EVALUATING CURRENT AND HISTORICAL ASR SYSTEM PERFORMANCE IN FLORIDA

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1 EVALUATING CURRENT AND HISTORICAL ASR SYSTEM PERFORMANCE IN FLORIDA June Mirecki, US Army Corps of Engineers, Jacksonville FL; Don Ellison, Southwest Florida Water Management District, Brooksville FL; Mark B. McNeal, ASRus LLC, Tampa FL; R. David G. Pyne, ASR Systems LLC, Gainesville FL; Robert Verrastro, South Florida Water Management District, West Palm Beach FL INTRODUCTION Objective evaluation of Aquifer Storage Recovery (ASR) system performance requires a systematic method so that the diversity of systems (potable, surface water, groundwater, and reclaimed) can be compared and classified uniformly. A recent study (Bloetscher et al., 2014) concluded that 26 percent of ASR systems across the United States have been functionally abandoned. In Florida, 32 ASR systems were identified as inactive, a term that was used synonymously with abandoned and caused the misperception that a large number of ASR wells were plugged and abandoned. In contrast, this paper presents an objective evaluation of Florida ASR system status using the Florida Department of Environmental Protection (FDEP) Underground Injection Control (UIC) permitting process documents as the primary dataset. Plugged and abandoned ASR wells in Florida totaled 6%, or 3 of the 55 ASR projects currently in the FDEP database. METHODS An ASR system consists of a surface treatment facility, plus ASR well(s) and storage zone monitor wells to monitor the recharge water residence in the storage zone. Many ASR systems also include a shallow monitoring well to evaluate potential influences of the stored water on a shallower permeable unit overlying the storage zone. Successful testing of an ASR system first requires construction of all system components, which can be a difficult decision to make based on costs and risks. However, there are several decision points along the permitting process that indicate whether an ASR system can be developed successfully from an exploratory borehole to a full ASR system. Aquifer testing in an exploratory borehole will quantify the aquifer capacity to receive and recover water. If successful, these data are used to support a UIC construction permit. Unsuccessful exploratory boreholes can be repurposed or plugged and abandoned. If hydrogeologic conditions are favorable for ASR, economic considerations exert a strong influence on further development of an ASR system. In this study, we quantify ASR system development of all potable/surface water/groundwater and reclaimed facilities currently tracked on the Florida Department of Environmental Protection (FDEP) database (Oculus; FDEP, 2016). To test and ultimately operate an ASR system, the Florida UIC program requires a progressive permitting process that consists of: 1) construction of an exploratory borehole for aquifer testing (often under a construction permit); 2) ASR system construction; 3) cycle testing of successive recharge and recovery cycles, also under a construction permit; and finally, after all monthly operating reports are filed and interpreted, 4) acquisition of an operation permit for the ASR system.

2 The status of potable ASR systems (including surface water and groundwater recharge sources) and reclaimed water ASR systems (highly treated source water from waste water treatment plants) are classified within the FDEP permitting process, to track each project s progress towards an operation permit to fulfill water supply requirements. ASR system status is classified as one of the following: active, idle, inactive, repurposed, and plugged and abandoned (Table 1). Table 1. Criteria used to define ASR system status as of March ASR System Status ACTIVE IDLE INACTIVE REPURPOSED NOT CONSTRUCTED PLUGGED AND ABANDONED Criteria ASR system has a current UIC construction or operation permit, and monthly operating reports have been submitted to FDEP as of September 2015 or later. All systems currently are cycle testing or operating. ASR system UIC permit is current, but monthly operating reports have not been submitted since September Some systems may be under a noflow condition of a current UIC permit, or are in the re-permitting process. ASR system was constructed, but the UIC construction permit has expired. UIC construction permit may or may not be current, but the utility decided to repurpose the ASR well to a monitoring, water supply, or deep injection well. UIC permit was acquired and may or may not be current. ASR system or exploratory borehole was not constructed at all, or not developed beyond the exploratory borehole for the ASR well. ASR system was constructed and subsequently plugged and abandoned (P&A), or exploratory borehole showed unsuitable hydrogeologic characteristics for ASR. All ASR wells have idle periods when no recharge and no recovery is occurring. This can occur for a number of reasons, including economic considerations, fluctuations in supply and demand, regulatory changes or interpretations, changes in source waters or pre-treatment requirements, maintenance or well rehabilitation requirements, or political reasons. All UIC permit and monthly operating report data available on the Oculus database were compiled, and ASR system status was interpreted using records through February Summary tables are presented for potable ASR systems (Table 2) and reclaimed ASR systems (Table 3). Potable and reclaimed ASR systems are evaluated separately (although status criteria are the same) because the development of these systems differs. From these datasets, the number of ASR systems classified by status was determined.

