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Task 6 – Design, Permit, and Construct Pilot Impoundment and Horizontal Wells
This task includes the design, permitting, and construction of the pilot impoundment and groundwater collection system (horizontal wells). The pilot project currently assumes that either or both surface water and groundwater will be recharged and stored in the FAS. In the CERP, it was assumed that the source water for the ASR pilot project would groundwater from traditional vertical wells. However, because of limitations in the groundwater quality and quantity at the site, horizontal wells in association with an above-ground impoundment were determined to be the optimal source of groundwater.
Task7 – Test and Operate Pilot Impoundment and Horizontal Wells
This task includes the operation and testing of the pilot impoundment in conjunction with the periodic testing of the horizontal wells. The purpose of this task is to test the effectiveness of the groundwater collection system with regards to water quantity and water quality. Based on the testing results, a determination will be made on the feasibility of using groundwater as source water for the ASR system. The pilot impoundment will be operated continually during this period in support of data collection for the full-scale impoundment proposed at the site.
Task 8 – Project Development Process
This task involves the processes necessary to complete the pilot project. The process starts with the preparation and approval of this Project Management Plan (PMP). The next step is the preparation of the Pilot Project Design Report (PPDR), which includes design and permitting phases of the project. In parallel to the PPDR, (National Environmental Policy Act (NEPA) requirements will be addressed. Before significant construction can begin, the Project Cooperation Agreement (PCA) must be prepared and approved. Also included in the process is the State of Florida's Chapter 373.1501 requirements for state funding. Finally, a Technical Data Report (TDR) will be prepared at the end of the pilot project. The TDR will summarize the findings of the pilot project and make recommendations for further study. Information from the TDR will be used during preparation of the Project Implementation Report (PIR) of the full-scale ASR component of CERP.
Task 9 – Permitting
This task involves the permits necessary to construct and operate the pilot ASR system. Permitting requirements may include Class V Construction Permits, Operating Permits, Water Quality Criteria Exemptions (WQCEs), Limited Aquifer Exemptions (LAEs), an National Pollutant Discharge Elimination System (NPDES) permit, and a Water Use Permit. A FDEP UIC ASR Well Construction Permit will be needed before construction can begin. The UIC construction permit will also allow limited cycle testing (Task 11) of the pilot ASR system. The existing ASR exploratory well will be re-permitted in addition to permitting the remaining two ASR wells. If any secondary drinking water standards are exceeded, a WQCE from FDEP may also be required. An exemption may also be required for the exceedance of primary drinking water standards such as coliform (which is common in surface water). ). A LAE is the current regulatory relief mechanism allowed by FDEP if coliform is exceeded in the source water of an ASR system. EPA has also indicated that it may allow a risk-based approach to the exceedance of coliform prior to recharge into an ASR well. These regulatory issues should become clearer as the pilot project progresses. A NPDES permit will be required before cycle testing can begin. The NPDES permit covers the discharge of water recovered from the ASR wells back into a surface water body. The Water Use Permit would be required for the “use” of groundwater or surface water for storage in the ASR wells.
Task 10 – Design and Construct Remaining ASR Wells, Monitor Wells, and Surface Facilities
This task involves the design and construction of the two remaining ASR wells for the pilot project. The first exploratory ASR well was constructed under Task 1. Following the issuance of an ASR construction permit (Task 9), the remaining two ASR wells can be constructed. The construction of the remaining ASR wells will be similar to the existing well. The task also includes the construction of an additional FAS monitor well, and a SAS monitor well. The construction will conclude with the installation of the surface facilities. The surface facilities include the piping, pumps, instrumentation, etc. necessary to operate the ASR pilot system.
Task 11 – Cycle Testing
This task involves the cycle testing of the pilot ASR system. Once all the components of the ASR pilot project are constructed, permitted, and operational (ASR wells, monitor wells, treatment facility, etc.), then cycle testing may begin. This task involves operation, data collection, and reporting necessary to support the evaluation of the pilot project.
Task 12 – Post-Construction Activities
This task involves all those activities that will be necessary to complete before construction is deemed complete. These activities include certifications, credits, audits, and reports necessary to close out the project.