flow
modeling challenges since there is reduced flow during tide reversal and,
at least for a short period of time, concentrate is accumulating at the
discharge location. Identification of the range of chloride concentrations
for the receiving water body should be conducted as soon as possible to
determine if tidal influence will be an issue in the permitting process as
well as whether the receiving waters will be considered predominantly
marine.

Biotoxicity requirements are identified in 62-302, F.A. C. Surface Water
Quality Standards for acute and chronic toxicity. For discharge of


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


concentrate to marine waters, FDEP typically requires assessment of the
mortality rates for the mysid shrimp and silverside minnow. Certified
laboratories are available in Florida and are familiar with FDEP's testing
procedure requirements.

In many cases, demineralization concentrate has been found to fail
biotoxicity tests due to naturally occurring constituents such as calcium,
potassium, and sodium. In many cases, the relative ratio of these
constituents is different than that of the proposed receiving water body,
even though the concentration of total dissolved solids may be equal. This
difference in the ratio of constituents has been found to cause mortality in
test organisms that can be corrected by adjustment of the ratio of these
ions, such as naturally occurs in free flowing surface water bodies via
dilution effects. Due to the source of and solution to this toxicity, Senate
Bill 536 has dictated that failure of toxicity tests due to naturally occurring
constituents cannot be the cause for rejection of a permit application.
Therefore, demineralization concentrate streams that fail biotoxicity tests
should be evaluated to determine if naturally occurring constituents are
the cause. In 1995, FDEP published a methodology for testing membrane
demineralization concentrate to determine whether and to what degree
observed toxicity is the result of naturally occurring constituents.

In summary, permitting of concentrate discharge to surface waters
involves balancing numerous factors and considerations. The viability of a
permit application is highly dependant on site-specific conditions and
interpretation of regulations.

OCEAN OUTFALLS

Discharge of demineralization concentrate to the open ocean falls under
the NPDES permitting requirements presented herein for surface water
discharge. This section should be referenced for basic requirements of
ocean discharge. Note that 'open ocean waters' are defined as all surface
waters extending seaward from the most seaward natural 90-foot (15-
fathom) isobath. In many instances, ocean discharges may not meet this
criteria and thus would fall under the criteria for coastal waters, also
addressed in the surface water discharge section herein.

As defined in 62-4.244, F.A.C., requirements for ocean discharges are less
stringent than that for other surface water bodies. Specific differences are:

1. Compliance with the antidegradation policy is more likely
2. Dissolved oxygen requirements are less stringent


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


3. Biotoxicity requirements are less stringent: the discharge can be
diluted one-third its normal concentration for toxicity testing
4. Water quality standards must be met at the point of 20:1 dilution, not
at the point of discharge
5. If water quality standards are met at the point of 20:1 dilution, a
mixing zone exemption is not required
6. A larger mixing zone is allowed (four times larger than other surface
water discharges)

Regulations require the use of a diffuser system that results in at least a
20:1 dilution before the effluent reaches the surface. In addition, the
relative density of demineralization concentrate should be considered
(e.g., in ocean waters, brackish demineralization concentrate will be less
dense and seawater demineralization concentrate would be more dense)
and appropriate diffuser and outfall structures constructed.

While FDEP requirements may be less stringent, additional agencies may
become involved in an ocean outfall project. These may include the Coast
Guard (navigable waterways), USACE (navigable waterways), FWC
(well-being of fish and wildlife resources), and local coastal and ocean
protection agencies.

In summary, ocean outfalls are a subcategory of surface water discharge,
with similar permitting requirements. However, the reduced water
quality requirements and the ability to discharge large quantities of water
treatment plant concentrate are such that ocean discharge may be a
reasonable alternative for large municipal demineralization water
treatment plant projects.

BRACKISH WETLANDS DISCHARGE

Discharge of demineralization concentrate to brackish wetlands is
considered a surface water discharge and requires an NPDES permit.
FDEP requirements are consistent with those presented for surface water
discharges.

BLENDING WITH WASTEWATER

The permitting process associated with blending of demineralization
concentrate with wastewater is application-specific. Primary methods for
combining demineralization concentrate and wastewater are listed below,
followed by a description of the permitting approach.


