Report of Permit Noncompliance

Turbidity Monitoring
Preliminary Data Review

Juno Beach Restoration Project

FDEP Permit 0127642-001-JC

Prepared by:
Palm Beach County Reef Rescue
PO Box 207
Boynton Beach, FL 33425

January 4, 2010
Introduction

Palm Beach County Reef Rescue (PBCRR) has conducted a preliminary data review of
borrow area turbidity compliance monitoring samples collected and analyzed in
conjunction with the Juno Beach Restoration Project, FDEP Permit 0127642-001-JC.
Turbidity compliance monitoring reports were supplied by the permittee, Palm Beach
County Environmental Resource Management (PBCERM), via electronic correspondence
transmitted December 31, 2009. The reports supplied by the permittee include water
quality monitoring results for the six day period December 21 through December 26,
2009.

A total of nineteen “Juno Beach Turbidity Monitoring Reports” were received as pdf
documents in the above referenced email correspondence. Also included in the electronic
submission were nineteen items labeled with a HTML file extension. These files could
not be opened and appeared to be empty, based on their 93 byte file size.

Each of the nineteen “Juno Beach Turbidity Monitoring Reports” were reviewed for
project permit compliance. In addition, borrow area sampling data were plotted on maps
prepared by PBCRR. Individual maps were prepared for each borrow area sampling
episode with background sample collection locations identified as “B” and compliance
sample locations designated as “C”. The maps, presented below, were utilized to
calculate the distance between sample collection locations and determine compass
bearing for each data set. Each graphic representation is accompanied by contactor
supplied report identification reference, sample collection location, sample collection
time, sample analysis time, turbidity analytical result, current direction and velocity.

Contractor supplied information was utilized to calculate distance and compass bearing
between background and compliance samples. These data are presented beneath the
contractor supplied information on the individual maps prepared by PBCRR. In addition,
a reviewer text box is presented with each sampling episode and contains a description of
permit noncompliance items identified.

Findings

Permit noncompliance events identified are listed below and also represented as reviewer
red text in comment boxes presented on the individual sample collection location maps
included with this summary report.

• The “Juno Beach Turbidity Monitoring Reports” do not identify the

contractor or provide the name of the individual(s) performing sample collection
and analysis.
• A statement describing the methods used in collection, handling, storage
and analysis of the samples is not provided.
• A map indicating the sampling locations is not provided.

2 PBCRR January 2010

• The position of the dredge in reference to compliance and background
sample collection locations is not included.
• A statement by the individual responsible for implementation of the
sampling program concerning the authenticity, precision, limits of detection,
calibration of the meter and accuracy of the data is not provided.
• The analytical methodology employed for turbidity analysis is not stated.
• The type of analytical instrument employed for turbidity analysis is not
stated.
• Borrow area turbidity compliance and background samples were not
collected 450 meters apart in all instances as required by the project permit.
• Turbidity compliance samples were not collected downcurrent of
background sample locations on all occasions as required by the project permit.
• The permit minimum of 4 sample collection episodes per day was not
observed on everyday of project activity.
• The minimum of 4 hours between sample collection episodes as required
by the project permit was not observed on all days.
• Contractor failed to report current direction for some sampling episodes.
• Contractor failed to report water temperature for all sampling episodes.

3 PBCRR January 2010

Contractor report reference: 12-21-09 0630
Sample collection: B = 1001, C = 1015
Sample analysis: B = 1007, C = 1020
Reported turbidity (NTU) B = 0.05, C = 1
Reported current direction and velocity: North (00), 0.5 kts
Calculated distance between background and compliance samples: 420 meters
Calculated compass bearing between background and compliance samples: 2990

Reviewer comment: Compliance sample not downcurrent from background location.

Compliance sample collected less than 450 meters from background location.

