STATE OF FLORIDA
DIVISION OF ADMINISTRATIVE HEARINGS
FERNCREST UTILITIES, INC., )
)
Petitioner, )
)
vs. ) CASE NO. 81-080
) DEPARTMENT OF ENVIRONMENTAL ) REGULATION, )
)
Respondent. )
)
RECOMMENDED ORDER
A hearing was held in the above captioned matter, after due notice, at Fort Lauderdale, Florida, on April 7, 1981 before the undersigned Hearing Officer.
APPEARANCES
For Petitioner: Martin S. Friedman and
R.M.C. Rose, Esquires
Myers, Kaplan, Levinson, Kenin and Richards 1020 East Lafayette Street
Tallahassee, Florida 32301
For Respondent: Alfred Clark, Esquire
Deputy General Counsel
Department of Environmental Regulation 2600 Blair Stone Road
Tallahassee, Florida 32301 ISSUE PRESENTED
Whether Petitioner's application for permit to operate a sewage treatment plant in Broward County should be approved, pursuant to Chapter 403, Florida Statutes.
In this proceeding, Petitioner seeks an operation permit for its sewage treatment plant located in Broward County, Florida. Respondent issued a Notice of Intent to deny the application on December 16, 1980, for the reason that the receiving waters of the plant discharge frequently have a dissolved oxygen concentration below 5 milligrams per liter in contravention of pertinent regulations, and that Petitioner's plant contributes to such substandard conditions.
Three witnesses testified for the Petitioner at the hearing and one witness appeared on behalf of the Respondent. The parties stipulated to the admission in evidence of Exhibits 1 through 8. It was further stipulated that no issue is presented in this proceeding as to statutory time limits prescribed in Section 120.60, F.S., with regard to agency processing of the application. It was further agreed that prehearing answers to interrogatories propounded by the
parties would be considered as evidence herein. Official recognition was taken of the pertinent provisions of Chapter 17, Florida Administrative Code.
FINDINGS OF FACT
Petitioner Ferncrest Utilities, Inc. owns and operates a sewage treatment plant at 3015 Southwest 54th Avenue, Fort Lauderdale, Florida. It presently services the needs of a population of about 2500 primarily located in three trailer parks, certain warehouses, a 153 room hotel, and several other business establishments. The plant was constructed and operated by a lessee of Petitioner's owners, but, in July 1979, Petitioner became the owner and operator of the facility. At that time, it was determined necessary to secure new operators and upgrade the plant equipment and method of process in order to properly service the existing and anticipated future number of customers in the area covered by a Public Service Commission franchise. Although the plant had been operating at a permitted capacity of 0.25 million gallons per day (MGD), Petitioner planned to expand the capacity to 0.60 MGD by modifying the aeration tank, and adding tertiary sand filters and equipment for clarification. Upon assuming control of the plant, Petitioner found that the 0.25 MGD permitted capacity had been exceeded by approximately 120,000 gallons per day for a number of years. Petitioner estimates that a population of 6,000 could be served under its new proposed design capacity. (Testimony of Forman, Exhibit 1)
Pursuant to Petitioner's application for a construction permit, dated May 25, 1979, to modify the existing treatment plant, Respondent issued permit No. DC06-21789 on August 6, 1979. The permit specified that it was for construction of additional tank capacity for an existing 0.25 MGD wastewater treatment plant intended to approve effluent quality, and further stated that plant design capacity would remain at that figure. A subsequent letter from Respondent's subdistrict manager to Petitioner on January 15, 1980, stated that an evaluation of the quality of the surface waters receiving the plant discharge and the effect of such increased discharge would have to be made before processing a request for an increase in permitted flow. (Exhibit 7)
On February 8, 1980, Respondent issued a temporary operating permit for Petitioner to temporarily operate a 0.25 MGD contact stabilization sewage treatment plant, including additional tank capacity and tertiary filtration. Specific conditions attached to the permit stated that it was issued to give the permittee a reasonable period of time to complete construction of the modification outlined in DER Permit DC06-21789 and for subsequent assessment of the effects of discharge on receiving waters. The conditions further required that the facility continue to achieve 90 percent removal of BOD5 and total suspended solids at all times with specified average daily discharges of such substances. Another condition required that the effluent from the plant be adequately chlorinated at all times so as to yield the minimum chlorine residual of 0.5 parts per million after a minimum contact period of 15 minutes. (Exhibit 8)
