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Indian River County <br />Department of 'Utility Services <br />Phosphorus from Class B biosolids spread annually on existing permitted sites with only <br />Water Extractable Phosphorus data being collected, but no changes to the application <br />practices. <br />Comment: Who would be responsible for cleaning up any Pollution that might be taking place by <br />allowing this activity to continue — the land owner, the hauler, the generating wastewater <br />facility, the State, the county, the ratepayers?? <br />62-640.100(6)(a) What about adoption of new BMAPs while permit is active — adoption of new <br />BMAP in area with existing permitted land application sites should trigger a reopening of the <br />land application site permit. <br />62-640.200 Definitions: <br />(9) Capacity index should have units reflected in equation <br />(?) Soil Fertility Test should be defined in this section <br />(42) & (5 1) "Seasonal high water" and "Water table" measured how? <br />(53) "Yard trash" should be replaced with "Yard waste" <br />62-640.210 General Technical Guidance and Forms <br />(1)(q) Since this is a new section, even the https://dI.science web address should be <br />underlined <br />(2)(a — e) Web address needs to be completed <br />62-640.300 General Requirements <br />(3)(c) Reference for web site needs to be completed <br />62-640.400 Prohibition's. <br />COMMENT: Should the Department not be able to enact regulations ensuring that the land <br />application of Biosolids is done in a manner protective to the environment and restoration <br />efforts verified through water quality monitoring, then perhaps they should consider adding <br />the Upper St Johns River Basin to the list of prohibited zones for application (similar to (11) <br />Lake Okeechobee watershed and (12) Caloosahatchee River and St Lucie River watershed <br />prohibitions). <br />62-640.500 Nutrient Management Plan <br />(5)(d) Spell out what a Soil Fertility Test entails <br />(5)(e) Soil Fertility Testing should be spelled out and also the test should be required <br />annually, prior to application (information on testing found in 62-640.65(3)(b)(1). <br />(5)(f) COMMENT: Reasonable Assurance — that should be defined and not vague, it is <br />going to be offered as a way for additional biosolids to be applied to a site. <br />(5)(f)(1) Table needs to define units of measurement (lbs ?) <br />(5)(f)(1) Table should have `assuming' verbiage removed. Rule should be based on <br />facts, not assumptions. <br />(5)(f)(7) Capacity is spelled incorrectly (capcity) <br />(5)(f)(7)(a)(I4V) I Are the units correct (mg/Kg)? No units defined in the Capacity <br />Indian River County 153 <br />Department of Utility Services <br />1801 271 Street, Vero Beach, FL 32960 Page 2 of 3 <br />