Flow limits were increased in 2011 from 30 to 40 MGD with no apparent documentation about the impacts this increase would have on flooding of homes and properties. Tropical Storm Debbie [sic] caused flooding in the Starke Country Club area the closest residential area downstream of the Chemours D001 discharge point. At the end of June 2012 Chemours’ discharges were over the 40 MGD limit for 4 days with the highest daily discharge being 55.3 MG. Chemours flows likely added to the level and duration of flooding in the Alligator Creek and Sampson River Basins.

Discharges over the spillway at the south end of the West Levy that bypass the water treatment facility need to be addressed. These discharges have occurred on several occasion [sic] and need to be addressed in the current permit renewal. These discharges are releasing untreated mine contact water with high humate content.

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The failure to control or address erosion from the mined areas that have not been reclaimed and the role the erosion plays as the source of humate in stormwater need to be addressed. Humate rich strata deposited during the dredge mining are eroding and causing very high humate levels in stormwater. The erosion problem needs to be addressed as a BMP to reduce or even eliminate the high levels of humate. The current conditions east of CR 225 in Bradford County on land owned by the SRWMD indicate that erosion BMPs have not been implemented on mined property. The impacts of the erosion east of CR 225 in Bradford County on land owned by the SRWMD needs to be addressed immediately and in the new NPDES permit.

The humate rich stormwater requires treatment with ferric solutions to remove the humate. Eliminating the waste product humate at its source is a waste reduction method. Reducing the amount of ferric solutions used should have a priority over doubling the permitted iron discharge levels that is [sic] proposed in the current permit application.

The apparent spill(s) of ferric solutions may require a review of the facility’s BMPs and response procedures to spills of hazardous materials.

The water balance diagram included in the permit does not include watershed discharges. The water balance diagram shows an almost zero discharge operation. A revised water balance is needed.

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DEP staff appear to have failed to review the abnormal events files for the Chemours facility. These abnormal events reports [sic] detail periods when water has passed over the spillway. Google Earth images also show apparent repairs to the spillway area. DEP staff appear to have failed to look at the path water takes after it passes over the spillway as erosion and sediments should have been clearly visible. The failure to design for adequate stormwater storage at the West Levee could be corrected by fixing the erosion problem so rate of runoff is slowed or eliminated. This needs to be addressed in the permit. The inspection schedule for the West Levee is not acceptable. The current stormwater systems transfer water from the SJRWMD and from 3 or more WBIDS to Alligator Creek. It is this transfer that may be contributing to flooding downstream of D001. The end of pipe discharge from the two pumps at the West Levee would appear to be a point discharge that should be documented as to volume and water quality. It cannot be determined from the Google Earth images if the pipe discharges are contained conveyance system that would carry the mine contact water to the treatment facility or if the discharges can flow to other areas. There is no indication that the settling ponds have had sludge removed. The holding capacity of the system may have been reduced to the point that it can no longer handle large rain events. An analysis of the current holding capacity of the setting ponds is needed.