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


1. Discharge to sewerage system or at the headworks of a wastewater
treatment plant
2. Blending with wastewater effluent for
a. Discharge to a surface water
b. Subsurface injection
c. Reuse

Concentrate may be discharged into the sewerage system or conveyed to
the headworks of a domestic wastewater treatment facility. This method is
commonly used by small demineralization facilities due to the low capital
costs involved. The maximum amount of industrial waste, including
demineralization concentrate a domestic wastewater treatment plant may
receive, is limited by the domestic wastewater facility capacity to accept
the discharge as well as meet the appropriate effluent regulations.
Depending on the type of industrial waste, pretreatment may be required
prior to mixing. The utility selects the pretreatment in accordance with the
approved pretreatment program for the utility.

Additional considerations include confirmation that the introduction of
the concentrate will not affect the treatment process and that the
wastewater effluent discharge permit requirements will not be impacted.
If introduction of concentrate into the sewerage system does not increase
the total influent flow of industrial waste above 10%, no separate
permitting requirements are expected from FDEP.

Permitting requirements for blending of concentrate with treated
wastewater effluent are dependant upon the fate of the combined stream.
Typical management methods include surface water discharge, deep well
injection, and reuse.

Discharge of blended water to a surface water must comply with NPDES
permitting requirements, as described previously herein. In the event the
concentrate is introduced to a wastewater effluent with an existing
NPDES permit, a new or updated permit application will be required to
confirm compliance with surface water discharge requirements.

Underground injection of blended water must comply with UIC
permitting requirements. Given the differing requirements for concentrate
and wastewater effluent, permit modification or construction of a different
Class of well may be required. It is also possible that improvements will
likely be required of an existing and permitted Class I well if it is to
receive a blend of reclaimed water and desalination concentrate and the
ratio of concentrate to reclaimed water exceeds 10%. The improvements


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


required will likely include a need for tubing and packer as well as fluid
filled annulus and hydropneumatic fluid level control of the annular fluid.

Reuse of blended concentrate/wastewater effluent is approached
cautiously by FDEP due to concerns over violation of water quality
standards and impact to the environment. The applicant must submit an
engineering report addressing an array of issues. Major points that should
be addressed in the engineering report include:

1. Compliance with groundwater quality criteria at the edge of the zone
of discharge. For the most part, water quality criteria are the primary
and secondary drinking water standards. The high concentration of
inorganic ions in demineralization concentrate limits the ability to
meet such standards. In addition, rainfall exceeds evapotranspiration
by less than 10 inches per year over much of Florida. Therefore, rainfall
at the land application sites provides a limited dilution before the edge
of the zone of discharge. Detailed water balances will be required in
the report and possibly monitoring wells to confirm compliance.
2. Impact of sodium on percolation rates. The sodium adsorption ratio
and other factors should be evaluated to determine if an adverse
impact to percolation rate would occur. FDEP generally views a
sodium adsorption ratio of less than 15 to be acceptable.
3. Vegetation concerns. Vegetative concerns may result from salinity,
boron, selenium, beryllium, and other specific constituents. The report
must provide reasonable assurances that the blend will not harm
vegetation or crops grown on the land application site(s).
4. Operating protocol. Given the interruptible nature of a reuse supply,
the report must include an operating protocol for the disinfection
process (for the wastewater) and for the blending operation.
5. Monitoring requirements must be addressed and must include
multiple locations (individual supplies, blend, and groundwater).

Concentrate/ wastewater reuse projects will be required to have a
minimum of three days of demineralization concentrate and reclaimed
water storage. Storage for extended wet weather conditions must be
evaluated as part of any project involving slow rate irrigation. Finally, an
annual summary must be prepared and submitted to FDEP for review.
Concentrate reuse has been addressed in detail via 62-610.865, F.A. C., and
Program Guidance Memo DOM-00-04 Blending of Concentrate with
Reclaimed Water.