3 Table 2. Potable water (including groundwater and surface water) ASR system permit data and system status. ASR System Name County FDEP Facility ID FDEP Permit Type No. of ASR Wells Number FDEP Permit Information Date Issued Date Expires Cycle Testing Conducted? Most Recent Monthly Operating Report Current (March 2016) Status of ASR System Boynton Beach Palm Beach Con UC 8/14/2012 8/13/2017 Yes Feb 2016 Active Bradenton Bill Evers Manatee Con UC 10/28/ /28/2019 No Under construction Bradenton HSPS Manatee Op UO 8/14/2013 8/13/2018 Yes Jan 2016 Active Cocoa Claude Dyal Brevard LOATU 10 Not applicable Yes June 2015 Active Collier Co Manatee Rd Collier Op-LOATU 1 Not applicable Yes Not Avail. Active Lake Manatee Manatee Con UC 9/27/2011 9/26/2016 Yes Jan 2016 Active Lee Co Corkscrew Lee Op UO 11/25/ /24/2019 Yes Jan 2016 Active Lee Co Olga Lee Con-AO-No flow UC 6/25/2015 6/24/2020 Yes Jan 2016 Active Marco Lakes Collier Op UO 9/17/2015 9/16/2020 Con-AO , 043-UC 7/19/2010 7/18/2015 Yes Nov 2015 Active North Palm Bay Brevard LOATU 1 Not applicable Yes Dec 2015 Active North Port Sarasota Con-AO UC 8/30/2012 8/29/2017 Yes Dec 2015 Active Orange County Eastern Orange Con-AO UC 7/23/2013 7/22/2018 Yes Jan 2015 Active Peace River De Soto Op UO 4/24/2013 4/23/2018 Yes Jan 2016 Active Punta Gorda Charlotte Op , 017-UO 6/17/2014 6/16/2019 Yes Jan 2016 Active Tampa Tippin Hillsborough Con UC 4/30/2012 4/29/2017 Yes Jan Active; 1 P&A Tampa Rome Ave Hillsborough Op UO 12/31/ /30/2018 Yes Jan 2016 Active West Palm Beach Palm Beach Con-AO-WQCE UC 8/8/2012 8/7/2017 Yes Jan 2016 Active Cape Coral NSTS, CPS2, CPS4 Lee 99494, 99495, Cons UC 12/4/ /3/2017 No Not Avail. Idle CERP W Hillsboro Palm Beach Con-AO-WQCE-No Flow UC 9/5/2010 9/4/2015 Yes May 2012 Idle-permit app. in prog CERP Kissimmee River Okeechobee Con-AO-WQCE-No Flow UC 4/11/2013 4/10/2018 Yes July 2013 Idle-permit app. in prog E Hillsboro Palm Beach Con- No Flow UC 1/31/2013 1/30/2018 Yes June 2015 Idle Ft Lauderdale-Fiveash Broward Con - No Flow UC 3/28/2013 3/27/2018 Yes Feb 2001 Idle Miami-Dade SW Miami-Dade Con-AO , 011-UC 12/19/ /18/2018 Yes July 2014 Idle Miami-Dade W Miami-Dade Con-AO UC 12/19/ /18/2018 Yes Dec 2015 Idle Palm Beach Co. System 3 Palm Beach Con - No Flow UC 7/10/2012 7/9/2017 Yes April 2012 Idle Peace River Avon Park DeSoto Con-AO UC 6/24/2011 6/23/2016 Yes (Ltd) Not Avail. Idle Sanford Seminole Con-AO UC 7/5/2012 7/4/2017 Yes Sept 2015 Idle Seminole-Markham Seminole Con-AO UC 1/12/2012 1/11/2017 Yes July 2011 Idle SFWMD Taylor Ck (L-63N) Okeechobee Con-AO UC 7/11/2012 7/10/2017 Yes Not Avail. Idle Sunrise-Springtree Broward LOATU 1 Not applicable Yes Nov 2014 Idle Deland Volusia Con-AO UC 3/25/2008 3/24/2013 Yes June 2011 Inactive Ft Myers Winkler Lee Con UC 6/1/2005 5/31/2010 Yes (Ltd) Not Avail. Inactive Lake Tarpon Pinellas Con-AO-WQCE UC 11/10/ /9/2015 No Not Avail. Inactive Notes: Con, Construction; Op, Operations; LOATU, Letter of Authorization to Use; AO, administrative order (usually for arsenic exceedance); WQCE, water quality criteria exemption; Ltd, limited, P&A, plug & abandoned The source water for the City of West Palm Beach ASR program is untreated surface water from Clear Lake. A WQCE was obtained to waive the groundwater discharge standard for total coliform (4 cfu/100 ml).