4 PBCRR January 2010

Contractor report reference: 12-21-09 1200
Sample collection: B = 1350, C = 1407
Sample analysis: B = 1355, C = 1416
Reported turbidity (NTU) B = 0.10, C = .50
Reported current direction and velocity: North (00), 1 kts
Calculated distance between background and compliance samples: 800 meters
Calculated compass bearing between background and compliance samples: 0130

5 PBCRR January 2010

Contractor report reference: 12-21-09 1745
Sample collection: B = 1810, C = 1825
Sample analysis: B = 1816, C = 1828
Reported turbidity (NTU) B = 0.36, C = .32
Reported current direction and velocity: North (00), 1 kts
Calculated distance between background and compliance samples: 650 meters
Calculated compass bearing between background and compliance samples: 3310

Reviewer note: Only 3 turbidity sampling episodes on 12-21-09

6 PBCRR January 2010

 Contractor report reference: 12-22-09 0700
Sample collection: B = 0755, C = 0840
Sample analysis: B = 0805, C = 0848
Reported turbidity (NTU) B = 0.38, C = .40
Reported current direction and velocity: North (00), 1 kts
Calculated distance between background and compliance samples: 720 meters
Calculated compass bearing between background and compliance samples: 2020

Reviewer comment: Compliance sample collected upcurrent from background location.

Revised page 8

7 PBCRR January 2010

 Contractor report reference: 12-22-09 1200
Sample collection: B = 1315, C = 1332
Sample analysis: B = 1320, C = 1339
Reported turbidity (NTU) B = .04, C = .7
Reported current direction and velocity: South (1800), 1-2 kts
Calculated distance between background and compliance samples: 370 meters
Calculated compass bearing between background and compliance samples: 3240

Contractor comment: Plume visible

Reviewer comment: Compliance sample collected upcurrent from background location.

Comment added Jan. 5, 2010

Compliance sample collected less than 450 meters from background location.

8 PBCRR January 2010

Contractor report reference: 12-22-09 1530
Sample collection: B = 1718, C = 1732
Sample analysis: B = 1725, C = 1734
Reported turbidity (NTU) B = .99, C = 1.87
Reported current direction and velocity: None
Calculated distance between background and compliance samples: 300 meters
Calculated compass bearing between background and compliance samples: 3050

Reviewer comment: Compliance sample collected less than 450 meters from
background location.

9 PBCRR January 2010

Contractor report reference: 12-22-09 2000
Sample collection: B = 1941, C = 1933
Sample analysis: B = 1945, C = 1935
Reported turbidity (NTU) B = 1.31, C = 1.62
Reported current direction and velocity: North (00), 1 kts
Calculated distance between background and compliance samples: 880 meters
Calculated compass bearing between background and compliance samples: 3350

Reviewer comment: Less than 4 hours between samples.

Contractor report reference: 12-23-09 0600

No borrow area samples collected
Contractor comment: No dredging 0700

10 PBCRR January 2010

Contractor report reference: 12-23-09 0958
Sample collection: B = 1028, C = 1044
Sample analysis: B = 1029, C = 1045
Reported turbidity (NTU) B = 0.31, C = 7.86
Reported current direction and velocity: North (00), 2 kts
Calculated distance between background and compliance samples: 390 meters
Calculated compass bearing between background and compliance samples: 3490

Reviewer comment: Compliance sample collected less than 450 meters from
background location.

Contractor report reference: 12-23-09 1400

No borrow area samples collected
Contractor comment: No dredge

11 PBCRR January 2010

Contractor report reference: 12-23-09 1800
No borrow area samples collected
Contractor comment: wind 24 mph, seas 4-6, too rough for samples

Reviewer supplied weather data: Wind speed at 1800 ~ 13 mph

Average Wind Speed: 13 mph (ENE) 12-23-09 PBI

12-23-09 PBI

12 PBCRR January 2010

Contractor report reference: 12-24-09 0700
Sample collection: B = 0725, C = 0740
Sample analysis: B = 0730, C = 0742
Reported turbidity (NTU) B = 0.07, C = 0.19
Reported current direction and velocity: North (00), 2 kts
Calculated distance between background and compliance samples: 740 meters
Calculated compass bearing between background and compliance samples: 0060

Contractor comment: seas rough 4-6’

Reviewer supplied weather data: Wind speed at 0700 ~ 15 mph

Average Wind Speed: 17 mph (ESE) 12-24-09 PBI

12-24-09 PBI

13 PBCRR January 2010

Contractor report reference: 12-24-09 1100
No borrow area samples collected
Contractor comment: No dredging

Contractor report reference: 12-24-09 1600

Sample collection: B = 1551, C = 1556
Sample analysis: B = 1552, C = 1557
Reported turbidity (NTU) B = 0.02, C = 1.33
Reported current direction and velocity: North (00), 1 kts
Calculated distance between background and compliance samples: 600 meters
Calculated compass bearing between background and compliance samples: 00

Reviewer note: Only 3 turbidity sampling episodes on 12-24-09

14 PBCRR January 2010

Contractor report reference: 12-25-09 0900
No borrow area samples collected
Contractor comment: No dredging

Contractor report reference: 12-25-09 1600

Sample collection: B = 1715, C = 1726
Sample analysis: B = 1719, C = 1729
Reported turbidity (NTU) B = .45, C = .48
Reported current direction and velocity: North (00), 2 kts
Calculated distance between background and compliance samples: 770 meters
Calculated compass bearing between background and compliance samples: 3200

Reviewer comment: Compliance sample not downcurrent from background location.

