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Middle St. Johns - Florida Department of Environmental Protection

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484 Water Quality Assessment Report: <strong>Middle</strong> <strong>St</strong>. <strong>Johns</strong><br />

background conditions. The basis for this opinion is that the watershed is reasonably<br />

undisturbed and has a very high percentage <strong>of</strong> low-relief with intact wetland cover.<br />

This supposition is subject to further verification and Volusia County is currently<br />

planning additional surface water and groundwater monitoring stations in this basin<br />

aimed at determining background verses anthropogenic influence. The <strong>St</strong>. John’s<br />

River Water Management District is planning to develop PLRGs for the Deep Creek<br />

basin. We suggest a joint meeting among FDEP, SJRWMD, and Volusia County to<br />

coordinate future monitoring activities, with an objective toward determining if<br />

metals sources and oxygen regimes are anthropogenic or natural prior to verifying a<br />

TMDL for this basin. Given the uncertainties <strong>of</strong> the sources, with reason for<br />

believing natural background levels may be controlling concentrations, we<br />

recommend shifting metals and dissolved oxygen proposed as “Verified Impaired”<br />

under WBID 2925 to the “Planning List” (Table 7). If legal constraints or court<br />

decisions prevent this, we ask that sufficient time be given to implement a more<br />

definitive monitoring program for determining if sources are anthropogenic or<br />

background before setting and implementing a TMDL [Volusia County Deep Creek<br />

Assessment, BCI Engineers and Scientists, Inc. July 2003].<br />

RESPONSE: Silviculture (tree plantations) and crop and pasture lands are the most<br />

significant land uses in the Deep Creek – Lake Ashby Canal (WBID 2725) watershed,<br />

per the 1995 <strong>St</strong>. <strong>Johns</strong> River<br />

Water Management District’s land use coverage (Figure 1). Next most significant<br />

perhaps are surface waters and wetlands. All <strong>of</strong> the data used in the assessment <strong>of</strong><br />

this segment for metals content came from samples taken at station 21FLSJWMDMR<br />

on Deep Creek (red dot on Figure 1). A wastewater residual (biosolids) application<br />

area is located 4.5 miles upstream <strong>of</strong> this station. The residual application area<br />

appears to have the potential for hydrologic connection to Deep Creek through a<br />

series <strong>of</strong> roadway ditches, canals and wetlands, particularly during high-water<br />

conditions (Figure 1). What’s more, wastewater residuals are commonly used in<br />

silviculture because they have been found to promote timber growth. Though it’s<br />

unknown at this time if residuals are being used in the silvicultural industry in this<br />

segment, if so, run<strong>of</strong>f from such applications would presumably be another source <strong>of</strong><br />

heavy metals to Deep Creek. It should be noted that station 21FLSJWMDMR is<br />

within feet <strong>of</strong> a tree plantation.<br />

With the exception <strong>of</strong> iron, most <strong>of</strong> the metals for which this segment is verified<br />

impaired are among the ten most common metals <strong>of</strong> concern in residual applications,<br />

per 40 CFR Part 503 <strong>of</strong> the Federal Register. While the <strong>Department</strong> does agree that<br />

the metals <strong>of</strong> concern in this segment do exist naturally in the environment, the levels<br />

observed are not consistent with natural levels. High concentrations <strong>of</strong> metals in<br />

groundwater does not necessarily indicate a natural condition, if the potential exists<br />

for surface water contaminants to be introduced to groundwater. This is particularly<br />

important in this segment in light <strong>of</strong> the likelihood <strong>of</strong> significant surface<br />

water/groundwater interaction. Before concluding that residual application is not a<br />

significant source <strong>of</strong> contaminants in this segment, the <strong>Department</strong> would like to

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