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Regional Issues in Aquifer Storage and Recovery for Everglades Restoration 3 Other Topics PROJECT CONSTRAINTS AND ASSUMPTIONS (SECTION 3.3) The PMP acknowledges in section 3.3 that the “implementation schedule of the CERP limits study length which is critical for ecological assays.” This is true, particularly for the additional assays suggested in the previous section of this report. For example, given the many sources of variation in species abundance, including climatic variability, it is unlikely that the Regional Study will be of sufficient duration to definitively demonstrate impacts of ASR on abundance of key species or on shifts in community composition and structure. But the study will provide a good start in that direction and provisions could be made for continuing the sampling under the auspices of the RECOVER plan of the CERP. The PMP also notes that the schedule of the overall study is controlled, in part, by linkages to the schedules of the ASR pilot projects. Ideally, many of the aspects of the regional study should have preceded planning of the pilot site studies. This is particularly true with respect to characterization of the regional hydrogeology, determination of hydraulic parameters of the potential ASR target zones, and preliminary numerical modeling to evaluate possible pressure increases in the Upper Floridan aquifer (UFA) and overlying strata. Also, prior characterization of the quality of surface water sources for the ASR wells would help in determining level of pre-treatment required and in planning for geochemical reaction tests and some of the ecological field studies. Unfortunately, the pilot studies were funded and initiated before the plans for a regional study were outlined in the PMP that is the subject of this review. This unfortunate sequence may preclude optimal use of the regional study results in design and execution of the pilot studies. Nevertheless, consideration should be given to modest changes in schedules of pilot study or regional study tasks if initial results of either study suggest opportunities for enhanced understanding though improved coordination. FUNCTIONAL AREA PLANS (SECTION 7) Section 7.1—Project Management The PMP calls for the use of consultants for the execution of various tasks. Close and thorough coordination of these various consultants is required to ensure the continuity and
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Regional Issues in Aquifer Storage and Recovery for Everglades Restoration integration of these separate efforts to avoid having them become disjointed parts of an overarching task. In view of the stated importance of the fate and transport of microorganisms to the ASR project, an advisory committee should be formed to assist with these aspects of the project. Dr. Ron Harvey, who has extensive experience in this area, is one of the Project Delivery Team members. Such a committee would be helpful in making decisions on these issues. The PMP calls for independent technical review. However, the Independent Technical Review Team is to be made up of only representatives of USACE, SFWMD, and contractors. This constitutes in-house review, which may be sufficient for many tasks. Independent technical review will be an important component of the major tasks. For example, in Appendix H, Quality Control Plan, there are provisions to include outside technical experts in review of the pilot studies, but not the regional study. Outside technical experts should also be included on the Independent Technical Review Team for the regional study in order to enhance credibility and acceptance of the quality of the study. A study of the peer review process at the USACE by the NRC (2002) should provide useful guidelines in this area. Section 7.8—Public Outreach and Involvement Appropriately, public outreach is given high priority in the Regional Study, and the plan appears to be well conceived. Appropriate attention is given to environmental compliance as well (e.g., Endangered Species Act, National Environmental Policy Act), but this is generally not an issue because construction activities are a component of the various project implementation reports (PIR) rather than part of the Regional Study. Section 22.214.171.124—Monitoring During Cycle Testing The plan to over-pump during the first cycle beyond water quality limits and all the way to near 100 percent recovery of injected water is a useful strategy. This will allow the entire recovery mixing-curve to be established and used as a baseline. Section 7.11—Operations and Maintenance The Operations and Maintenance (O & M) plan to be developed through the regional ASR study apparently will cover only data logger systems for monitoring wells constructed as part of this study. However, additional O & M costs associated with these monitoring wells could be substantial depending on the level of monitoring undertaken during full scale ASR operation and the level of maintenance required for the monitoring wells. Even more substantial O & M costs will be associated with the operating ASR wells. For reference, the Las Vegas Valley Water District, with an average recovery cost of $191 per million gallons spends $13,000 per well per year in maintenance.
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