4 Table Potable water (including groundwater and surface water) ASR system permit data and system status completed. ASR System Name County FDEP Facility ID FDEP Permit Type No. of ASR Wells FDEP Permit Information Cycle Testing Conducted? Most Recent Monthly Operating Report Current (March 2016) Status of ASR System Number Date Issued Date Expires Cape Coral (Horseshoe) Lee Expl UC 3/5/2013 3/4/2018 No Not Avail. Repurposed mon. well Delray Beach Palm Beach Con UC 3/26/2004 3/25/2009 Yes Feb 2016 Repurposed WS well FKAA Homestead Miami-Dade Con UC 12/21/ /20/2008 Yes Not Avail. Repurposed WS well Lee Co N Reservoir Lee Con UC 7/11/2005 7/10/2007 Yes Jan 2000 Repurposed WS well San Carlos Estates (BSU) Collier Con UC Yes (Ltd) Not Avail. Repurposed ROS well Sanibel Lee Con U0-1I No Jan 2016 Repurposed DIW Brighton Seminole Glades Expl Not Required 1 Sovereign Entity No Not Avail. Exploratory Well only CERP Moore Haven Glades Con UC 2/17/2004 2/16/2009 No Not Avail. Not Constructed CERP Port Mayaca Martin Con-AO UC 5/6/2009 5/5/2014 No Not Avail. Not Constructed Collier Co Carica Rd Collier Expl UC 8/18/2004 8/17/2009 No Not Avail. Exploratory Well only Con , 003-UC 11/1/ /31/2010 No Not Avail. Not Constructed Cape Coral (Gator Slough) Lee Expl /5/2013 3/4/2018 No Not Avail. Exploratory Well only Cape Coral (Hermosa Canal) Lee Expl UC 3/5/2013 3/4/2018 No Not Avail. Exploratory Well only Collier Co Gordon River Collier Con UC 5/6/2008 5/5/2013 No Not Avail. Not constructed Daytona Bch Brennan Volusia Con UC 1/31/2008 1/30/2013 No Not Avail. Not Constructed Naples Stormwater Collier Expl UC 10/24/ /23/2017 No Aug 2013 Exploratory Well only Royal Poinciana Collier Con-AO UC 8/16/2011 8/15/2016 No Not Avail. Not Constructed SFWMD Paradise Run Glades Expl UC No Not Avail. Exploratory Well only Tuscany Reserve Collier Con UC 3/13/2006 3/12/2011 No Not Avail. Not Constructed Volusia-Empire Volusia Con UC 3/25/2008 3/24/2013 No Not Avail. Not Constructed Broward Co 2A WTP ASR Broward P&A UA 5/30/2013 5/29/2015 Yes Feb 2014 Plugged & Abandoned CERP Caloosahatchee River Hendry Expl UA 1/5/2008 1/5/2013 No Not Avail. Plugged & Abandoned Miami Beach Miami-Dade P&A UA 11/15/ /12/2016 Yes March 1998 Plugged & Abandoned Notes: Con, Construction; Op, Operations; Expl, Exploratory Borehole, LOATU, Letter of Authorization to Use; AO, administrative order (usually for possible arsenic exceedance); WQCE, water quality criteria exemption; Ltd, limited, P&A, plug & abandoned; WS, water supply; ROS Reverse Osmosis Supply; DIW, deep injection well; WTP, water treatment plant; CERP, Comprehensive Everglades Restoration Plan.

