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Andrew Tobin Letter to the Editor - Regarding Sorensen's Inquiry into
Raising Limits Nitrogen threshold in Wastewater Treatment.

Key Largo Free Press

February 11, 2004


No backsliding

Your Feb. 4, 2004 editorial criticized state Rep. Ken Sorensen for asking the state Department of Environmental Protection to lower state water quality standards. You probably were not aware that the request was a limited inquiry about raising the threshold for nitrogen removal only for small treatment plants.

Since I was one of the persons that asked Rep. Sorensen to look into the issue, I thought it might be helpful for your readers to consider the following:

1. Currently, Ch. 99-395 (which Rep. Sorensen co-sponsored) has the toughest water quality standards in Florida. Treatment plants that produce more than 100,000 gallons per day (gpd) must meet Advanced Wastewater Treatment (AWT) standards for nitrogen (TN) at 5 milligrams per liter (mg/L). Treatment plants that produce less than 100,000 gpd must meet Best Available Technology (BAT) standards of TN to 10 mg/L.

2. The Key Largo Wastewater Treatment District Board had received conflicting information on whether our new 150,000 gpd plant can meet the AWT nitrogen standards of 5, and whether the cost of doing so for this relatively small plant is justified.

3. The Implementing Report for Ch. 99-395, prepared by DEP in December 2002, states:

Most of the 60 AWT treatment plants in Florida produce more than 500,000 gpd.‚

New AWT systems for flows in the range of 100,000 gpd to 2 million gpd are estimated to be roughly 60 to 90 percent more expensive to construct than a conventional secondary treatment facility.‚

Operating and maintaining a new AWT system in estimated to cost 60 to 80 percent more than that for a conventional secondary treatment facility.‚

The treatment plants that recently have been built with nutrient removal capabilities do not have long enough operating histories to draw firm conclusions as to the practicality of achieving high levels of nutrient reduction.

4. According to the Florida Keys Aqueduct Authority; tap water contains TN of 3 mg/L. Therefore, treating to 10 mg/L instead of 5 mg/L reduces TN to 95 percent instead of 98 percent, which could be insignificant compared to the cost/benefit.The point I am trying to make is that elected officials like Ken Sorensen are doing their job (and are not "backsliding") when they ask state agencies to rethink and reexamine their data and conclusions, for the simple reason that wastewater science is an emerging field of study, especially in the Florida Keys. And, as noted in the Implementing Report, with new information and new technology; changes and modifications to the standards and how we deal with the issues are inevitable.

Honestly folks, everyone involved in wastewater issues, and especially Ken Sorensen who is a tireless advocate for funding for Monroe County, is trying to do the right thing without wasting your money.

Andrew Tobin, commissioner, Key Largo Wastewater Board


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