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Item B1aFlorida Keys Reasonable Assurance Documentation Update FKRAD Program December 2011 Prepared for FLORIDA DEPARTMENT OF ENVIRONMENTAL PROTECTION Watershed Management Bureau Tallahassee, Florida Prepared by Cm 1715 N. Westshore Boulevard Tampa, Florida 33607 FKRAD TABLE OF CONTENTS Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS December 2011 Executive Summary Section 1.0 Background 1.1 Purpose of the Document..................................................................................4 1.2 Activities since the Florida Keys Reasonable Assurance Documentation Adoption........................................................................................................................ 7 Section 2.0 Identification of Dissolved Oxygen Impaired Waters 2.1 Understanding of Impairment in the Florida Keys..............................................8 2.1.1 Problem Definition..................................................................................8 2.1.2 Impaired Waters.....................................................................................8 Section 3.0 Description of Water Quality Standards for Dissolved Oxygen 3.1 Water Quality Standards.................................................................................13 3.1.1 Florida Water Quality Standards- Dissolved Oxygen .........................13 3.1.2 Antidegradation.....................................................................................13 3.2 Restoration of the Designated Uses of the Impaired Waters - Dissolved Oxygen............................................................................................................14 Section 4.0 Description of Proposed Management Actions to be Undertaken 4.1 Names of the Responsible Participating Entities.............................................15 4.2 Update of Proposed Management Activities Designed to Address Nutrients..........................................................................................................15 4.3 Anticipated Benefits to Address the Dissolved Oxygen Impairment................18 4.4 Agreements Committing Participants to the Management Actions..................18 4.5 Changes to Chapter 99-935, L.O.F.................................................................18 Section 5.0 Schedule to Achieve Water Quality Targets 5.1 Achieving Water Quality Targets - Dissolved Oxygen....................................20 5.2 Schedule to Achieve Targets - Dissolved Oxygen..........................................20 Section 6.0 Monitoring Results 6.1 Summary of Existing Monitoring......................................................................21 6.2 Methods for Evaluating Progress Towards Goals...........................................23 Attachment 1 Summary of Status of Completion for Proposed Management Practices ................................ A-1 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE K R A D FLORIDA KEYS F S December 2011 TABLE OF CONTENTS (Continued) Figures 1-1 Florida Keys............................................................................................. 1-2 Planning Units.......................................................................................... 2-1 Lower Keys WBID's................................................................................. 2-2 Upper Keys WBID's............................................................................. 2-3 Middle Keys WBID............................................................................... 6-1 FKNMS WQMP Sampling Sites........................................................... Tables 1-1 FKRAD Pollutant Load Summary ......................................................... 2-1 Florida Keys WBIDs in category 4e for DO .......................................... 2-2 Threshold Values for Nutrient Parameters by Waterbody Type........... 4-1 General Management Actions.............................................................. 4-2 Estimated Nutrient Loadings in the Florida Keys ................................. 6-1 EPA WQPP Water Quality Targets ...................................................... 6-2 FKNMS Summary Statistics................................................................. 4 6 ...10 ...11 ...12 ...22 2 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 Executive Summary SUMMARY The Florida Keys Reasonable Assurance Documentation (FKRAD) was approved by the Florida Department of Environmental Protection (FDEP or Department) for Nutrients in 2008 and provided to the Environmental Protection Agency (EPA) in February 2009. This document provides an update to the FKRAD ("Update") for two major reasons: to provide the status of the management activities defined in the original RAID and to address dissolved oxygen (DO) impairments for some segments (WBIDs). It is expected that the Nutrient FKRAD will support placement of the Florida Keys in category 4b for nutrients (i.e., impaired but no TMDL is required because the waterbody will attain the narrative nutrient criterion as a result of completed or proposed measures as part of an approved Reasonable Assurance) and support placement of the DO impaired segments in category 4e (i.e., impaired but recently completed or ongoing management activities are underway to restore the water body). MANAGEMENT ACTIVITIES STATUS Since 2008, a total of 68 projects have been completed. The status of each project along and a list of new projects are provided in Attachment 1 of the FKRAD Update. Project status is provided for each stakeholder: Monroe County, Key West, Marathon, Key Colony Beach, Layton, Islamorada, Key Largo Wastewater Treatment Authority, US Navy, FDOT and Florida Park Service. It should be noted that the original FKRAD was based partly on compliance with Chapter 99-395, Laws of Florida, which mandated compliance with wastewater treatment requirements by June 2010. However, in 2010, Chapter 2010-205, Laws of Florida (LOF) extended the compliance date to December 2015 (a full summary of Chapter 2010-205, LOF, is provided in the Update). DO REASONABLE ASSURANCE FDEP has identified 10 WBIDs that are impaired for DO, based on exceedance of the marine DO standards (i.e., ambient DO average not less than 5 mg/I in a 24-hour period and not lower that 4 mg/1). For each segment, the ambient biochemical oxygen demand (BOD), total nitrogen (TN) and total phosphorus (TP) do not exceed the estuarine thresholds for each parameter; therefore, FDEP could not identify a causative pollutant. Since the management activities identified in the FKRAD including wastewater and stormwater projects will result in reduced discharges of nutrients and other pollutants to the nearshore waters, it is expected that the ambient DO will also improve. Therefore, the Update provides the needed information to include the 10 WBIDs as category 4e. Information includes identification of DO impaired segments, description of the DO standard, definition of the potential effects of the management activities, schedule to achieve water quality targets, and summary of ongoing monitoring. Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS ^RA December 2011 Section 1.0 BACKGROUND 1.1 PURPOSE OF THE DOCUMENT The purpose of this document is to provide an update to the Florida Keys Reasonable Assurance Plan to document actions taken by stakeholders since 2008 (date of plan acceptance) to return the area's near shore water quality to the targets set for total nitrogen (TN) and total phosphorus (TP). This document also addresses the dissolved oxygen (DO) impairment identified by the Florida Department of Environmental Protection (Department) in some of the water segments for the Florida Keys. This Florida Keys Reasonable Assurance Plan for the Florida Keys (see Figure 1-1) was developed by the Department in cooperation with local governments, state agencies, and federal agencies within the Florida Keys to set forth and accelerate the actions that have been taken or were planned to be taken to reduce nutrient loadings to near shore waters throughout the Florida Keys so that water quality standards are met and beneficial uses are restored. The plan was reviewed and accepted by the Department in 2008 and was sent to EPA for review and comment in February 2009. The Florida Keys Reasonable Assurance Plan was divided into several documents (listed below) and can be found at http://www.dep.state.fl.us/water/watersheds/bmap.htm: Florida Keys Reasonable Assurance Documentation (FKRAD) Northern Report 2. FKRAD Central Keys Report 3. FKRAD South Central Report 4. FKRAD Southern Report 5. Technical Reference Document ARoo a a;,619..a Krr FLORIDA BAY ="'�TAVERNIEk GULF OF MEXICC K..r /15LAMORADA r upp.r Kry loyioh { Ccvnr Y: t.rmh. [ry tan 9 Kay •seneg Kay 5faia Conch Kay Racrgaroaal nraa BIG PINE Gr.-ay K0 oucL Kay . KEY, 11Colony Sac_h h ' ARATH O N Cudlnc Kt,0. Slat. Pork dd3ahunch Kays In accordance with Section i -- cc Chien Kay 62-303.600, F.A.C., the YKEEY WEST FKRAD provided reasonable assurance that Figure 1-1 Florida Keys stakeholders in the Florida Keys have 4 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 provided or would implement sufficient control mechanisms to return the area's impaired waters to the water quality targets for nutrients. To provide reasonable assurance, the following elements were included: ■ Description of the Impaired Water ■ Description of the Water Quality and Aquatic Ecological Goals ■ Description of the Proposed Management Actions to Be Undertaken ■ Estimate or Projection of Time When Water Quality Target(s) Met ■ Description of Procedures for Monitoring and Reporting Results ■ Description of Proposed Corrective Actions The Florida Keys is a chain of islands approximately 220 miles long, extending from the end of the Florida peninsula curving southwest toward the Dry Tortugas. Consisting of 822 islands, of which about 30 are inhabited, the Florida Keys are traversed by U.S. Highway 1 (a.k.a., US 1 or Overseas Highway) with 19 miles of bridges. The Keys are entirely within Monroe County and includes the municipalities of Islamorada, Key Colony Beach, Layton Marathon and Key West. Key West represents about 34 percent (24,650 people) of the population of Monroe County, which, according to the 2010 Census, is about 73,090 people. The Florida Keys is unique in that local runoff is not focused and pollutants are dispersed in the Gulf of Mexico and Straits of Florida. Soils are such that infiltration and percolation are relatively enhanced, moving infiltrated runoff and its pollutants to nearshore waters quickly, yielding little or no nutrient entrapment or treatment in the soils matrix. The limited size of the land area limits the ability to place land intensive stormwater BMPs (such as detention or retention ponds). Also unique to the Florida Keys is the degree to which external farfield pollutants circulating in marine waters impact local waters. Due to the soils, high water table and tides, onsite sewage treatment and disposal systems (OSTDSs), also commonly referred to as aerobic treatment units (ATUs) or septic tanks, have limited treatment capability and "regional" wastewater treatment systems are historically limited to small package plants. Finally, pollutant sources outside of the control of the local governments provide the dominant influence on the receiving waters of the area. In this case, unconventional approaches to pollutant controls are required. Additionally, the Florida Keys have been the subject of significant regional, State and Federal scrutiny and regulatory oversight with most aspects of growth and development reviewed at all levels of government. The nutrient impaired waters (impaired for TN and TP) include Halo zone waters surrounding the Florida Keys that are up to 500 meters offshore and nearshore waters up to 12,100 meters offshore; these waters are Class III (Recreation, Propagation and Maintenance of a Healthy, Well Balanced Population of Fish and Wildlife) and Outstanding Florida Waters (OFW). Waters were originally listed as impaired for nutrients on the 1998 303(d) List. Water Body Identification (WBID) numbers include the following: 11 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 ■ Northern Keys: WBIDs 6019, 6017, 6009, 6006A, 6006B, 6006C, and 6005EB, which are the Halo Zone WBIDs surrounding the islands of Lower Matecumbe Key, Upper Matecumbe Key, Windley Key, Plantation Key and Largo Key. ■ Central Keys: WBIDs 6010, 6011A, 6011B, 6011C, 6012E, and 6016, which are the Halo Zone WBIDs surrounding Marathon, Key Colony Beach, Duck Key and Layton/Long Key. ■ South Central Keys: WBIDs include 6014C, 6013A, 6013B, 6013C, 6013D, 6012A, 6012B, 6012C, 6012D, 