Environmental Groups Lobby Receiver on Piney Point Deep Well

MANATEE COUNTY – Suncoast Waterkeeper, Manasota 88, and Tampa Bay Waterkeeper were among several environmental groups to sign a letter sent to Herbert Donica, the attorney appointed as receiver for HRK Holdings, the site owner at Piney Point, a former phosphate processing plant that has been the source of multiple environmental catastrophes in Manatee County. The groups requested a "robust, representative, and transparent sampling effort at Piney Point.

"We write today about the present situation at the former Piney Point phosphate plant and the pending application to inject billions of gallons of process wastewater from that site just below the aquifer that millions of Floridians rely upon for drinking water and crop irrigation,“ the letter stated. "On behalf of our collective members that reside in Florida, we respectfully request that you, in your role as receiver on behalf of HRK Holdings, LLC, undertake a robust, representative, and transparent sampling effort to confirm that the process wastewater proposed to be disposed of via deep well injection does not contain any hazardous constituents above the regulatory limits É“

The Center for Biological Diversity and Our Children’s Earth Foundation also signed the letter.

"As you know,“ the letter continued, "in April of this year Manatee County submitted an application to construct an underground injection well to dispose of the process wastewater stored at Piney Point. The permit is presently under review with the Florida Department of Environmental Protection. The source of the wastewater proposed to be injected includes "the water stored in the Piney Point Facility gypsum stacks (gyp-stacks) and the phreatic water collected by the underdrain system.“ The permit application admits that Manatee County does not know the precise geologic strata in the location of the proposed well and instead is guessing that the "anticipated geologic strata“ is similar to a well located five miles away. The permit application further admits that Manatee County does not know the precise location where the underground drinking water source begins or ends.

"More troubling, the permit application makes explicit that process wastewater from Piney Point will not be treated to reduce pollution in the wastewater to levels consistent with Florida’s water quality standards prior to injection. To the contrary, the application plainly states that the "pre-treatment strategy is not to reduce constituents to any regulatory standard,“ but rather "to assure chemical compatibility with the injection zone to avoid or limit the potential for lugging of the formation to the degree possible.“ Indeed, "the type and level of treatment is yet to be determined,“ and no treatment plant has been proposed or designed as of the date of this letter.

The groups added that the permit application itself is based on a series of assumptions that have not yet been evaluated or proven, including several "assumptions and qualifiers.“

• The injection zone is homogenous and isotropic.
• No leakance occurs between the overlying and underlying geologic units. - No density differences exist between the injected water and the native groundwater.
• The direction, magnatude [sic], and temporal variations of the groundwater gradient are not accounted for.
• The cylindrical volume calculation is used only to provide a gross estimation of the average distance the injected water may extend laterally from the injection well.
• Assumes collection from underdrains is 0.15 MGD and completed in 40 years.

"In light of this information, our organizations and the collective tens of thousands of Floridians we represent respectfully request that you meaningfully evaluate whether the wastewater stored at Piney Point has been fully investigated, characterized, and sampled in a representative manner, especially with regard to the phreatic water and the underdrain system,“ the letter concluded. "While some portion of the precipitation-diluted wastewater at Piney Point may not rise to the level of hazardous waste, the sampling showing hazardous levels of selenium from the OGS-N is of serious concern and indicates that plans to inject the process wastewater are both unlawful and unwise. We understand the endangerment threatened by Piney Point, but a thorough analysis of the wastewater must be completed before billions of gallons of dangerous pollution is injected beneath the Lower Floridian aquifer. The process of sampling should be open and transparent, with input from our organizations’ experts before sampling begins.“

Click here to view the letter and its citations in their entirety.