5 Table 3. Reclaimed water ASR system permit data and system status. ASR System Name County FDEP Facility ID FDEP Permit Type No. of ASR Wells Number FDEP Permit Information Date Issued Date Expires Most Recent Monthly Operating Report Cycle Testing Conducted? Current (March 2016) Status of ASR System Cocoa Beach Brevard Con UC 4/14/2011 4/13/2016 January 2016 Yes Active Collier Co Livingston Rd/Pelican Bay Collier Con ,-008, 009-UC 5/13/2014 5/12/2019 None Available No Under Construction Englewood Charlotte Op UO 7/30/2013 7/29/2018 January 2016 Yes Active Naples WRF Collier Op UO 4/8/2015 4/7/2020 January 2016 Yes Active Naples WRF Collier Con UC 8/23/2010 8/22/2018 None Available No Construction Pending Oldsmar Pinellas Con UC 7/30/2012 7/29/2017 January 2016 Yes Active Palmetto Manatee Con UC 6/5/2012 6/4/2017 January 2016 Yes Active Polk County Polk Con UC 9/9/2014 9/8/2019 January 2016 Yes Active Sarasota Co Central Sarasota Op UO 8/3/2015 8/2/2020 December 2015 Yes Active St Petersburg SW WRF Pinellas Op-AO UO 7/29/2011 7/28/2016 February 2016 Yes Active St Cloud Southside WWTP Osceola Con ,002-UC5X 10/27/ /26/2019 None Available No Under Construction Manatee SW Manatee Con UC 2/24/2015 2/23/2020 April 2015 Yes Idle Club Pelican Bay Collier Con UC 5/11/2006 5/10/2011 None Available No Repurposed to WS well Hillsborough Big Bend Hillsborough Con UC Expired None Available No Repurposed to a mon. well Cape Coral Everest Lee Expl UC 5/24/2005 5/23/2010 None Available No Not Constructed Hillsborough Cargill Hillsborough Con UC Expired None Available No Not Constructed Manatee N Manatee Con UC 8/1/2005 7/31/2010 None Available No Exploratory borehole only Pt St Lucie Westport WWTP St. Lucie Con-AO UC 6/20/2011 6/19/2016 None Available No Not constructed Rotunda Charlotte Con UC 1/22/2009 1/21/2014 None Available No Exploratory borehole only Canaveral Port Authority Brevard Con /9/2005 6/8/2010 None Available No Plugged and Abandoned Clearwater Pinellas Con UC 6/8/2005 6/7/2010 None Available No Plugged and Abandoned Hillsborough NW Hillsborough Con UA Expired None Available Yes Plugged and Abandoned Pinellas Co S Cross Bayou Pinellas P&A UA 12/9/ /8/2019 December 2014 Yes Plugged and Abandoned Notes: Con, Construction; Op, Operations; Expl, Exploratory Borehole, AO, administrative order (usually for possible arsenic exceedance); P&A, plug & abandoned; WS, water supply; DIW, deep injection well; WRF, water reclamation facility; WWTP, wastewater treatment plant.

6 RESULTS Current Status of Potable and Reclaimed ASR Systems in Florida A total of 55 potable ASR systems are tracked currently on the FDEP Oculus database. Potable ASR system status consists of the following: active, 17 (31 percent); idle, 13 (24 percent); inactive, 3 (6 percent); repurposed, 6 (10 percent); not constructed, 13 (24 percent); and plugged and abandoned, 3 (6 percent). Percentages are rounded to the nearest number. Status classification is shown graphically in a bar chart (Figure 1). A total of 23 reclaimed ASR systems are tracked currently on the FDEP Oculus database. Reclaimed ASR system status consists of the following: active, 11 (48 percent); idle, 1 (4 percent); inactive, 0; repurposed, 2 (9 percent); not constructed, 5 (22 percent); and plugged and abandoned, 4 (17 percent). Percentages are rounded to the nearest number. Status classification is shown graphically in a bar chart (Figure 1). Figure 1. Potable (left) and reclaimed (right) ASR system status classification. Potable ASR System Status over Time Construction and operation permits for all ASR systems are issued for a 5-year duration by the FDEP UIC program. Therefore, those permits issued prior to 2011 are not current, but these facilities are still tracked in Oculus. ASR system status classification by the year of permit issue is shown graphically (Figure 2).