6012E, 6010, and 6018, which are the Halo Zone WBIDs surrounding the islands of Boca Chica Key, Saddlebunch Key, Sugarloaf Key, Cudjoe Key, Summerland Key, Ramrod Key, Big Torch Key, Big Pine Key, Long Beach, No Name Key and Bahia Honda Key. ■ Southern Keys: WBIDs include 6014A and 6014E which are the Halo Zone WBIDs surrounding the islands of Key West and Stock Island. The WBID boundaries in the near shore waters of the Florida Keys have gone through a series of changes over time. Historically, the WBIDs were identified by a 8000-series number and were very large. In early 2000, WBIDs were redrawn by local interests to closely surround each island (about 200 meters, 0.12 miles, from the shore) and were represented by a 6000-series number. These "bubbles" around the islands were termed Bubble WBIDs. For the purposes of the FKRAD, the near shore waters include the Bubble WBIDs and other coastal waters out to about 12,000 meters (7.5 miles) from the shore. The applicable water quality standard applied to the impaired waters was the narrative nutrient criteria defined in Chapter 62-302.530(47)(b): "In no case shall nutrient concentrations of a water body be altered so as to cause an imbalance of natural populations of flora and fauna." At the time the FKRAD was submitted to FDEP in 2008, there were no scientifically supported nutrient thresholds that had been defined for aquatic resources in the area. Since that time, using more recent data and research, the Environmental Regulation Commission (ERC) has adopted numeric nutrient standards for the Florida Keys nearshore waters that are generally based on maintaining existing conditions. As noted in the FKRAD, the planned management activities are expected to improve ambient nutrient concentrations once the activities are fully completed. Therefore, the FKRAD and recently adopted Florida numeric nutrient standards should be consistent. Presuming the nutrient standards are eventually approved by EPA, this consistency will be reviewed during the next assessment cycle. Two sets of nutrient targets were originally supported in the FKRAD. Since the farfield sources dominate the nutrient concentrations in nearshore waters, the first target was defined to be an insignificant increase in concentration at 500 meters above natural background, with "insignificant" defined as less than 10 pg/I for TN and 2 pg/I for TP and with "background" defined as the Halo Zone condition in the absence of anthropogenic loads. A second target was set based on the OFW designation, with the target set at the Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 average of values measured at the nearshore ambient nutrient concentrations at 500 meters during the year (1985) the Florida Keys was designated as an OFW. A stakeholder process was implemented during the preparation of the FKRAD. The stakeholder process provided an opportunity for local, regional, state and federal governments (as well as other third party interest) to: understand the reasonable assurance process; provide data and research input into the development of the FKRAD documentation; and confirm that the FKRAD reasonably expresses the committed activities of the stakeholders. The list of completed and proposed management actions in the FKRAD included wastewater projects, stormwater programs and regulatory requirements committed by the stakeholders. The management actions specified in the FKRAD were projected to provide the following nutrient load reductions as shown in Table 1-1: Table 1-1: FKRAD Pollutant Load Summary Nutrient Anthropogenic Loading After % Loading Loading (Ibs/yr) Management Reduction Actions (Ibs/yr) Total Nitrogen 965,724 360,939 63% Total Phosphorus 246,368 67,840 73% Water quality targets (OFW condition restoration and insignificant increase above farfield concentrations) are expected to be achieved by 2020. All committed wastewater and stormwater management activities will be completed by 2015. Monitoring will be completed via a number of ongoing ambient water quality and biological assessment stations throughout the Florida Keys; monitoring will be implemented by the Department, the South Florida Water Management District (SFWMD), and the Florida Keys National Marine Sanctuary (FKNMS); results are reported to the FKNMS Sanctuary Advisory Council with studies by the Florida Marine Research Institute (FMRI) and the Florida Figure 1-2 Planning Units International Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 University (FIU) via the Water Quality Protection Program (WQPP). Monitoring will be reported to the FKNMS Steering Committee. This document provides an update to the Florida Keys Reasonable Assurance Plan and addresses the DO impairment identified by the Department for the Upper, Middle and Lower Keys planning units (Figure 1-2). Section 2 and Section 3 describe the DO impairment and water quality standards for DO. Section 4 provides an update on the proposed management actions. Section 5 provides a schedule to achieve water quality targets and Section 6 describes monitoring efforts. For the purpose of this document, the stakeholders include the Village of Islamorada, Key Largo Wastewater Treatment District for unincorporated Monroe County, City of Marathon, City of Key Colony Beach, City of Layton, City of Key West, Monroe County, US Navy, Florida Department of Transportation (FDOT) District VI, and Florida State Parks Service. 1.2 Activities since the Florida Keys Reasonable Assurance Documentation Adoption Since the time that the 2008 FKRAD was accepted by the Department, a number of activities have occurred. These are described in general terms and are further discussed in more detail throughout the document. Since 2008, implementation of activities to reduce nutrient loadings to near shore waters has been successful. In addition to the progress reported prior to FKRAD implementation, a total of 68 projects have been completed. Many are still ongoing and are anticipated to be complete between 2011 and 2015. The majority of the completed projects are wastewater related although there are several stormwater projects that have been completed as well. In addition to stakeholder activities, a number of related regulatory actions have occurred. In the FKRAD, enforcement and oversight by the Florida Department of Health (FDOH) provided reasonable assurance for achieving non -voluntary wastewater management actions on the private facility level. Chapter 99-395, Laws of Florida (LOF) requires FDOH to conduct enforcement actions against private owners of cesspits and non -complying OSTDSs that have failed. Cesspit elimination is mandated by Chapter 99-395, LOF as part of the Keys -wide initiative to improve Halo Zone water quality. Non -complying on -site systems also require that their owners undertake action to avoid violating Chapter 99-395, LOF. Since the FKRAD was initially approved by the FDEP, this law has been amended. Specific changes to this law and its impact on reasonable assurance activities are discussed in Section 4. Since acceptance of the FKRAD in 2008, the Department has completed the Draft Cycle 2 Assessment of Impaired Waters for Group 5 (which includes the Florida Keys). As part of the draft assessments, the Department has identified several WBIDs in the Florida Keys as impaired for DO. These WBIDs are currently assigned to Assessment Category 4e, which represents waterbodies that have been identified as impaired applying the Impaired Waters Rule; however, there are on -going or recently completed activities to restore the waterbody. The Department will not verify waterbodies as impaired or develop TMDLs for waters that will attain water quality standards in the future and reasonable progress towards attainment will be made prior to the next assessment cycle (Rule 62-303.100(5), F.A.C.). Waterbodies 7 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 that meet this condition are placed into category 4a, and waters where ongoing restoration activities should restore the designated uses of the waterbody are placed in Category 4e. It is anticipated that this final list of impaired waters will be adopted by Secretarial Order in January 2012. Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS AFFKRAD December 2011 Section 2.0 IDENTIFICATION OF DISSOLVED OXYGEN IMPAIRED WATERS 2.1 UNDERSTANDING OF IMPAIRMENT IN THE FLORIDA KEYS This section provides a description of the impaired waters, recent information showing the DO impaired waters, and a consideration of the pollutants and suspected sources. 2.1.1 Problem Definition The Bubble WBID and nearshore waters within the Florida Keys are designated Class III (Recreation, Propagation and Maintenance of a Healthy, Well -Balanced Population of Fish and Wildlife) and, except for interior canals, Outstanding Florida Waters (OFW). The operative criteria are listed in Chapter 62-302.530(47), F.A.C. (criteria for Class III) and Chapter 62.4-242(2), F.A.C. (criteria for OFW). The 1998 303(d) List of Impaired Surface Waters records "the Florida Keys" as impaired for nutrients, with no other specificity. The Florida Keys Reasonable Assurance Plan for the Florida Keys addressed nutrient impairment, specifically TN and TP, for the Florida Keys nearshore waters. Since that time the Department has identified multiple WBIDs as being impaired for DO. As defined in Chapter 62-302.530(30), F.A.C., the ambient DO in marine waters is not to average less than 5.0 mg/I in a 24-hour period and not be less than 4.0 mg/l. 2.1.2 Impaired Waters The Department has determined that DO is impaired for multiple WBIDs (See Table 2-1 below) in the Florida Keys based on exceedance/sample size ratio meeting the verification requirements in Chapter 62-303.420, F.A.C., of the Impaired Waters Rule (IWR). Table 2-1: Florida Keys WBIDs in category 4e for DO Planning Unit WBID Water Segment Name Verified Period Assessment Data Upper Keys 6006A South Key Largo 21/92 Upper Keys 6006C North Key Largo 5/19 Upper Keys 6009 Plantation Key 12/31 Middle Keys 6010 Long Key 6/24 Middle Keys 6011A Vaca Key 185/369 Middle Keys 6011C Grassy Key 8/20 Lower Keys 6012A Big Pine Key 9/31 Lower Keys 6012C No Name Key 3/4 Upper Keys 6017 Upper Matecumbe Key 8/28 Upper Keys 6019 Lower Matecumbe Key 5/17 This column shows the number of DO exceedances over the sample size Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 As part of the DO assessment, the Department evaluates available biological data, calculates regressions, and is required to identify a causative pollutant TN, TP, or biochemical oxygen demand (BOD) in order to place a waterbody on the verified list. The thresholds used to assist in identifying a causative pollutant (TN, TP, or BOD) for DO are based on the 70t" percentile of data collected statewide. For WBIDs that fall within the Everglades and South region of the state (including the Florida Keys) FDEP uses the threshold values in Table 2-2 below. Figures 2-1, 2-2, and 2-3 below show the sampling locations for each impaired WBID for the Lower Keys, Upper Keys and Middle Keys, respectively. Table 2-2: Threshold Values for Nutrient Parameters by Waterbody Type WATER TYPE BOD TN TP Lake 2.9 1.7 0.11 Coastal 2.1 1.0 0.19 Estuary 2.1 1.0 0.19 Spring 2.0 1.6 0.22 Stream 2.0 1.6 0.22 Blackwater 2.0 1.6 0.22 In the case of the 10 WBIDs listed in Table 2-1, the Department could not identify a causative pollutant for the DO impairments because the TN, TP, and BOD medians were below the estuarine threshold values. Furthermore, when DO is impaired and a causative pollutant cannot be determined, the Department typically would consider placing the waterbody in assessment category 4d (no causative pollutant) for further investigation. However, the restoration activities set forth in the FKRAD to address nutrient impairments are expected to have an ancillary benefit of reducing the anthropogenic pollutant loads impacting DO, thus the Department has placed these WBIDs in assessment category 4e (Ongoing Restoration Activities). These ancillary benefits are discussed in more detail in Section 4. .;. W Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 Lower Keys (DO 4e Wffl - V Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS O�FK 5A��D' December 2011 W91D 6006C (North Key Largo) WBD 6009 {Plantation Key) 0 2.5 5 10 Miles 6017 (Upper Matecumbe Key) wumber Key) Q DO 4e WBIDs Stations u r Figure 2-2 — Upper Keys WBID's 11 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS CFKRAID December 2011 MID GO ti AO AjV QDO4eMIN � Stations 0 1.25 2.5 5 Miles u ' Figure 2-3 — Middle Keys WBID 12 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS ((F December 2011 Section 3.0 DESCRIPTION OF WATER QUALITY STANDARDS FOR DISSOLVED OXYGEN 3.1 WATER QUALITY STANDARDS This section defines the water quality standards used to evaluate the degree to which management activities result in the attainment of the water quality criterion. The applicable water quality standards, resource targets and selected targets are discussed below. 