Letter to the Editor / Incompetence or Cover-up

By Diane Johnson

Before I moved to the Keys I’d never thought about where all the wastewater goes when you flush the toilet or take a shower. Then there was all the brouhaha about deep wells versus shallow wells for the Cudjoe Wastewater Treatment Plant, and I got educated. The output from the Plant goes into shallow wells, which only go down 80-120 feet. Unfortunately, we learned from FIU’s Dr. Briceno, given the porous nature of the Keys, that treated wastewater migrates from those shallow wells to our nearshore waters. Hence, the final decision to dig a Deep Well, which goes down 3300 feet.

Testing by the Florida Keys Aqueduct Authority’s (FKAA) consultant, Flowers Chemical Laboratory, Inc., reports the number of fecal coliform and enterococci in the groundwater under the treatment plant and former landfill is “too many colonies to count. ”. The Lab Reports are posted on the FKAA website monthly at: http://www.cudjoewastewater.com under documents.

“Too many colonies to count” first appeared on the Flowers Reports in November 2015 for one of five shallow groundwater-monitoring wells. Since that time, “too many colonies to count” have been reported at two of the five monitoring wells at each quarterly sampling of groundwater.

I spoke with Julie Cheon, the Public Information Manager for the Aqueduct Authority and learned that ” There is no sanitary control over the monitoring wells”. “Its part of nature” she explained; the results of birds and deer who frequent the area. “We were seeing hits of ecoli before there was any discharge from the Plant.” Perhaps the former landfill is contributing to the increase in fecal coliform and enterococci.

The problem is we don’t know the extent of the fecal coliform and enterococci in the ground water when the Flowers Lab reports too many colonies to count. The Florida Department of Environmental Protection (FDEP) publishes a document to guide Discharge Monitoring Reporting (DMR). This FDEP document on p.13 clearly states: “Laboratories should be encouraged to conduct the necessary dilution series in order to obtain a quantifiable result for reporting fecal coliform values. Instead of reporting “TNTC,” laboratories should report the results as “> X,” where X is the minimum number of colony forming units/100 mL based on the sample dilutions as determined following the method outlined in EPA 600/8-78-017. However, if your laboratory reports a fecal coliform observation as being “TNTC” (too numerous to count) do not enter “TNTC” on the DMR. In order to use this result (e.g. to calculate the geometric mean for the month), a value is needed for this observation.”

Failing to accurately measure the fecal coliform and enterococci (gut bacteria) at the Cudjoe Wastewater Treatment Plant monitoring wells effectively nullifies the Lab’s results because we don’t know any more than we did before the testing. Why is the incompetence being tolerated? Why have DEP and the FKAA accepted the “too many to count” reports when testing protocol calls for diluting the sample until the tester is able to count the number of colonies. You decide.

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