7 Figure 2. Number of ASR system permits issued by year. ASR wellfields have been operational in Florida since the first ASR wellfield at Lake Manatee received its operation permit in Some potable ASR systems or exploratory boreholes having their most recent permits issued prior to 2011 (n=21) generally are inactive, repurposed, were never constructed, or were plugged and abandoned. Active potable ASR systems generally have received a permit since Two potable ASR systems have been cycle tested but are inactive (Deland, Fort Myers-Winkler Ave.). Five potable ASR construction permits were revised to repurpose the exploratory borehole to serve as monitor, water supply, or deep injection well (Table 2). Four potable ASR system permits did not proceed beyond construction of an exploratory borehole (Brighton, CERP Port Mayaca, Collier County-Carica Rd., Paradise Run). Paradise Run provides a typical example of this category, as exploratory monitoring wells were successfully drilled and significant hydrogeologic data were collected in support of a stacked ASR system (using multiple receiving zones), but lack of available funding has temporarily suspended ASR development even though data supports a 50 MGD ASR system at this location. Seven potable ASR system permits never progressed beyond permit acquisition (Table 2). One potable ASR system was permitted, cycle tested, and subsequently plugged and abandoned (Miami Beach). This failure resulted from poor conceptual design. One exploratory borehole was plugged and abandoned (CERP Caloosahatchee River) due to unsuitable hydrogeologic conditions in the proposed storage zone in the Upper Floridan aquifer. Potable ASR systems or exploratory boreholes that are currently permitted (post-2011; n=30) generally are active or idle (Table 2). Six active potable ASR systems have obtained operation permits (Bradenton HSPS, Lee County-Corkscrew, Marco Lakes, Peace River WF1 and WF2, Punta Gorda and Tampa-Rome Ave.), confirming successful completion of a multi-year permitting and testing program. Most of these systems are considered successful investments in water resource infrastructure, and can operate with fewer regulatory requirements. Twelve active ASR systems currently are cycle testing under construction permit or Letter of Authorization to Use (LOATU) authority. Thirteen idle potable ASR systems can still function under existing construction permit authority. Few currently permitted potable ASR systems are repurposed, inactive, or plugged and abandoned. Exceptions are potable ASR systems that are repurposed (n=1, Cape Coral

8 Horseshoe), or consist only of an exploratory borehole (n=4; Cape Coral Gator Slough and Hermosa Canal, Royal Poinciana, Naples Stormwater). One potable ASR system was permitted, cycle tested, and subsequently plugged and abandoned (Broward Co. 2A) due to utility exasperation. Reclaimed ASR System Status over Time Reclaimed ASR systems have developed more recently, reflecting the recognition that highly treated wastewater is a resource for irrigation water, and the loss of ocean outfalls for wastewater disposal beginning in 2018 (Florida Administrative Code [F.A.C.] 2012). However, status trends in pre- and post-2011 permitting are similar to that of potable ASR systems, except there are fewer reclaimed systems permitted prior to 2011 (Table 3). This is to be expected, since the first reclaimed water ASR construction permit was issued in 1999 (Northwest Hillsborough County), nearly two full decades later than the initial potable water ASR system was being considered in Manatee County. Reclaimed ASR systems or exploratory boreholes having permits issued prior to 2011 (n=11) generally are repurposed, were never constructed, or were plugged and abandoned. There are no inactive permitted reclaimed water ASR systems. Two reclaimed ASR systems (Club Pelican Bay, Hillsborough Big Bend) were repurposed. Two reclaimed ASR systems (Manatee North and Rotunda) did not progress beyond an exploratory borehole, and Manatee North is in the process of repurposing to a monitoring well for a deeper aquifer recharge program. Three reclaimed ASR system construction permits never progressed beyond permit acquisition (Table 3). Two exploratory boreholes were plugged and abandoned (Canaveral Port Authority and Clearwater). The proposed shallow storage zone (35 to 65 ft) at the Canaveral Port Authority site met with public opposition. The Clearwater reclaimed ASR system has evolved into an aquifer recharge indirect potable reuse system. One reclaimed ASR system was permitted, cycle tested, and subsequently plugged and abandoned (Hillsborough NW). Although this system was plugged and abandoned, it is believed by many professionals that insufficient cycle testing was conducted to make this premature determination. Interestingly, Hillsborough County is in the process of drilling a deeper recharge well at this location and a future recovery well may be installed at this site with a very similar well completion as the ASR well that was plugged and abandoned. This project was still considered successful by many, as it broke down the barriers of reclaimed water ASR, developed key regulatory requirements for future reclaimed water ASR systems, and many existing ASR systems that are operating successfully in