3.1.1 Florida Water Quality Standards — Dissolved Oxygen The nearshore waters in the Florida Keys are classified as Class III (Recreation, Propagation and Maintenance of a Healthy, Well -Balanced Population of Fish and Wildlife), and have been designated as an OFW. These designations are discussed further in the 2008 Technical Reference Document, Appendix A, completed as part of the FKRAD. For these waters, the applicable water quality standard is Chapter 62-302.530(30), F.A.C., which states that DO in Class III marine waters: "Shall not average less than 5.0 milligrams/liter in a 24-hour period and shall never be less than 4.0 milligrams/liter. Normal daily and seasonal fluctuations above these levels shall be maintained." 3.1.2 Antidegradation Antidegradation policies are intended to maintain the existing uses and the level of water quality necessary to protect those uses. The policies that discuss antidegradation are contained within Chapters 62-302.300 and 62-4.242, F.A.C. As discussed in these sections, a new or existing discharge may be permitted if: the discharge will not lower water quality below the established classification; degradation is necessary or desirable under federal standards and under circumstances which are clearly in the public interest; and if all other Department requirements are met. In determining whether a proposed discharge, which results in water quality degradation, is necessary or desirable under federal standards and under circumstances which are clearly in the public interest, the Department shall consider and balance the following factors: 1. Whether the proposed project is important to and is beneficial to the public health, safety, or welfare; and 2. Whether the proposed discharge will adversely affect conservation of fish and wildlife, including endangered or threatened species, or their habitats; and 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; and 13 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 4. Whether the proposed discharge is consistent with any applicable Surface Water Improvement and Management Plan (SWIM) that has been adopted by a Water Management District and approved by the Department. 3.2 RESTORATION OF THE DESIGNATED USES OF THE IMPAIRED WATERS - DISSOLVED OXYGEN The resulting water quality in the canals, after the completion of the management activities identified in the FKRAD, is unknown. The Department expects that the conditions in the canals will improve for both nutrients as well as DO. However, due to the varying nature of the canals with poor circulation, weed wrack, organic sediments and water depth, the Department also recognizes that the ambient DO concentrations in the canals will likely not achieve Class III marine DO standards even after the management activities have been completed. As a result, the Department intends to continue to work with the FKNMS in the study of potential improvements to the canals, beyond the management activities listed herein, and evaluate whether reclassification of the canals to Class III -Limited is appropriate. .;. 14 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS ^RA December 2011 Section 4.0 DESCRIPTION OF PROPOSED MANAGEMENT ACTIONS TO BE UNDERTAKEN 4.1 NAMES OF THE RESPONSIBLE PARTICIPATING ENTITIES There are a total of ten stakeholders participating in the FKRAD documentation process including: ® Key Largo Wastewater Treatment District (WBIDs 6006A and 6006B) ■ Islamorada, Village of Islands (WBIDs 6009, 6017 and 6019) ® City of Key Colony Beach (WBID 6011 B) ® City of Layton (WBID 6010) ® City of Marathon (WBIDs 6011A and 6011C) ® City of Key West (WBID 6014A) ® Monroe County (WBIDs 6006B, 6006C, 6010, 6016 6012A/B/C/D/E, 6013A/B/C/D, 6014B,6014C, and 6018) ® Florida Department of Transportation, District VI (WBIDs 6006A, 6006B, 6006C, 6009, 6010, 6011 A, 6011 B, 6011 C, 6012A/B/C/D, 6013A/B/C/D, 6014A, 6014B,6014C, 6016, 6017, 6018 and 6019) ® Florida State Parks System (WBIDs 6016, 6017 and 6018) ® United States Navy (WBIDs 6014A, 6014C) 4.2 UPDATE OF PROPOSED MANAGEMENT ACTIVITIES DESIGNED TO ADDRESS NUTRIENTS As previously discussed, the Florida Keys are unlike any other watershed in Florida in terms of the relationship of watersheds to receiving waterbodies, dispersion versus concentration of nutrients, and the predominance of farfield sources on local water quality. Consequently, there are a number of important concepts that were presented in the FKRAD relative to the management actions in the Florida Keys: a Water quality in the nearshore waters is dominated by farfield sources that are a combination of naturally occurring nutrient loads and anthropogenic sources located outside of the Florida Keys. ® Farfield sources are not within the control of the residents of the Florida Keys. ® Water quality in the Halo Zone waters (the area from the beach to line approximately 500 meters off the shoreline) are incrementally affected by a combination of natural 15 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS FKRAD December 2011 stormwater discharges originating on undeveloped areas and anthropogenic discharges from developed land with loads attributable to wastewater and stormwater management practices from developed properties. ® Water quality in the Halo Zone waters are also incrementally affected, though to a much lesser degree, by nutrients discharged via stormwater from existing natural areas. s Management actions proposed in the FKRAD focused specifically on the reduction or elimination of the anthropogenic nutrient loads being discharged to the Halo Zone waters in the defined "bubble" WBIDs. ® No attempt to reduce farfield impacts was incorporated into the FKRAD as these strategies are outside to the implementation abilities of the governments of the Florida Keys. Management activities were classified into three different categories: wastewater management practices; stormwater management practices; and regulatory programs. The implemented and anticipated management actions are summarized in Table 4-1. Table 4-1: General Management Actions Wastewater Management P Practices Stormwater Management Practices Regulatory Programs ■ Elimination of Cesspits ■ Retrofitting Existing Drainage ■ Designation as an "Area of ■ Centralized Wastewater Systems with Stormwater Critical State Concern" Services Treatment prior to Outfall to ■ Local Development and ■ Upgraded Privately Owned Halo Zone Waters Redevelopment Regulations Wastewater Systems ■ Retrofitting Existing Drainage . Enforcement of Chapter 99- ■ Class Deep Injection Well Systems with Stormwater 395, LOF amended as for Disposal of Wastewater Treatment and Stormwater ter 2010-205, LOF Chapter p ) Effluent (Replacing Existing N Disposal Wells o Direct p ( Requirements by FDEP and Ocean Outfall) Outfall to Halo Zone) FDOH ■ Marine Pump -Out Service for ■ Incorporation of Treatment Chapter 62, F.A.C., including Moored Boats to Reduce Illicit Components in New OFW (Chapter 62-302.700, p Discharges Transportation Projects F.A.C( ) The collective effect of the wastewater and stormwater management actions proposed in the FKRAD represented a significant effort for removing the 1999 baseline anthropogenic stormwater nutrient load that was identified for the Florida Keys. Continued application of proposed management actions will also limit the additional nutrient loading associated with the anticipated future new growth and redevelopment within the Florida Keys. Baseline nutrient loading and future nutrient loading estimates provided in the FKRAD are generally shown in Table 4-2. of Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 Table 4-2: Estimated Nutrient Loadinas in the Florida Total Anthropogenic Nutrient Load Total Nitrogen Total Phosphorus (Ibs/year) (Ibs/year) 1 1999 Baseline Condition 1 965,724 1 246,368 1 July 1, 2015 I 363,605 I 68,249 Excludes anticipated but as yet unquantified reductions from existing and anticipated stormwater management practices Documentation of the estimated pollutant load reduction and other benefits anticipated from implementation of individual management actions by stakeholders were documented in the FKRAD. The stakeholders felt confident that the FKRAD provided reasonable assurance that water quality targets will be met in the watershed because the plan specifically removed/reduced the known anthropogenic sources of the pollutants of concern. As part of this addendum, stakeholders were contacted and requested to provide an update on the status of the proposed future management projects originally outlined in the Stakeholder Agreements contained within Exhibit 1 of the FKRAD. Stakeholders provided feedback on the implementation status of each project and actual dates of completion. If a project had been delayed or substituted for any reason, an explanation and a revised date of implementation were provided. This information is provided in Attachment 1 and is organized by Florida Keys region (e.g., northern, central, south central and southern). Management practices already implemented at the time of original FKRAD development are not included in Attachment 1. In general, many of the projects have been completed by the stakeholders. Several projects are ongoing while funding is still being pursued for some projects. Wastewater projects that are still pursuing funding are anticipated to be completed no later than December 2015 when entities are required to comply with discharge standards. Information was provided by the Florida Division of Recreation & Parks (FDRP) and the FDOT, District VI on many completed and proposed projects that were not previously included in the Stakeholder Agreements of the original FKRAD. For the FDRP, these included: the conversion of standard septic tanks to Florida Department of Health (FDOH) ATU septic tank systems and abandonment of State Park wastewater treatment facilities and using the local utility provider at several State Parks throughout the Florida Keys. For FDOT, District VI, projects consisted mainly of road improvements, drainage projects and drainage improvements. Additionally, the City of Layton met all of its project commitments at the time that the 2008 FKRAD was accepted and therefore does not have any projects listed in Attachment 1. 17 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS 0F K R A D December 2011 4.3 ANTICIPATED BENEFITS TO ADDRESS THE DISSOLVED OXYGEN IMPAIRMENT The physical and operational nature of the implemented and soon -to -be completed management actions will provide additional benefits, beyond reduction of nutrient concentrations. Along with the reduction of nutrients, it is anticipated that ongoing restoration activities will address the anthropogenic pollutant loads impacting DO. However, it should be noted that even with restorative activities in place, these waterbodies may not meet the applicable DO criteria due to the physical structure of the canal system. Other anticipated benefits of restoration activities include: ■ Ancillary reduction of other (non -nutrient) pollutants; ■ Trash collection/removal; ■ Leaf collection and net pollutant load reduction ■ Potential reduction of Inflow to the wastewater collection system; ■ Improvement of ambient Halo Zone water quality; and, ■ Improvement of ambient Canal water quality. 