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


OTHER METHODS

While a number of lesser-known demineralization concentrate
management methods are available, most fall into one of the categories
described previously. These lesser-known methods and the permitting
approach are defined as follows:

1. Land Spraying and Percolation Ponds. Demineralization concentrate
addressed via land spraying or percolation ponds must meet
groundwater standards at edge of zone of discharge. Given the issues
of percolation rates and land area required, these methods are typically
not used for large-scale facilities.

Nevertheless, permits can be issued and have similar requirements as
those described previously for reuse of blended concentrate and
wastewater effluent. Primary concerns that must be addressed by the
applicant include impact of sodium on percolation rates, protection of
vegetation and crops, operational and monitoring procedures,
concentrate storage, and the ability to meet drinking water standards
at the edge of the zone of discharge. This latter requirement can be the
most difficult to meet.

2. Evaporation Ponds. The use of evaporation ponds for management of
concentrate is typically restricted to small-scale water systems in areas
with a warm, dry climate, high evaporation rates, level terrain, and
low land costs. As a result, most applications are in the western United
States. However, a survey of Florida demineralization WTPs indicates
at least one concentrate evaporation pond is operating in the state.

Permitting of an evaporation pond requires an impervious liner and
development of monitoring wells. While evaporation ponds are
typically designed to accommodate concentrate for the projected life of
the demineralization facility, precipitation of salts is expected and
must be incorporated into the depth requirements of the pond. These
precipitated salts or the liquid brine may ultimately have
concentrations of constituents at levels that result in a hazardous waste
classification. Therefore, the ultimate fate of the concentrated salts and
the future regulatory implications should be considered for any
evaporation pond project.

3. Zero Discharge. Zero discharge systems have been designed for
concentrate from industrial applications. The most cost-effective
method involves increasing the TDS of the stream via use of a


Applicable Rules and Regulations for Concentrate Management









Overview of Permitting Process


concentrator evaporator, followed by solidification via a crystalizer.
The resulting wet cake can readily be transported for disposal in a
landfill. Both a concentrator evaporator and a crystalizer are thermal
processes and require a source of steam or electrical power for heating.
Amortized capital costs (excluding operation and maintenance costs)
for a zero discharge system are typically over $12 per 1,000 gallons of
potable water produced (Mickley et al.). Therefore, zero discharge
applications have been limited to select industrial applications.

Permitting of a zero discharge system would be limited to the RCRA
requirements for landfill disposal. Considerations include the ability of
the material to pass a toxicity characteristic leaching procedure test
and confirmation that the cake does not contain levels of constituents
that result in a hazardous waste classification.

4. Coastal Exfiltration Galleries Surface water discharges include
coastal exfiltration galleries, given their direct connection to coastal
and ocean waters. Based on input from FDEP, standard NPDES
permitting requirements would apply as described herein. However, it
is also possible that the FDEP UIC group would become involved to
confirm that the design and location of the galleries were such that
they did not fall under UIC domain.

5. Bore Holes. A bore hole represents a Class V UIC system under the
Safe Drinking Water Act. Requirements for Class V systems were
defined in the Deep Well Injection section herein.

In summary, the alternative disposal methods described can all be
permitted in Florida, pending compliance with specific criteria. Other
factors such as costs may have more bearing on the use of these methods.


Applicable Rules and Regulations for Concentrate Management









Summary and Conclusions


SUMMARY AND CONCLUSIONS

The rules and regulations governing the management of demineralization
concentrate in Florida are primarily associated with FDEP, with additional
requirements from a broad base of local, state, and federal agencies. While
FDEP must grant approval for any and all concentrate projects, the
involvement of other agencies may be dependant upon project-specific
factors such as the selected concentrate management alternative or the
location of the project.

The complexity of FDEP's regulations are such that the acceptability of a
demineralization concentrate management alternative to FDEP is difficult
to determine prior to detailed development of the permit application. In
addition, the specifics of individual demineralization water treatment
projects render each concentrate permitting effort unique.