Florida have benefited greatly by the pioneering efforts of Hillsborough County at this site. Reclaimed ASR systems that currently are permitted (post-2011; n=13) generally are active (n=8). Four active reclaimed ASR systems have obtained operation permits (Englewood WWTP, Naples WRF, Sarasota Co. Central, and St. Petersburg Southwest WRF) confirming successful completion of a multi-year permitting and testing program, and can operate with fewer regulatory requirements. The City of Oldsmar is close to obtaining an operation permit for its reclaimed water ASR system. Another reclaimed water ASR system that is close to obtaining an operation permit is Northwest Polk County, the deepest ASR well worldwide (total depth 2,944 feet) and the first to successfully utilize permeable units within the Lower Floridan aquifer (LFA). The County is currently preparing an operation permit after only two successful cycles. Three systems

9 are under construction, and one system is idle (Table 3). Reclaimed ASR systems are showing steady growth in response to regulatory requirements for wastewater disposal. The most progress occurs at facilities where highly treated wastewater meeting public access reuse standards can be introduced into aquifers characterized by native total dissolved solids (TDS) concentrations that exceed 1,000 mg/l. Aquifers containing less than 1,000 mg/l TDS concentrations require advanced treatment such as reverse osmosis to remove Total Organic Carbon (TOC) and Total Organic Halogens (TOX). There are no recent (post-2011) permitted reclaimed ASR systems that consist only of an exploratory borehole, or that were never constructed. One reclaimed ASR system was permitted, cycle tested, and subsequently plugged and abandoned (Pinellas County S. Cross Bayou). While this statistically qualifies as a plugged and abandoned ASR program, this project involved partially back-plugging a highly transmissive injection well and performing some cycle testing to determine if any reasonable recovery could be achieved. The well was never designed to be an ASR well, but the benefits that the County would realize should this prove successful were worth the research that was performed on this well during the systematic backplugging that occurred. CONCLUSIONS Interpretation of potable ASR system status shows that over half (n=30 of 55 total systems, or 55 percent) of the facilities currently tracked in the FDEP Oculus database are active or idle. Considering only those facilities having active (post-2011) construction or operation permits (n=37), the majority are active or idle (n=30), with five potable ASR systems issued operation permits. Interpretation of reclaimed ASR system status shows that over half (n=12 of 23 total systems, or 52 percent) of the facilities currently tracked in the FDEP Oculus database are under construction, active, or idle. Considering only those facilities having active (post-2011) construction or operation permits (n=14), the majority are active or idle (n=12), with four reclaimed ASR systems issued operation permits. The historical downturn in ASR system applications resulted primarily from testing constraints that resulted from a reduction of the Florida and Federal safe drinking water standard for arsenic (from 50 g/l to 10 g/l) in 2005 and Existing systems also recognized that arsenic is released from most marine limestone lithologies that serve as ASR storage zones during cycle testing. The potential for litigation, and the apparent inability to obtain an ASR operation permit from FDEP from 2001 to 2013 as a result of arsenic exceedances, led many utilities to restrict planning and development of ASR systems throughout Florida, or shelving their previous investments in ASR system construction. Subsequent evolution of the UIC regulatory framework has led to an improved outlook for ASR in Florida. Use of institutional controls, and developing ASR systems where storage zones underlie property boundaries, or are not in underground sources of drinking water (greater than 10,000 mg/l total dissolved solids) have expanded ASR applications in systems permitted after At least 14 ASR operating permits have been issued since Increased acceptance of the Target Storage Volume (TSV) approach to ASR well development that guided successful ASR wellfield implementation from 1983 to 2001 has contributed to this improved outlook for

10 ASR to meet Florida s water storage needs. Recent permit conditions allow for a Zone of Discharge in lieu of obtaining a Water Quality Criteria Exemption, a major step that should continue to advance the development of ASR systems throughout Florida. Many ASR systems that were shelved during the period of regulatory uncertainty surrounding the arsenic issue have recently renewed their construction permits and cycle testing is progressing at several of these sites. REFERENCES Bloetscher, F., Sham, Chi Ho, Danko, J.J., III, and Ratick, S., Lessons Learned from Aquifer Storage and Recovery (ASR) Systems in the United States. Journal of Water Resource Protection, 6: Florida Administrative Code (2012). Sewage disposal facilities. Advanced and secondary waste treatment. Chapter 403, section 086, Florida Department of Environmental Protection, Consolidated Oculus Electronic Document Management System. Accessed at