4.4 AGREEMENTS COMMITTING PARTICIPANTS TO THE MANAGEMENT ACTIONS Copies of the written agreements committing participants to the management actions are contained in the Stakeholders Agreement. These can be found in Exhibit 1 of the original FKRAD reports for the Northern, Central, South -Central and Southern Keys. 4.5 CHANGES TO CHAPTER 99-395, L.O.F. On June 18, 1999, Governor Bush approved Chapter 99-395, LOF. A portion of Chapter 99-395 provides requirements for wastewater facilities and OSTDSs in Monroe County. In general, provisions are given for monitoring at sewage treatment facilities for TN and TP beginning on October 1, 1999; elimination of existing water discharges before July 1, 2006; and compliance of existing sewage facilities that discharge to areas other than surface waters to cease discharge or meet specified standards by July 1, 2010. On June 4, 2010, Governor Christ approved Chapter 2010-205, LOF. A portion of Chapter 2010-205 includes amendments to specific sections of the Florida Statutes (FS) as well as repealing of portions of Chapter 99-395 — these amendments and repeals are summarized below. ■ Section 215.619, Florida Statutes (FS), was amended and provides clarification on bonding capacity and the purposes for which the bond proceeds may be expended. This includes the issuance of bonds to be used to finance the 18 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS F K R A D December 2011 management of sewage facilities in the Florida Keys Area of Critical State Concern. ■ Section 380.0552, FS, was amended to revise legislative intent relating to the designation of the Florida Keys as an Area of Critical State Concern. It revises conditions and procedures for removing the designation, Area of Critical State Concern, from the Florida Keys including reporting requirements beginning on November 30, 2010 by the Division of Community Planning. This amendment authorizes the Administration Commission to review the report and determine whether the designation should be removed. Also, this amendment revises compliance requirements for reviewing comprehensive plan amendments. ® Section 381.0065 FS was amended to change the compliance dates for certain activities. OSTDSs must cease discharge by December 31, 2015, or comply with new discharge standards including monitoring for total nitrogen and total phosphorus concentrations. It requires disinfection standards for OSTDSs discharging to an injection well. It requires that on or after July 1, 2010, all new, modified, or repaired OSTDSs comply with discharge standards; however, if a property is scheduled for central sewer connection by December 31, 2015, and the owner has paid an assessment or connection fee, the owner will be required to meet minimum standards for the OSTDSs until connection to the central sewer. Land application of septage is prohibited effective January 1, 2016. ® Section 381.00656 FS was created to provide for a low-income grant program for septic tank maintenance and replacement. ® Section 381.0066 FS was amended to authorize the FDOH to collect an evaluation report fee and for the report fee to be revenue neutral. ® Section 403.086 FS was amended to require the Department to submit a report on the effects of reclaimed water use, clarifying reuse requirements for domestic wastewater facilities that discharge through ocean outfalls, clarifying reuse requirements for domestic wastewater facilities that divert wastewater from facilities discharging through ocean outfalls, providing legislative findings and discussing discharge requirements for wastewater facilities in Monroe County. By December 31, 2015, Monroe County, each municipality and those special districts established for the purpose of collection, transmission, treatment, or disposal of sewage in Monroe County must complete the wastewater collection, treatment, and disposal facilities designated as hot spots in the Monroe County Sanitary Master Wastewater Plan, dated June 2000. Domestic wastewater facilities located outside local government and special district service areas must meet treatment and disposal requirements by December 31, 2015. Also, all wastewater treatment facilities in operation after December 31, 2015, must comply with the treatment and disposal requirements of Section 403.086 and Department rules. ® Sections 5 and 6 of Chapter 99-395, LOF were repealed because these sections were superseded with the approval of Chapter 2010-205. Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS ^RA December 2011 Section 5.0 SCHEDULE TO ACHIEVE WATER QUALITY TARGETS 5.1 ACHIEVING WATER QUALITY TARGETS - DISSOLVED OXYGEN As previously discussed, the nutrient concentrations in the Halo Zone and nearshore waters are dominated by farfield effects and anthropogenic sources of nutrients in the Florida Keys. Water quality in the halo zone waters are incrementally affected by a combination of natural stormwater discharges originating on undeveloped areas and anthropogenic discharges from developed land with loads attributable to wastewater and stormwater management practices from developed areas. The management activities discussed in Section 4 will help to reduce or eliminate anthropogenic nutrient loads to the halo zone waters. An ancillary benefit of the management activities is improved DO in the inland canals. It is expected that the ambient DO in the inland canals will improve but may not achieve Class III marine DO standards. The exact condition of the canals after the completion of the management activities is unknown but, as stated before, is expected to be better (i.e., increased ambient DO) than the baseline condition. As discussed in Section 3, the nearshore waters are classified as Class III and have been designated an OFW. By returning to an OFW condition, this restoration is consistent with OFW requirements. 5.2 SCHEDULE TO ACHIEVE TARGETS - DISSOLVED OXYGEN The management actions discussed herein, to be completed by the signatories, will be completed in 2015. It is expected that the effects of these actions will be seen and will achieve the TN and TP water quality targets in the Halo Zone waters for all of the Florida Keys in 2020. As it relates to the inland canals, it is expected that the conditions of these canals will improve for both nutrients as well as DO during this timeframe. Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS F K R A D December 2011 Section 6.0 MONITORING RESULTS 6.1 SUMMARY OF EXISTING MONITORING Monitoring and reporting activities provides the basis for establishing the water quality improvements that will be achieved through implementation of the management actions described in Section 4. Monitoring, including both the sampling of water quality in the receiving waters and the oversight of management action implementation and operation, provides the data and information required to assess improvements and compliance with the plan. Reporting activities maintain a continuous flow of performance information that supports adaptive management efforts as may be required to achieve the anticipated benefits. The primary network of interest for the Florida Keys is the FKNMS Water Quality Monitoring Program network, operated by the Florida International University (FIU) Southeastern Environmental Research Center (SERC). The central portion of this network includes "local" stations that have been sampled quarterly since 1995. These stations can be used to define long-term nutrient concentration trends in the waters that are most immediate to the WBIDs of interest, including the Halo Zone and the more immediate nearshore waters. There are 95 stations within this network that are within the Florida Keys TMDL Planning Units as shown_ in Figure 6-1. The 2009 Annual Report of the Water Quality Monitoring Project for the Water Quality Protection Program of the Florida Keys National Marine Sanctuary (FIU, 2010) summarizes the period of record from March 1995 through December 2009 and includes data from 58 quarterly sampling events at 155 stations within the FKNMS and southwest Florida shelf, including the Dry Tortugas National Park. Field parameters measured at each station include salinity (practical salinity scale), temperature (°C), dissolved oxygen (DO, mg/1), turbidity (NTU), relative fluorescence, and light attenuation (Kd, m-'). Water quality variables include the dissolved nutrients nitrate (NOO, nitrite (NOZ ), ammonium (NH4+), dissolved inorganic nitrogen (DIN), and soluble reactive phosphate (SRP). Total unfiltered concentrations include those of nitrogen (TN), organic nitrogen (TON), organic carbon (TOC), phosphorus (TP), silicate POD and chlorophyll a (CHLA, pg/1). The EPA developed Strategic Targets for the Water Quality Monitoring Project which state that beginning in 2008 through 2011, they shall annually maintain the overall water quality of the near -shore and coastal waters of the FKNMS according to 2005 baseline. For all monitoring sites in FKNMS, dissolved inorganic nitrogen should be less than or equal to 0.75 micromolar (0.01 mg/1) and TP should be less than or equal to 0.2 micromolar (0.077 mg lI . Table 6-1 provides a summary of the compliances with EPA targets over time. ►14l 6 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 Figure 6-1 FKNMS WQMP Sampling Sites Table 6-1: EPA WQPP Water Quality Targets* Year DIN <_ 0.75 pM** (0.010 mg/1) TP <_ 0.25 pM** (0.0077 mg/1) 1995-05 7923 of 10254 (76.3%) 8304 of 10267 (80.9%) 2006 432 of 990 (43.7%) 312 of 995 (31.3%) 2007 556 of 993 (60.0%) 608 of 941 (64.7%) 2008 836 of 1;000(83.6%1 685 of 1,004 (68.2%) 2009 909 of 1,10)�82.5%0� 889 of 1,102 (80.7%) * Taken from 2009 Annual Report of the Water Quality Monitoring Project for the Water Quality Protection Program of the Florida Keys National Marine Sanctuary (FIU, 2010) ** Values in green are those years with % compliance greater than 1995-2005 baseline. Values in yellow are those years with % compliance less than 1995-2005 baseline. 22 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 Table 6-1 shows that, although the TP results have not met the percent compliance target for the 1995-2005 baseline, the results have been significantly improving since 2006. The 2009 results were just shy of the 1995-2005 baseline target of 80.9 percent. DN results show that the compliance target was met in 2008 and 2009. It is important to note that these results represent data from all the sampling stations in the FKNMS (including southwest Florida shelf and the Dry Tortugas National Park), and is just not representative of the Florida Keys themselves. The study also noted that for 2009, in all regions of the FKNMS, water quality has returned to conditions prior to 2005 hurricane season. Summary statistics for all water quality variables for all 58 sampling events were reported as the median, minimum, maximum and number of samples. On this coarse scale, the FKNMS exhibited very good water quality with median NO3 -, NH4 +, TP, and Si02 concentrations of 0.001, 0.003, 0.006, and 0.009 mg/ I, respectively. Summary statistics for TN and TP for the 2009 period of record are provided in Table 6-2. Table 6-2: FKNMS Summary Statistics* Variable Depth Median Min. Max. n Surface 0.173 0.036 0.584 722 TN (mg/1) Bottom 0.159 0.019 0.948 382 Surface 0.006 0.001 0.038 722 TP (mg/1) Bottom 0.005 0.001 1 0.020 1 380 * Taken from 2009 Annual Report of the Water Quality Monitoring Project for the Water Quality Protection Program of the Florida Keys National Marine Sanctuary (FI U, 2010) 6.2 METHODS FOR EVALUATING PROGRESS TOWARDS GOALS Procedures to be used in the Florida Keys for monitoring implementation progress and water quality improvements focus on the elimination of substandard wastewater treatment practices (pursuant to Chapter 99-395 and Chapter 2010-205) and corresponding changes in ambient water quality in the canals, halo zone and nearshore waters. The monitoring program for the Florida Keys primarily requires the efforts of the central wastewater system operators and the operators of the existing FKNMS and Florida Bay ambient water quality monitoring networks. The monitoring program proposed in the FKRAD focused upon immediate measurement of the benefits being produced by implementation of the proposed management activities outlined below. Given the DO impairment for the Florida Keys, monitoring should also include reporting of this parameter. Review of the FKNMS WQPP indicates that this parameter is already being sampled on a quarterly basis via these three items that are listed here and discussed below: 1) Total Wastewater Service Level; 2) Ambient Bubble WBID Water Quality Trends; and 3) Nearshore Water Quality Trends. Total Wastewater Service Level. This is the basic measure of net nutrient reductions being achieved in the Florida Keys via capital projects. 23 Lj Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 2. Ambient Bubble WBID Water Quality Trends. These are measured in the Halo Zone WBID waters and the more immediate nearshore waters (at distances up to 5,600 meters off the shoreline), which demonstrate localized water quality improvement in the "backyard" of the Florida Keys. Specific measures of progress include quarterly measurement of TN, TP and DO concentrations at the existing stations in the existing FKNMS and Florida Bay monitoring networks (currently operated by FIU/SERC) that are generally located inside of the Halo Zone WBIDs and nearshore waters at distances up to 5,600 meters off the shoreline. 