Reviewer note: Only 2 turbidity sampling episodes on 12-25-09

15 PBCRR January 2010

Contractor report reference: 12-26-09 0645
Sample collection: B = 0720, C = 0727
Sample analysis: B = 0722, C = 0729
Reported turbidity (NTU) B = .21, C = .27
Reported current direction and velocity: South (1800), <1 -1 kts
Calculated distance between background and compliance samples: 250 meters
Calculated compass bearing between background and compliance samples: 0210

Reviewer comment: Compliance sample collected upcurrent from background location.

Compliance sample collected less than 450 meters from background location.

16 PBCRR January 2010

Contractor report reference: 12-26-09 1045
Sample collection: B = 1123, C = 1130
Sample analysis: B = 1125, C = 1132
Reported turbidity (NTU) B = 02, C = .93
Reported current direction and velocity: 1 kts, no direction recorded
Calculated distance between background and compliance samples: 520 meters
Calculated compass bearing between background and compliance samples: 3560

Reviewer comment: Contractor failed to report current direction.

17 PBCRR January 2010

 Contractor report reference: 12-26-09 1500
Sample collection: B = 1518, C = 1540
Sample analysis: B = 1520, C = 1542
Reported turbidity (NTU) B = 0.01, C = 0.01
Reported current direction and velocity: 1 kts, no direction recorded
Calculated distance between background and compliance samples: 250 meters
Calculated compass bearing between background and compliance samples: 1660

Reviewer comment: Compliance sample collected less than 450 meters from
background location. Contractor failed to report current direction.

Reviewer note: Only 3 turbidity sampling episodes on 12-26-09

PERMIT INFORMATION:

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Permit/Authorization Number: 0276415-001-JC

WATER QUALITY MONITORING REQUIRED:

Frequency: Four times daily at least 4 hours apart during all dredging and sand placement
operations.

Location: Background: At mid-depth, clearly outside the influence of any artificially

generated turbidity plume.

Dredge Site: approximately 300 meters in the opposite direction of the prevailing current
flow.

Dredge Site: Samples shall be collected 150 meters downcurrent from the dredge head,
in the densest portion of any visible turbidity plume.

Reviewer note:
Background = 300 meters up-current
Compliance. = 150 meters downcurrent
Minimum distance between samples = 450 meters

Additionally, samples shall be collected at the borrow area monitoring stations (see SC
43 a) when the dredge is operating within 1,000 feet of the compliance stations or
whenever the turbidity plume is observed over the reef. Samples shall be collected at the
surface and approximately 2 meters above bottom.

All monitoring data shall be submitted within one week of analysis with documents
containing the following information: (1) permit number; (2) dates of sampling and
analysis; (3) a statement describing the methods used in collection, handling, storage and
analysis of the samples; (4) a map indicating the sampling locations; (5) a statement by
the individual responsible for implementation of the sampling program concerning the
authenticity, precision, limits of detection, calibration of the meter and accuracy of the
data.

Monitoring reports shall also include the following information for each sample that is
taken:
(a) time of day samples taken;
(b) depth of water body;
(c) depth of sample;
(d) antecedent weather conditions;
(e) tidal stage and direction of flow;
(f) wind direction and velocity; and
(g) water temperature.

19 PBCRR January 2010

Monitoring reports shall be submitted to the BBCS in Tallahassee (attn: JCP Compliance
Officer) and to the Department’s Southeast District office. Failure to submit reports in a
timely manner constitutes grounds for revocation of the permit. When submitting this
information to the Department, please clearly include, at the top of each page or as a
cover page to the submittal: "This information is provided in partial fulfillment of the
monitoring requirements in
Permit No. 0276415-001-JC, for the Juno Beach Nourishment Project."

Reviewer supplied weather data source:

http://www.wunderground.com/history/airport/KPBI/2009/12/24/DailyHistory.html

20 PBCRR January 2010