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Indian River County <br />Department of Utility Services <br />equation presently, so no way to determine validity of the units in this <br />section? <br />(5)(f)(8) Seems to contradict sections in this Rule that make determinations based on <br />Total Nitrogen instead of Plant Available Nitrogen referenced here (62- <br />640.650(3)(b)(2)(c)(1). <br />62.640.650 Monitoring, Record Keeping, Reporting and Notification <br />(3)(b)(2)(c)(1) Timing between required test and any application rate changes based on the <br />required test seems excessive and could allow for a significant period of time <br />(years) before monitoring activities based on that data take place <br />(3)(b)(2)(e) Tests in the Rule are required to be performed by a certified laboratory (in <br />accordance with 62-620.610(18)(d). Are all required tests recognized by <br />laboratory certification programs (water extractable Phosphorus, etc.). <br />62-640.700 Requirements for Land Application of Biosolids <br />(6)(3)(2)(f) In addition to the provisions of subparagraph 62-640.700(6)(e)(1)., F.A.C., <br />measures to prevent leaching and run-off of n*t6epAs pollutants are also <br />implemented. <br />(10)(a) — (c) How is this to be measured — locations of piezometers or monitoring wells <br />should be defined and appropriate measurement units. <br />GENERAL COMMENT: Wastewater plants adjust operations throughout the process depending <br />on influent and effluent characteristics. Basing applications on estimates or at the most monthly <br />analyses of Biosolids may not be protective to the environment, as these values can change <br />drastically based on the desired treatment process of the contributing wastewater plant. Application <br />rates should be based on real values of the loads destined for application. <br />Indian River County 154 <br />Department of Utility Services <br />180127" Street, Vero Beach, FL 32960 Page 3 of 3 <br />