3. Nearshore Water Quality Trends. These are measured in the existing FKNMS and Florida Bay nearshore waters monitoring stations located in the nearshore waters (at distances greater than 5,600 meters off the shoreline). These trends generally indicate the water quality changes in the marine environment outside the general impact of Keys discharges are attributable to changing farfield loadings. Specific measures of progress include quarterly measurement of TN, TP and DO concentrations at the existing stations in the existing FKNMS and Florida Bay monitoring networks (currently operated by FIU/SERC) that are generally located outside of the halo zone WBIDs at distances greater than 5,600 meters off the shoreline. A comprehensive update of the wastewater and infrastructure improvements were summarized in Section 4 while a summary of existing ongoing water quality monitoring was previously provided in Subsection 6.1. The Department will continue to use water quality data results from the networks previously described, as available and appropriate, to evaluate the progress of the implemented management actions toward meeting water quality management goals. Aggregated data will be interpreted using graphical and statistical methodologies. 24 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS JFK I A D December 2011 ATTACHMENT 1 Summary of Status of Completion for Proposed Management Practices Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION UPDATE FLORIDA KEYS 0!KAD December 2011 Attachment 1 SUMMARY OF STATUS OF COMPLETION FOR PROPOSED MANAGEMENT PRACTICES FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date NORTHERN KEYS PROPOSED FUTURE MANAGEMENT PRACTICES Construction of the North Plantation Key Phase II central wastewater collection system, to be 6009 connected to the existing North August 2008 October Project completed. Plantation Key AWT treatment 2009 facility and shallow Class V effluent disposal well serving approximately 1,100 EDUs Islamorada Construction of the South Islamorada, Village of Islands is pursuing construction of a central wastewater Plantation Key central wastewater collection and treatment system for the entire Village (outside of the existing North collection system, 0.300 MGD AWT December December Plantation Key Phase I and Phase II service areas) through a Design Build 6009 treatment facility and shallow Class 2010 2015 Operate Finance (DBOF) process. Per the issued Request for Proposals, central V effluent disposal well serving wastewater shall be available throughout the entire Village by December 1, 2015. approximately 1,900 EDUs Construction phasing will be the responsibility of the selected DBOF firm. [Islamorada] Construction of the Lower Islamorada, Village of Islands is pursuing construction of a central wastewater Matecumbe Key central collection and treatment system for the entire Village (outside of the existing North wastewater collection system, December December Plantation Key Phase I and Phase If service areas) through a Design Build 6019 0.250 MGD AWT treatment facility 2012 2015 Operate Finance (DBOF) process. Per the issued Request for Proposals, central and shallow Class V effluent wastewater shall be available throughout the entire Village by December 1, 2015. disposal well serving approximately Construction phasing will be the responsibility of the selected DBOF firm. 1,600 EDUs Islamorada A-1 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Construction of 2.3 MGD AWT 6006A treatment facility with disposal in a May 2009 October Project completed. deep Class V effluent disposal well 2010 KLWTD Construction of the Basin A central wastewater collection system serving 1,323 EDUs with September 6006A subsequent connection to the 2.3 May 2009 2010 Project completed. MGD AWT treatment facility with finished effluent disposal in a deep Class V well KLWTD Construction of the Basin B central wastewater collection system serving 1,861 EDUs with September 6006A subsequent connection to the 2.3 May 2009 2010 Project completed. MGD AWT treatment facility with finished effluent disposal in a deep Class V well [KLWTD] Construction of the Basin D central wastewater collection system serving 2,548 EDUs with September 6006A subsequent connection to the 2.3 May 2009 2010 Project completed. MGD AWT treatment facility with finished effluent disposal in a deep Class V well KLWTD Construction of the Basin C central wastewater collection system serving 1,207 EDUs with October October 6006A subsequent connection to the 2.3 2009 2010 Project completed. MGD AWT treatment facility with finished effluent disposal in a deep Class V well KLWTD] A-2 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Construction of the North Upper Islamorada, Village of Islands is pursuing construction of a central wastewater Matecumbe Key central collection and treatment system for the entire Village (outside of the existing North wastewater collection system, to be Plantation Key Phase I and Phase II service areas) through a Design Build 6017 connected to the proposed Upper December December Operate Finance (DBOF) process. Per the issued Request for Proposals, central Matecumbe Key AWT treatment 2012 2015 wastewater shall be available throughout the entire Village by December 1, 2015. facility and shallow Class V effluent Construction phasing will be the responsibility of the selected DBOF firm. disposal well serving approximately 1,100 EDUs Islamorada Construction of the South Upper Islamorada, Village of Islands is pursuing construction of a central wastewater Matecumbe Key central collection and treatment system for the entire Village (outside of the existing North wastewater collection system, December December Plantation Key Phase I and Phase II service areas) through a Design Build 6017 0.600 MGD AWT treatment facility 2012 2015 Operate Finance (DBOF) process. Per the issued Request for Proposals, central and shallow Class V effluent wastewater shall be available throughout the entire Village by December 1, 2015. disposal well serving approximately Construction phasing will be the responsibility of the selected DBOF firm. 2,700 EDUs Islamorada Construction of the Basin E (Phase ll) central wastewater collection system serving 999 EDUs with October September 6006A subsequent connection to the 2.3 2009 2010 Project completed. MGD AWT treatment facility with finished effluent disposal in a deep Class V well KLWTD Construction of the Basin F central wastewater collection system serving 1,111 EDUs with September 6006A subsequent connection to the 2.3 June 2010 2010 Project completed. MGD AWT treatment facility with finished effluent disposal in a deep Class V well KLWTD A-3 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Construction of the Basin G central wastewater collection system 6006A serving 1,625 EDUs with subsequent connection to the 2.3 September 2011 G1, G2, G5 (Mar-11); G3 (Jul-11); G4 (Apr-11) MGD AWT treatment facility with 2010 finished effluent disposal in a deep Class V well KLWTD Construction of the Basin H central wastewater collection system serving 737 EDUs with subsequent January 6006A connection to the 2.3 MGD AWT 2011 March 2011 Project completed. treatment facility with finished effluent disposal in a deep Class V well KLWTD Initial connection of John The John Pennekamp Coral Reef State Park WWTP was decommissioned, Pennekamp State Park to KLWTD abandoned and removed in 2010 and the entire Park's wastewater flows are now 6006A central wastewater collection June 2010 June 2010 being transmitted, received and handled by the KLWTD AWT(see Florida State system serving 167 EDUs in Parks entry for WBID 6006B). Basins A-C KLWTD Construction of the Windley Key Islamorada, Village of Islands is pursuing construction of a central wastewater central wastewater collection collection and treatment system for the entire Village (outside of the existing North system, 0.140 MGD AWT December Plantation Key Phase I and Phase II service areas) through a Design Build 6009 treatment facility and shallow Class March 2011 2015 Operate Finance (DBOF) process. Per the issued Request for Proposals, central V effluent disposal well serving 900 wastewater shall be available throughout the entire Village by December 1, 2015. EDUs [Islamoradal Construction phasing will be the responsibility of the selected DBOF firm. Final connection of John The John Pennekamp Coral Reef State Park WWTP was decommissioned, Pennekamp State Park to KLWTD January abandoned and removed in 2010 and the entire Park's wastewater flows are now 6006A central wastewater collection 2011 June 2010 being transmitted, received and handled by the KLWTD AWT (see Florida State system serving 43 EDUs in Basins Parks entry for WBID 6006B). C-H KLWTD Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Construction of the Basin K central wastewater collection system serving 1,080 EDUs with 6006A subsequent connection to the 2.3 July 2011 N/A Basin K was merged with Basin J. Basin "JK" consists of 9 phases. MGD AWT treatment facility with finished effluent disposal in a deep Class V well KLWTD Construction of the Basin I central wastewater collection system serving 1,910 EDUs with October 6006A subsequent connection to the 2.3 2011 2010/2011 Oceanside (Jan-11)•; Bayside (Nov-10); 15 (Jul-11) W MGD AT treatment facility with finished effluent disposal in a deep Class V well KLWTD Construction of the Basin J central wastewater collection system 6006A serving 893 EDUs with subsequent connection to the 2.3 MGD AWT December 2011 JK2, JK6, JK7, JK9, (Jul-1 I); JK-1, JK-4 (Aug-11); JK3, JK5 (Sept-11); JK8 (Nov - treatment facility with finished 2011 11) effluent disposal in a deep Class V well KLWTD Ocean Reef Club AWT and AWT was completed and is fully operational. Anglers Club is also served by 6006C Shallow Well [North Key Largo NI May, 2011 Ocean Reef Club's sanitary sewer system. Additionally, three (3) private buildings Utility Corp.] were taken off of septic systems in 2008 and are served by Ocean Reef Club's system. Ocean Reef Club is now entirely served by sanitary sewer. A-5 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Construction of the Middle Plantation Key central wastewater Islamorada, Village of Islands is pursuing construction of a central wastewater collection system, 0.250 MGD AWT collection and treatment system for the entire Village (outside of the existing North treatment facility expansion at December December Plantation Key Phase I and Phase II service areas) through a Design Build 6009 North Plantation Key AWT 2010 2015 Operate Finance (DBOF) process. Per the issued Request for Proposals, central treatment facility and shallow Class wastewater shall be available throughout the entire Village by December 1, 2015. V effluent disposal well serving Construction phasing will be the responsibility of the selected DBOF firm. approximately 1,600 EDUs [Islamorada] Dagny Johnson Key Largo This system's design, permitting and construction are dependent upon the Hammock Botanical State Park - availability of the service connection to the utility provider, KLWTD [Florida State Assistant Manager Residence December Parks]. At this time the KLWTD indicates they will not provide the needed service 6006E (BL015054), 1013 Atlantic Blvd. NI 2015 extension for this residence connection. Based upon this indication the (Garden Cove), future to utility Department intends to pursue funding to construct an OSTDS — ATU (Performance provider, KLWTD [Florida State Based) as originally planned. Parks Dagny Johnson Key Largo This system's design, permitting and construction are dependent upon the Hammock Botanical State Park - availability of the service connection to the utility provider, KLWTD [Florida State Ranger Residence (131-190002), December Parks]. At this time the KLWTD indicates they will not provide the needed service 6006B 127 Valois Blvd. (Ocean Reef NI 2015 extension for this residence connection. Based upon this indication the Shores), future to utility provider, Department intends to pursue funding to construct an OSTDS — ATU (Performance KLWTD Florida State Parks Based) as originally planned. Performance Based as originally planned. Dagny Johnson Key Largo This system's design, permitting and construction are dependent upon the Hammock Botanical State Park - availability of the service connection to the utility provider, KLWTD [Florida State Ranger Residence (BL190009), December Parks]. At this time the KLWTD indicates they will not provide the needed service 6006B 203 Charlemagne Blvd. (Ocean NI 2015 extension for this residence connection. Based upon this indication the Reef Shores), future to utility Department intends to pursue funding to construct an OSTDS — ATU (Performance provider, KLWTD [Florida State Based) as originally planned. Parks E I KRAD Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Dagny Johnson Key Largo Hammock Botanical State Park - This system's design, permitting and construction are dependent upon the Ranger Residence availabilityof the service connection to the utility ate rnot dprovide �the 60066 Charlemagne Blvd. (Ocean Blvd. (Ocean NI December