cudjoe flow chart

by Mark Songer on behalf of the Board of Directors of LAST STAND ……………………………………………………………………………………

Last Stand commends FKAA Executive Director Kirk Zuelch for agreeing to urge funding for the study to confirm or to rule-out the hydraulic connection between the shallow injection wells discharge at the Cudjoe Regional Wastewater Plant and surface waters. We also commend the FKAA Board of Directors and the Monroe County Commissioners for recognizing the need and funding deep well disposal.

Dr. Henry Briceno’s April 2015 report clearly states there is convincing evidence that freshwater injected to shallow wells at 420 gallons per minute readily migrates upward then laterally to the unconfined shallow aquifer and eventually to surface waters. The test data indicate high velocity underground flow beneath the abandoned landfill adjacent to the plant.

There is a reasonable risk that even the low flows from the start up of the Cudjoe plant will result in treated water disturbing and distributing toxic material from the abandoned landfill into surface water, the surrounding wetlands and near shore waters.

Last Stand is urging further testing before the Cudjoe plant is started to answer the question: will injected treated water at low flows cause the release of hazardous materials from the abandoned landfill?

An early draft of Dr. Briceno’s proposal for a Water Quality study included two objectives:

1. Is the injected wastewater seeping to the surface?

2. If injected wastewater reaches the surface, will it adversely impact surface water quality?

Dr. Briceno has answered the first question. Injected sewage effluent percolates up in the immediate area. We know that various harmful pollutants remain in wastewater, even after Advanced Wastewater Treatment, but in the case of the Cudjoe Regional plant, we also know the surrounding land is saturated with contaminants from over 40 years of use as a dump and then an unlined landfill. The question remains, “Is it safe to use shallow wells during the first two years of plant operation?”

Unfortunately, the second objective was either not included in the final version of Dr. Briceno’s study or it was not completed before the study was terminated. Last Stand believes an answer to the question of how sequestered land fill contaminants respond to shallow well flushing is absolutely necessary before these shallow wells are put into operation.

Monroe County and FKAA officials chose to locate the new regional wastewater plant within a landfill site. They decided to build the system with shallow injection wells. It is now time for our local officials to acknowledge the proximity of these shallow wells to the decades-old accumulation of contaminants and to provide county residents the assurance that these contaminants will not be flushed into Lower Keys backcountry waters and the sanctuary.

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  1. Actually, the limited testing already answered the questions posed above.
    The tracer dyes were found in monitoring wells even before test injection began. Dr.Briceno’s guess was that these chemicals might be from anti-freeze or other chemicals in the landfill that use the same colorants.
    The ground near the landfill is saturated with leachate. At excavations for the new treatment plant, yellow or orange water would run in through holes in the limerock. The tinted water held the tint and did not appear to transfer the tint to the saline tidal groundwater. This was evidenced by a yellow “bathtub ring” around open excavations that were pumped down after a couple of days of inactivity. My guess is that the ring was from tinted freshwater leachate that floated atop denser saline water.
    Injection testing resulted in rapid displacement to the surface, so we know that injected freshwater effluent rises up through the leachate layer.
    Florida DEP warned FKAA back in 2008 that shallow wells might not work at all, and in any event they would need a deep well to handle anticipated flows. FKAA’s consulting engineers told FKAA in a written report in 2008 that two deep wells would be needed if FKAA and the County were to consolidate the 3 treatment plants proposed by the 2000 Monroe County Wastewater Plan into just one plant. The engineers warned that a decision to consolidate into one plant should not be made based solely on a desire to save money, because there were design issues that could easily consume the relatively small potential savings. The report was sent to the County Engineer Dave Koppel by FKAA’s Tom Walker.with a recommendation that the entire Cudjoe Regional Wastewater System be treated at one plant because money would be saved. We see now that this was really poor advice, after spending an additional $3.5 million to drill under Niles channel with a risky uncased sewage forcemain, authorizing $6-7 million for a deep well, and soon to realize that another $5-6 million or so will be needed for the required back-up injection well- just like FKAA was warned in 2008. Shallow wells have been scientifically proven to not work at that location; leachate has been definitively shown to have saturated the area soil; and shallow well injection has been proven to rise into and migrate that leachate. Leachate migration is also as DEP warned in 2008. For the supporting documents and photos of leachate being dumped by the County into a ditch to soak into the ground, see the links in the Blue Paper article here:
    Note that consolidation to a single plant constituted an abandonment of the 2000 Monroe County Wastewater Master Plan, as was the Niles crossing and the switch to a pressure sewer collection system from gravity or vacuum. The cursory Programmatic Environmental Impact Statement issued by the Army Corps of Engineers in 2004 for Keys sewering was based on the 2000 Monroe County Wastewater Master Plan. Therefore, all of the CRWS has been designed and built with absolutely no environmental risk assessment from the federal agencies charged with protecting the National Marine Sanctuary and the wildlife refuges and marine preserves of the Keys. Why does it take lawsuits funded by concerned citizens to have federal and state environmental agencies simply do their job? There are two pending now.

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