The amendments to Section 403.0882, FS, pursuant to passage of Senate
Bill 536, will result in rule making by FDEP that will, at a minimum, result
in permit applications specific to demineralization concentrate and
clarification of options and requirements for demineralization concentrate
disposal. Therefore, the permitting approach defined in this document
will change following this rule making. However, the federal industrial
wastewater requirements that form the base of FDEP's regulations have
not changed. Therefore, technical criteria may remain as stringent, but the
level of effort to determine permit viability and the intentions of FDEP
should be reduced. This summary of rules and regulations should be
updated following completion of the rule making pursuant to Senate Bill
536.


Applicable Rules and Regulations for Concentrate Management









References


REFERENCES


American Desalting Association. 1995. Concentrate from membrane desalting: A
logical approach to its disposal. A White Paper. Sacramento, Calif.

Drew, M. 2000. Blending of concentrate with reclaimed water. Florida Department of
Environmental Protection Program Guidance Memo DOM-00-04.

Drew, R.D. 2001. Florida Department of Environmental Protection. Personal
communication.

Florida Department of Environmental Protection. Various dates. Florida
Administrative Code. Title 62. Tallahassee, Fla.

1995. Protocolsfor determining major-seawater-ion toxicity in membrane-
technology water-treatment concentrate. Florida Department of Environmental
Protection Bureau of Laboratories.

Ferraro, C. 2001. Florida Department of Environmental Protection. Personal
communication.

Fletcher, C.R. N.d. Legal and regulatory obstacles to alternative water supply
development in Florida. De La Parte and Gilbert, P.A.

Flemming, P. 2001. City of Melbourne. Personal communication.

Florida Senate. 2001. Senate Bill 536.

Hazen and Sawyer. 2001. Personal communication.

Kenna, E.N., and A.K. Zander. 2000. A/VWARF current management of membrane
plant concentrate. Sponsored by AWWA Research Foundation. Denver, Colo.:
AWWA Research Foundation and American Water Works Association.

Leitner and Associates, Inc. 1992. Potable water desalination in the U.S.: Capital
costs, operating costs, and water selling prices. National Water Supply
Improvement Association Survey on Costs. St. Leonard, Md.

Mickley, M. 1995. Many issues must be considered when planning and permitting
concentrate disposal A complete summary. 1995 AWWA Membrane
Technology Conference Presentation.

Mickley, M., R. Hamilton, L. Gallegos, and J. Truesdall. 1993. AV/VARF
membrane concentrate disposal. Sponsored by AWWA Research Foundation.
Denver, Colo.: AWWA Research Foundation and American Water Works
Association.


Applicable Rules and Regulationsfor Concentrate Management









Overview of Permitting Process


National Water Supply Improvement Association and California Association of
Reclamation Entities of Water. 1989. Setting water quality standards: A complex
issue. A White Paper. St. Leonard, Md.

.1987. The water quality challenge facing the nation. A White Paper.
Alexandria, Va.

Parker, T.J. 2001. Florida Department of Environmental Protection. Personal
communication.

Potts, J. 1995. Concentrate disposal regulations on a national level American
DesaltingAssociation is pressing for solutions. 1995. AWWA Membrane
Technology Conference Presentation.

Teneyck, J. 2001. City of Vero Beach. Personal communication.

Thomas, J.R. 1995. Concentrate disposal in Florida. 1995. AWWA Membrane
Technology Conference Presentation.

U.S. Fish and Wildlife Service. 1996. Endangered Species Act of 1973 A summary
of the ESA and implementation activities.
http:/ /endangered,fws.gov/esasum.html.

Vergara, B.A., ed. 2000. District water supply plan. Special Publication SJ2000-SP1.
Palatka, Fla.: St. Johns River Water Management District.

2000. District water supply plan: Appendixes. Special Publication SJ2000-SP1.
Palatka, Fla.: St. Johns River Water Management District.

2000. District water supply plan: Executive summary. Special Publication
SJ2000-SP1. Palatka, Fla.: St. Johns River Water Management District.

Vergara, B.A. 2001. St. Johns River Water Management District. Personal
communication.

Weinberg, E.W. 1995. Breakthroughs are occurring in concentrate toxicity The very
latest toxicity testing issues. 1995. AWWA Membrane Technology Conference
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.2001. E.W. Consultants. Personal communication.


Applicable Rules and Regulations for Concentrate Management




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