Parks]. At this time the KLWTD indicates they will needed service Re Reef Shores), future t utility 2015 extension for this residence connection. Based upon this indication the provider, KLWTD [Florida State i Department intends to pursue funding to construct an OSTDS — ATU Performance Based) as originally planned. Dagny Johnson Key Largo Hammock Botanical State Park - This system's design, permittingand construction are dependent upon the Ranger Residence 190011),December availabilityof the service connection to the utilityW provider, KLWTD [Florida State 60066 211 Charlemagne Blvd. . (OcOceanean NI Parks]. At this time the KLWTD indicates they will not provide the needed service Reef Shores), future utility 2015 extension for this residence connection. Based upon this indication the provider, KLWTD[Florida State Department intends to pursue funding to construct an OSTDS — ATU Performance Parks] Based) as originally planned. Dagny Johnson Key Largo This system's design, permitting and construction are dependent upon the Hammock Botanical State Park - availability of the service connection to the utility provider, KLWTD [Florida State 6006B Ranger Residence/Office (BL NI December Parks]. At this time the KLWTD indicates they will not provide the needed service 190012), 3 Lacroix (Ocean Reef 2015 extension for this residence connection. Based upon this indication the Shores), future to utility provider, Department intends to pursue funding to construct an OSTDS — ATU (Performance KLWTD Florida State Parks Based) as originally planned. Dagny Johnson Key Largo Hammock Botanical State Park - This system's design, permitting and construction are dependent upon the Ranger Residence (BL 190009), availability of the service connection to the utility provider, KLWTD [Florida State 6006E 203 Charlemagne Blvd. (Ocean NI December Parks]. At this time the KLWTD indicates they will not provide the needed service Reef Shores), future to utility 2015 extension for this residence connection. Based upon this indication the provider, KLWTD [Florida State Department intends to pursue funding to construct an OSTDS — ATU (Performance Parks Based) as originally planned. Dagny Johnson Key Largo Hammock Botanical State Park - This system's design, permitting and construction are dependent upon the Ranger Residence/Office (BL availability of the service connection to the utility provider, KLWTD [Florida State 6006E 190024), 265 Charlemagne Blvd. NI December Parks]. At this time the KLWTD indicates they will not provide the needed service (Ocean Reef Shores), future to 2015 extension for this residence connection. Based upon this indication the utility provider, KLWTD [Florida Department intends to pursue funding to construct an OSTDS — ATU (Performance State Parks Based) as originally planned. A-7 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date John Pennekamp Coral Reef State The John Pennekamp Coral Reef State Park WWTP was abandoned in 2007 and 6006E Park - Park Manager Residence NI June 2010 this Residence's wastewater flows are now being transmitted, received and (131015043) to utility provider, handled by the KLWTD AWT. KLWTD Florida State Parks John Pennekamp Coral Reef State Park - Mobile Home Ranger The John Pennekamp Coral Reef State Park WWTP was abandoned in 2007 and 6006E Residence (B1015053) to utility NI June 2010 this Residence's wastewater flows are now being transmitted, received and provider, KLWTD [Florida State handled by the KLWTD AWT. Parks] John Pennekamp Coral Reef State Park - Ranger Residence_1023 W The John Pennekamp Coral Reef State Park WWTP was abandoned in 2007 and 6006B Gibraltar Road (B1015028) to utility NI June 2010 this Residence's wastewater flows are now being transmitted, received and provider, KLWTD [Florida State handled by the KLWTD AWT. Parks] John Pennekamp Coral Reef State Park - Ranger Residence_1026 The John Pennekamp Coral Reef State Park WWTP was abandoned in 2007 and 6006B Gibraltar Road (131015005) to utility NI June 2010 this Residence's wastewater flows are now being transmitted, received and provider, KLWTD [Florida State handled by the KLWTD AWT. Parks] John Pennekamp Coral Reef State Park - Ranger Residence The John Pennekamp Coral Reef State Park WWTP was abandoned in 2007 and 6006B _1053 Alhambra Drive (B1015001) to utility NI June 2010 this Residence's wastewater flows are now being transmitted, received and provider, KLWTD [Florida State handled by the KLWTD AWT. Parks John Pennekamp Coral Reef State Park - Park WWTP, I.D. # The John Pennekamp Coral Reef State Park WWTP was decommissioned, 6006B FLA015030 (Plant NI June 2010 abandoned and removed in 2010 and the entire Park's wastewater flows are now Decommissioned, Abandoned & being transmitted, received and handled by the KLWTD AWT. Removed) [Florida State Parks Lignumvitae Key State Park - PM Residence (BL097002) This new DOH ATU septic tank system was constructed in June 2010 to meet the 8078 Standard Septic Tank System To NI June 2010 B.A.T. for this residence. There are no other improvements anticipated at this time. DOH ATU [Florida State Parks WV u Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Lignumvitae Key State Park - 8078 Matheson House Area RR Standard Septic Tank System NI June 2009 This wastewater system for this structure was closed for public use. It is no longer Abandoned [Florida State Parks] generating wastewater bio-solids. This shop building's collection/transmission system design, permitting and Lignumvitae Key State Park - construction are dependent upon the availability of the service connection to the 8078 Land Based Shop Bldg, DOH NI December utility provider, Village of Islands [Florida State Parks]. At this time the shop's DOH Composting Toilet Unit is planned to eventually be replaced with a collection/ Composting Toilet Unit [Florida State Parks] 2015 transmission system connection to the Village of Islands AWT. This service connection is anticipated to become available sometime after December 2015 as indicated by the Village of Islands. This composting toilet unit is still active and open for public use. This residence's collection/transmission system design, permitting and construction Lignumvitae Key State Park - are dependent upon the availability of the service connection to the utility provider, 8078 Land Based Residence DOH ATU December Village of Islands [Florida State Parks]. At this time the residence's DOH ATU Septic Tank System [Florida State NI 2015 system is planned to eventually be replaced with a collection/ transmission system Parks] connection to the Village of Islands AWT. This service connection is anticipated to become available sometime after December 2015 as indicated by the Village of Islands. Windley Key Fossil Reef State Park This visitor center's existing DOH ATU system is planned to eventually be replaced 8084 - Visitor Center (BL206001) NI December with a collection/ transmission system connection to the Village of Islands AWT. Standard Septic Tank System To 2015 This service connection is anticipated to become available sometime after DOH ATU [Florida State Parks] December 2015 as indicated by the Village of Islands. A-9 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date CENTRAL KEYS PROPOSED FUTURE MANAGEMENT PRACTICES Installation of central wastewater collection system serving Service Service Area 2 suspended since the closure and removal of Boot Key Bridge. Only Area 2 and provision of AWT June 2009 N/A one developed property, currently unoccupied. The owner will be responsible for 6011A treatment with disposal in a shallow the installation of a compliant wastewater/stormwater system when and if the site is effluent disposal well serving 33 redeveloped. The owner has been notified of his responsibility in this regard. EDUs[City of Marathon Installation of central wastewater Collection System complete. A force main is currently being completed to the collection system serving Service Service area 3 wastewater treatment plant (WWTP) instead of the construction of Area 1 and provision of AWT November September an Area 1 WWTP and will be available for service by March 2012. The City has 6011A treatment with disposal in a shallow 2009 2011 abandoned the concept of acquiring property and of constructing a WWTP within effluent disposal well serving 312 Area 1. A force main has been approved and a contract awarded to construct the EDUs [City of Marathon] transmission system to the Area 3 wastewater treatment plant (WWTP). Installation of stormwater interception and treatment system 6011A serving approximately 81 acres in conjunction with the central November September a Project complete. 100 /o Road resurfacing complete (not a patch). wastewater collection system 2009 2011 serving Service Area 1 [City of Marathon Installation of central wastewater collection system serving Service 6011A Area 6 and provision of AWT May 2009 May 2009 Project complete/operational and in service. 80% connection to system complete. treatment with disposal in a shallow effluent disposal well serving 1,014 EDUs[City of Marathon Installation of central wastewater collection system serving Service 6011 B Area 6 and provision of AWT May 2009 May 2009 Project complete/operational and in service. 80% connection to system complete. treatment with disposal in a shallow effluent disposal well serving 14 EDUs[City of Marathon A-10 Florida Department of Environmental Protection. REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Installation of stormwater interception and treatment system serving approximately 390 acres in 6011A conjunction with the central May 2009 May 2009 Project complete. wastewater collection system serving Service Area 6 [City of Marathon Installation of central wastewater collection system serving Service Collection system 85% complete. Will be complete by December 25, 2011. Area 3 6011A Area 3 and provision of AWT October September WWTP 97% complete. Will be available by 9/20/2011. Residents and businesses within the completed portion of the project will be requested to connect to the treatment with disposal in a shallow effluent disposal well serving 1,565 2009 2011 wastewater system effective 9/20/2011. As the remainder of the collection system EDUs [City of Marathon] is completed, residences and businesses in that area will be asked to connect. No later than 12/25/2011. Installation of stormwater interception and treatment system 6011A serving approximately 248 acres in conjunction with the central October September 100% complete. 85% road re -surfacing complete not a Remainingre- patch). wastewater collection system 2009 2011 surfacing will be done as collection system completed. serving Service Area 3 [City of Marathon Installation of central wastewater collection system serving Service 6011A Area 4 and provision of AWT treatment with disposal in a shallow October 2009 October 2009 Complete/operational and in-service. 85% connection to system complete effluent disposal well serving 2,283 EDUs[City of Marathon Installation of stormwater interception and treatment system serving approximately 1,010 acres 6011A in conjunction with the central October 2009 October 2009 Complete. 100% road re -surfacing complete (not a patch). wastewater collection system serving Service Area 4 [City of Marathon A-11 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Installation of centralized cluster wastewater collection system serving Service Area 7 and February Treatment is AWT not BAT. 82% Complete. Will be complete by 2/28/2012. No 6011A provision of secondary treatment April 2010 2012 longer cluster system, now a small pipe grinder basin system to WWTP on US 1. with disposal in a shallow effluent disposal wells serving 360 EDUs [City of Marathon Installation of centralized cluster wastewater collection system serving Service Area 7 and February Treatment is AWT not BAT. 82% Complete. Will be complete by 2/28/2012. No 6011 C provision of secondary treatment April 2010 2012 longer cluster system, now a small pipe grinder basin system to WWTP on US 1. with disposal in a shallow effluent disposal wells serving 1,237 EDUs [City of Marathon Installation of stormwater interception and treatment system serving approximately 1,672 acres February Complete. Area 7 is a more sparsely populated area & has only been completed in 6011A in conjunction with the central April 2010 2012 designated problem areas. 100% road re -surfacing to be completed (not a patch) wastewater collection system in FY 2011-2012. serving Service Area 7 [City of Marathon Installation of central wastewater collection system serving Service Area 5 and provision of AWT December December Complete for expansion area (60th to 90th Streets; area behind Marathon Airport). 6011A treatment with disposal in a shallow 2010 2011 Phase I & II Completed in 2002/2003 (90th Street to Vaca Cut (117th Street)). effluent disposal well serving 2,668 EDUs [City of Marathon] A-12 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Installation of stormwater interception and treatment system 6011A serving approximately 1,135 acres in December December Complete for expansion area (60th to 90th Streets; area behind Marathon Airport). conjunction with the central 2010 2011 Phase I & II Stormwater Retrofit (90th Street to Vaca Cut (117th Street)) in wastewater collection system progress; to be complete by December 2011. serving Service Area 5 [City of Marathon] Completion of Phase IV Stormwater Treatment System serving approximately 17 acres including the construction of treatment BMPs and two 120-foot Project completed. The City completed the following stormwater improvements: 6011 B deep 24-inch diameter Class V September 2010 2008 - Five wells were installed and four outfalls closed; 2009 - Seven wells were stormwater injection wells serving 5 2008 installed and two outfalls closed; 2010 - Six wells were installed and one outfall drainage basins and eliminating closed. direct discharges to Halo Zone waters at 3 outfalls and [City of Key Colony Beach] Conversion of existing membrane 6011 B filter WWTP to full AWT operations May 2010 June 2015 The City's WWTP is fully AWT compliant. It is not currently operating at that level [City of Key Colony Beach] since the date for operational compliance was revised to June 2015. Long Key State Park - Ranger The Long Key State Park WWTP was abandoned in 2007 and this Ranger 6010 Station (BL00021) to Municipal NI June 2007 Station's wastewater flows are now being transmitted, received and handled by the Sewer [Florida State Parks] City of Layton AWT. Long Key State Park - Manager The Long Key State Park WWTP was abandoned in 2007 and this Residence's 6010 Residence (BL00020 ) to Municipal NI June 2007 wastewater flows are now being transmitted, received and handled by the City of Sewer Florida State Parks Layton AWT. Long Key State Park - Assistant 6010 Manager Residence to The Long Key State Park WWTP was abandoned in 2007 and this Residence's Sewer [Florridaids State t NI June J2007 wastewater flows are now beingtransmitted, received and handled by the City of Parks]Municipal Layton AWT. A-13 AM FKRAD Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date The new wastewater collection/transmission system serving the shop building is Long Key State Park - Shop December currently being designed and permitted for bidding and construction. This sewer 6010 Building (BL), Future To Municipal NI 2015 system will be connected to the City of Layton AWT dependent upon funding Sewer[Florida State Parks] approval. At this time it is anticipated the sewer connection will be completed by December 2015. Long Key State Park - Boardwalk The Long Key State Park WWTP was abandoned in 2007 and this Restroom RR Building (BL00010) to NI June 2007 Building's wastewater flows are now being transmitted, received and handled by 6010 Municipal Sewer [Florida State the City of Layton AWT. The collection/transmission system became operational Parks] during June 2007. The Long Key State Park WWTP was abandoned in 2007 and this Area's Long Key State Park - Ranger wastewater flows are now being transmitted, received and handled by the City of 6010 Compound Area to Municipal NI June 2007 Layton AWT. The collection/transmission system became operational during June Sewer [Florida State Parks] 2007. Long Key State Park - The Long Key State Park WWTP was abandoned in 2007 and this Bathhouse's Campground Bathhouse # 1 wastewater flows are now being transmitted, received and handled by the City of 6010 (BL00003) to Municipal Sewer NI June 2007 Layton AWT.' The collection/transmission system became operational during June Florida State Parks] 2007. Long Key State Park - The Long Key State Park WWTP was abandoned in 2007 and this Bathhouse's Campground Bathhouse # 2 NI June 2007 wastewater flows are now being transmitted, received and handled by the City of 6010 (BL00022) to Municipal Sewer Layton AWT. The collection/transmission system became operational during June Florida State Parks 2007. Long Key State Park - The Long Key State Park WWTP was abandoned in 2007 and this Bathhouse's Campground Bathhouse # 3 wastewater flows are now being transmitted, received and handled by the City of 6010 (BL00023) to Municipal Sewer NI June 2007 Layton AWT. The collection/transmission system became operational during June [Florida State Parks] 2007. Long Key State Park - Day Use RR The Long Key State Park WWTP was abandoned in 2007 and this Restroom Building (BL00008/09) to Municipal Building's wastewater flows are now being transmitted, received and handled by 6010 Sewer [Florida State Parks] NI June 2007 the City of Layton AWT. The collection/transmission system became operational during June 2007. Long Key State Park - Park The Long Key State Park WWTP was abandoned in 2007 and the entire Park's WVVTP, I.D. # Fla015025 (Plant wastewater flows are now being transmitted, received and handled by the City of 6010 Decommissioned, Abandoned & NI June 2007 Layton AWT. The collection/transmission system became operational during June Removed) [Florida State Parks 2007. A-14 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date A new wastewater collection/transmission system serving the Park is currently being designed for permitting by our contracted consultant, George McDonald of Curry Hammock State Park - McDonald Group International, Inc. This sewer system's construction and 6011A Ranger Station BL228009 to g ( ) NI September connection to the Cityof Marathon's AWT is dependent upon the AWT's p Municipal Sewer [Florida State 30, 2012 construction completionp and funding approval. At this time it is anticipated the p Parks] sewer construction and connection will be completed by September 2012. The Ranger Station DOH ATU Septic Tank system will eventually be replaced with a collection/transmission system and its wastewater flows will be transmitted to the City of Marathon, Florida AWT. A new wastewater collection/transmission system serving the Park is currently being designed for permitting by our contracted consultant, George McDonald of Curry Hammock State Park - McDonald Group International, Inc. This sewer system's construction and 6011A Manager Residence BL228011 to g ( ) September connection to the Cityof Marathon's AWT is dependent upon the AWT's p p Municipal Sewer [Florida State NI 30, 2012 construction completion pletion and funding approval. At this time it is anticipated the p Parks] sewer construction and connection will be completed by September 2012. The Residence's standard septic tank system will eventually be replaced with a collection/transmission system and its wastewater flows will be transmitted to the Curry Hammock State Park - Cityof Marathon, Florida AWT. 6011A Ranger Residence (BL228001) to NI September Municipal Sewer [Florida State 30, 2012 Same as above. Parks A new wastewater collection/transmission system serving the Park is currently being designed for permitting by our contracted consultant, George McDonald of Curry Hammock State Park - Shop McDonald Group International, Inc. This sewer system's construction and 6011A Building (131-228012, Future) to NI September connection to the City of Marathon's AWT is dependent upon the AWT's construction completion and funding approval. At this time it is Municipal Sewer [Florida State Parks] 30, 2012 anticipated the sewer construction and connection will be completed by September 2012. The Residence's standard septic tank system will eventually be replaced with a collection/transmission system and its wastewater flows will be transmitted to the City of Marathon, Florida AWT. The new Shop Building's wastewater flows will be collected and transmitted to the Citv of Marathon Flnridn AlArr A-15 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date A new wastewater collection/transmission system serving the Park is currently being designed for permitting by our contracted consultant, George McDonald of McDonald Group International, Inc. This sewer system's construction and Curry Hammock State Park - Picnic connection to the City of Marathon's AWT is dependent upon the AWT's 6011A Area RR Building (BL228010) to NI September construction completion and funding approval. At this time it is anticipated the Municipal Sewer [Florida State 30,201 sewer construction and connection will be completed by September 2012. The Parks] Picnic Area Day Use Restroom Building's DOH ATU Septic Tank system will be replaced with a collection/transmission system and its wastewater flows will be transmitted to the City of Marathon, Florida AWT. A new wastewater collection/transmission system serving the Park is currently being designed for permitting by our contracted consultant, George McDonald of McDonald Group International, Inc. This sewer system's construction and Curry Hammock State Park - connection to the City of Marathon's AWT is dependent upon the AWT's 6011A ng Area Bathhouse Camping Campi NI September September construction completion and funding approval. At this time it is anticipated the 003) to Municipal Sewer 2012 sewer construction and connection will be completed by September 2012. The [Florida State Parks] Camp Area Bathhouse's DOH ATU Septic Tank & Composting Toilet systems will be replaced with a collection/transmission system and its wastewater flows will be transmitted to the City of Marathon, Florida AWT. Gravity Collection; 0.2 MGD The Notice to Proceed for the expansion and upgrade of the Duck Key WWTP was 6016 WWTP upgrade to AWT [Monroe No later than October issued on March 16, 2010 with a Final Completion Date of August 27, 2011. Field County] June 2010 2011 conditions required the contract extension of approximately 60 days. Bahia Honda State Park - Ranger This septic tank system was abandoned and the residence's effluent discharge residence (BL005059) septic tank February combined and transmitted to the newly constructed DOH ATU Septic Tank system. 6018 system to DOH ATU [Florida State NI 2010 This ATU serves both the Manager's and Ranger residences. The system became Parks] operational early in 2010. Bahia Honda State Park - Manager This residence's effluent discharge was combined and transmitted to the newly 6018 residence (BL005070) septic tank NI February constructed DOH ATU Septic Tank system. This ATU serves both the Ranger and system to DOH ATU [Florida State 2010 Manager residences. The system became operational early in 2010. Parks Bahia Honda State Park - Ranger residence (BL005047) to SAND November This residence's effluent discharge was continued to the SAND SPUR #3 AWT. 6018 SPUR #3 AWT [Florida State NI 2009 The modified plant became operational during November 2009. Parks A-16 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or New Anticipated Anticipated Comments Operational Operational Date Date Bahia Honda State Park - Ranger 6018 residence (bl005048) to SAND SPUR #3 AWT [Florida State NI November This residence's effluent discharge was continued to the SAND SPUR #3 AWT. Parks 2009 The modified plant became operational during November 2009. Bahia Honda State Park -Ranger 6018 station (BL 005044) septic tank NovemberW This septic tank system was abandoned and the Station's effluent discharge is system to SAND SPUR #3 AT NI 2009 being transmitted to the Park's AWT. The modified plant became operational Florida State Parks during November 2009. Bahia Honda State Park - Sand 6018 Spur day use RR (BL 005068) ATU November This septic tank system was abandoned and the Restroom Building's effluent septic tank system to SAND SPUR NI 2009 discharge is being transmitted to the Park's AWT. The modified plant became #3 AWT Florida State Parks operational during November 2009. Bahia Honda State Park - Sand Spur Campground Bath House 6018 (13I005062) Septic Tank System To NI November This septic tank system was abandoned and the Bathhouse Building's effluent SAND SPUR #3 AWT [Florida 2009 discharge is being transmitted to the Park's AWT. State Parks Bahia Honda State Park - 6018 Loggerhead Beach Area — South Composting Toilet Restroom Bldg. NI November This composting toilet unit was abandoned and closed for public use. It is no 131-005066 . Florida State Parks 2009 longer generating wastewater bio-solids. Bahia Honda State Park - 6018 Loggerhead Beach Area — North Composting Toilet Restroom Bldg. NI November This composting toilet unit was abandoned and closed for public use. It is no 131-005067 . Florida State Parks 2009 longer generating wastewater bio-solids. Bahia Honda State Park - SAND 6018 SPUR WWTP, I.D. # FLA015032 (Modified to AWT) [Florida State NI November This WWTP was modified and converted to an AWT to meet BAT. The modified Parks 2009 plant became operational during November 2009. Bahia Honda State Park - SAND SPUR #4 WWTP, I.D. # 6018 FLA015033 (Plant NI November 2009 This WWTP was abandoned and decommissioned. Decommissioned, Abandoned & Removed) [Florida State Parks A-17 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date SOUTH CENTRAL KEYS PROPOSED FUTURE MANAGEMENT PRACTICES One treatment facility is designed to reduce water quality impacts from the following WBIDs: 6014C-N, 6014C-S, 601313-N, 6013C-N, 6013C-S, 6013D-N, 6012A-N, 6012A-S, 6012C-N, 6012D-S, and 6012E-N. Project is ready to bid and will be 30% funded by system development fees levied as assessments; Monroe County plans to complete project using its portion of the $200 million in bonds authorized under Section 215.619 F.S. Monroe County Resolution 086-2011 requested issuance of the first year annual portion of $50 million. In attempt to Construction of the South Lower create another revenue stream, Monroe County requested approval in 2010 from Keys central sanitary sewer system the Florida Legislature to seek additional sales tax revenue for this project. 6014C-N to serve 936 EDUs on with an AWT 2009 TBD Subsequent to request denial, Monroe County is planning a referendum for (5-5-3-1) treatment facility and continuation of the existing infrastructure sales tax on the 2012 general election nominal 90-foot effluent disposal ballot. The Monroe County Sanitary Wastewater Master Plan recommended well [Monroe County/FKAA] construction of three wastewater treatment plants to address the nutrient loading for WBIDs 6014C-N, 6014C-S, 60136-N, 6013C-N, 6013C-S, 6013D-N, 6012A-N, 6012A-S, 6012C-N, 6012D-S, and 6012E-N. Value Engineering study recommended siting one facility as a more cost effective solution. The service area has been expanded to include some properties formerly considered "cold spots" (areas not included in the central service area). An EPA Grant has been secured by the Florida Keys Aqueduct Authority to provide on -site wastewater nutrient reduction systems to many former cold spots. Construction of the South Lower Keys central sanitary sewer system 6014C-S to serve 686 EDUs on with an AWT 2009 TBD Same as above (5-5-3-1) treatment facility and nominal 90-foot effluent disposal well Monroe Count /FKAA A-18 FKRAD Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Construction of the Middle Lower Keys central sanitary sewer system 6013B-N to serve 66 EDUs on with an AWT June 2009 (5-5-3-1) treatment facility and TBD Same as above nominal 90-foot effluent disposal well Monroe Count /FKAA Construction of the Middle Lower Keys central sanitary sewer system 6013C-N to serve 565 EDUs on with an AWT June 2009 (5-5-3-1) treatment facility and TBD Same as above nominal 90-foot effluent disposal well Monroe Count /FKAA Construction of the Middle Lower Keys central sanitary sewer system to serve 2,860 EDUs on with an 6013C-S AWT (5-5-3-1) treatment facility June 2009 TBD and nominal 90-foot effluent Same as above disposal well [Monroe Count /FKAA Construction of the Middle Lower Keys central sanitary sewer system 6013D-N to serve 9 EDUs on with an AWT June 2009 (5-5-3-1) treatment facility and TBD Same as above nominal 90-foot effluent disposal well Monroe Count /FKAA Construction of the North Lower Keys central sanitary sewer system to serve 2,815 EDUs on with an 6012A-N AWT (5-5-3-1) treatment facility December TBD and nominal 90-foot effluent 2010 Same as above disposal well [Monroe Count /FKAA] A-19 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Construction of the North Lower Keys central sanitary sewer system 6012A-S to serve 813 EDUs on with an AWT December TBD Same as above (5-5-3-1) treatment facility and 2010 nominal 90-foot effluent disposal well Monroe Count /FKAA Construction of the North Lower Keys central sanitary sewer system 6012C-N to serve 24 EDUs on with an AWT December TBD Same as above (5-5-3-1) treatment facility and 2010 nominal 90-foot effluent disposal well Monroe Count /FKAA Construction of the North Lower Keys central sanitary sewer system 6012D-S to serve 43 EDUs on with an AWT December TBD Same as above (5-5-3-1) treatment facility and 2010 nominal 90-foot effluent disposal well Monroe Count /FKAA Construction of the North Lower Keys central sanitary sewer system 6012E-N to serve 94 EDUs on with an AWT December TBD Same as above (5-5-3-1) treatment facility and 2010 nominal 90-foot effluent disposal well [Monroe Count /FKAA] Upgrading existing secondary WWTP to AWT processes with discharge of effluent to shallow On June 22, 2010, the Navy submitted a request to have the permit modified to effluent disposal well or contracting No Later extend the construction completion date for converting the WWTP to sequencing 6014C-N with FKAA/Monroe County for Than July 1, December batch Reactor (SBR) until December 31, 2015. It is the Navy's intent to meet the wastewater treatment services for 2010 31,2015 2015 deadline. The Navy is still pursuing both options, but has not yet developed a Boca Chica Field. schedule. An update was provided to the DEP and DCA earlier this year A-20 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date SOUTHERN KEYS PROPOSED FUTURE MANAGEMENT PRACTICES Construction of 3 baffle boxes and 6014A-N 3 stormwater disposal wells (1 per 2008- 2010 2008- 2010 Seventeen (17) baffle boxes and wells installed completed. ear[City of Key West Construction of 3 baffle boxes and 6014A-S 3 stormwater disposal wells (1 per 2008- 2010 2008- 2010 Fifteen (15) baffle boxes and wells installed completed. ear[City of Key West Incremental collections of marine pump -out program (above the 2007 6014A-N levels) of sanitary boat wastes 2007- 2010 2007- 2010 Pumpout collections (294,220 gal/yr avg) & boats serviced (4,485 avg). Second serving enforced by police boat pumpout boat added to service anchorages, mooring field and marinas. sweeps[City of Key West Installation of stormwater treatment 6014A-S systems for Existing Roadway Jul 2005 2008- 2010 Six (6) baffle boxes and pollution control devices completed. [FDOT/City of Key West Installation of stormwater treatment 6014A-N systems for Existing Roadway Jul 2005 2008- 2010 Four (4) baffle boxes and pollution control devices completed. [FDOT/City of Key West Incremental collections of marine 6014A-N pump -out program (above the 2010 levels) of sanitary boat wastes 2011- Pumpout boats will remain in service for anchorages, Key West mooring field and serving enforced by police boat 2020 2011- 2020 marinas (city & private). Sanitary connection stations will be installed on all sweeps[City of Key West transient docks (87 boat slips) Construction of 10 baffle boxes and 6014A-N 10 stormwater disposal wells (1 per 2011- 2020 2011- 2020 Two (2) baffle boxes and wells installed completed (2011). ear[City of Key West Construction of 10 baffle boxes and 6014A-S 10 stormwater disposal wells (1 per 2011- 2020 2011 One (1) baffle box and well installed completed (2011). earCit of K- West A-21 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 FKRAD Updated Reported Actual or WBID Management Action Actual or Anticipated New Anticipated Comments Operational Operational Date Date Ft. Zachary Taylor State Park - Initially an ATU septic tank system was planned to replace the conventional septic Concession (BL125008) and beach November tank system. Instead the septic tank system is presently being decommissioned 6014A bathroom (BL125002) DOH ATU NI 2011 and its effluent discharge will be transmitted to the City of Key West WWTP. septic tank system to municipal Anticipated completion of the municipal sewer connection is November 19, 2011. sewer Florida State Parks Ft. Zachary Taylor State Park - Park manager's residence Initially an ATU septic tank system was planned to replace the conventional septic (131-125015) & assistant park November tanks stem. Instead the septic tanks stem is resent) being decommissioned Y p Y presently g 6014A manager's residence (BL125014) NI 2011 and its effluent discharge will be transmitted to the City of Key West WWTP. standard septic tank system to Anticipated completion of the municipal sewer connection is November 19, 2011. municipal sewer [Florida State Parks Ft. Zachary Taylor State Park - Fort Initially an ATU septic tank system was planned to replace the conventional septic bathroom (BL125007) standard NI November tank system. Instead the septic tank system is presently being decommissioned 6014A septic tank system to municipal 2011 and its effluent discharge will be transmitted to the City of Key West WWTP. sewer Florida State Parks Anticipated completion of the municipal sewer connection is November 19, 2011. Ft. Zachary Taylor State Park - Initially an ATU septic tank system was planned to replace the conventional septic Shop and volunteer village November Instead the tic tanks stem is resent) being decommissioned tanks system. septic y presently g 6014A (BL125009) standard septic tank NI 2011 W and its effluent discharge will be transmitted to the City of Key West WTP. system to municipal sewer [Florida Anticipated completion of the municipal sewer connection is November 19, 2011. State Parks] Ft. Zachary Taylor State Park - The new entrance station will be constructed within the near future. The final standard septic Entrance stationmunicipal portion of the sewer system's construction and connection is dependent upon the 6014A tank system t sewer NI December City & DRP executed easement agreement for the park's new proposed entrance [Florida State Parks] 20be and construction funding approval. At this time it is anticipated the new park entrance and the sewer connection will be completed by December 2015. FLORIDA DEPARTMENT OF TRANSPORTATION PROPOSED FUTURE MANAGEMENT PRACTICES Jewfish Creek Bridge - SR 5/US 1/Jewfish Creek Bridge N/A from Abaco Rd at Key Largo to 2004-2009 2010 Project complete. north of Jewfish Creek - Construct Bridge — High Level. A-22 FKRAD FKRAD Updated Reported Actual or WBID Management Action Actual or New Anticipated Anticipated Operational Operational Date Date Big Coppitt Key -From Shark N/A Channel Bridge to Old Boca Chica Channel, (add turn lanes) 2006-2009 2010 Card Sound Road/CR-905 N/A Intersection Conversion - 2006-2012 2009 PD&E/EMO Stud Key West, United Street - N/A Stormwater Mitigation (LAP 2008-2009 2009 A reement Master Drainage Plan SR 5/ Overseas Highway - N/A Resurfacing from MM 33.8/Spanish Harbor Channel to MM 35.3/Big 2009-2010 2009 S anish Channel SR5/US 1/Overseas Hwy - N/A Resurfacing from MM 86.8/S of East Ridge Road to MM 90/ Royal 2007-2009 2009 Poinciana Boulevard SR 5/ Overseas Highway - N/A Resurfacing from MM 103.2 Hialeah Lane to MM 106.6 Reef 2006-2010 2012 Drive SR 5/Overseas Highway - Resurfacing from MM 93 to MM 97 2006-2011 2013 SR 5/ Overseas Highway - N/A Resurfacing from SR A1A to 320 ft. 2007-2009 2009 north of Cross Street SR 5/ Overseas Highway - N/A Resurfacing from 2000 ft. south of 2006-2010 2012 MM100 to 2580 ft. south of MM 97 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011 Comments Project complete. Project complete. Project complete. Project complete. Project complete. Work on this project is ongoing, completion date extended until 2012. The scope of this project has been expanded to include swale drainage improvements, thus the anticipated completion date has been extended to 2013. Project complete. Work on this project is ongoing, completion date extended until 2012 A-23 FKRAD Updated Reported Actual or Actual or New WBID Management Action Anticipated Anticipated Operational Operational Date Date SR 5/ Overseas Highway - Resurfacing from MM 49.1/north of 2006-2012 2012 N/A 37th St. to MM 53.1/Bridge over Vaca Cut SR 5/ Overseas Highway - Resurfacing from MM 99.7/south of 2006-2011 2012 N/A Laguna Avenue to MM 103.1/Hialeah Lane SR 5/ Overseas Highway - Resurfacing from 500 ft north of 2008-2011 2009 N/A Cut Throat Drive to 500 ft. north of S anish Drive City of Marathon, Little Venice Road Improvements at Various NI 2010 N/A Locations; the south ends of 95�', 961" and 105 West Streets Monroe Countywide Drainage NI 2011-2016 N/A Pushbutton Projects SR5/0verseas Highway from N/A MM59 to Grassy Key Drainage NI 2012 improvements SR5/Overseas Highway from Caribbean Drive/MM24.5 to W. NI 2014 N/A Shore Drive MM25.0 Drainage improvements TBD = To Be Determined N/A = Not Available NI = Not included in original FKRAD A-24 Florida Department of Environmental Protection REASONABLE ASSURANCE DOCUMENTATION FLORIDA KEYS December 2011