Thereafter, on July 21, 1980, petitioner filed the instant application for an operation permit for the facility at a design capacity of 0.60 MGD. On October 7, 1980, Petitioner filed a certificate of completion of construction. By letter of December 16, 1980, Respondent's South Florida Subdistrict Manager advised Petitioner that the application for an operating permit had been denied for the reason that monitoring of the Class III receiving waters by the Broward County Environmental Quality Control Board indicated that the dissolved oxygen concentration was frequently below the minimum of 5 milligrams per liter required by Section 17-3.161(1), Florida Administrative Code, and that
Petitioner's plant contributed to the substandard conditions in those waters. Petitioner thereafter requested a Section 120.57(1), F.S., hearing. (Exhibits 1-2, 4, 8)
Petitioner's plant discharges into the North New River Canal through a six inch effluent pipe. The canal extends from Lake Okeechobee to the intracoastal waterway approximately five miles in distance from the point of discharge of Petitioner's plant. Monitoring of water quality in the canal for the past several years by the Broward County Environmental Quality Control Board shows that the dissolved oxygen concentrations at various sampling stations have ranged from below one part per million to in excess of five parts per million, depending upon the season of the year. However, at no station did the dissolved oxygen concentration reach an average of five parts per million. In addition, the tests also showed that BOD5 is generally low in the canal waters.
(Testimony of Mazzella, Exhibits 1, 3, 5)
Petitioner's modified plant is now capable of treating 0.60 MGD and meets current basic state requirements of 90 percent (secondary) removal of BOD and total suspended solids. In fact, the plant has tertiary treatment and can consistently operate at a level of 95 percent treatment. The data submitted by the applicant as to effluent water quality characteristics showed removal of 98 percent BOD, 97 percent suspended solids, 50 percent total nitrogen, and 25 percent total phosphorus with an average chlorine residual in the effluent of
0.2 parts per million. The dissolved oxygen level in the effluent has been established at 6.5 milligrams per liter. (Testimony of Hermesmeyer, Dodd, Exhibit 1)
Respondent's district personnel took one 24-hour sample of the effluent from Petitioner's plant in March 1981 and determined that a concentrate of 14.6 milligrams per liter of ammonia was being discharged to receiving waters. Respondent therefore determined that the dissolved oxygen levels of the canal would be further degraded because approximately 48 to 50 parts per million of dissolved oxygen would be necessary to offset the effects of oxygen removal resulting from the ammonia discharge. Respondent further found that, although the effluent from the plant had 6.5 milligrams per liter of dissolved oxygen, the amounts of phosphorus and nitrogen being discharged could lead to algal blooms and consequent eventual eutrophication of its waters. Respondent's reviewing personnel therefore considers that there would be negative impacts upon the receiving waters if Petitioner discharged its prior licensed capacity of 250,000 gallons per day, and that a discharge of 600,000 gallons per day would double such impacts. Respondent's personnel therefore believes that although Petitioner's facility meets the basic secondary treatment requirements of Rule 17-6.01, Florida Administrative Code, it does not meet the water
quality-based effluent limitation specified in Rule 17-6.10. In order to meet such requirements, it would be necessary to redesign the plant for more efficient removal of nutrients or to redirect the discharge. (Testimony of Mazzella)
Other facilities adjacent to or near the North New River Canal discharge directly or indirectly into the canal waters and contribute to an unknown degree to the poor quality of the canal waters. Additionally, agricultural use of land produces stormwater runoff containing fertilizer residue into the canal in an unknown amount. A sewage treatment plant operates at optimum level of treatment when it discharges at about 50 percent of its treatment capacity. (Testimony of Mazzella)
In 1983, Broward County will require Petitioner's plant to conform to state advanced waste treatment criteria which will provide for additional removal of nitrogen and phosphorus from effluent. To meet this requirement, Petitioner, plans to investigate the possibilities of utilizing a landlocked lake on its property near the treatment plant as a seepage pond. Although Petitioner's plant is identified in area regional plans to be diverted to the Hollywood wastewater treatment plant in the future, there is presently no target date for tying in to such a regional facility. (Testimony of Hermesmeyer, Exhibit 1)
CONCLUSIONS OF LAW
Section 403.087, Florida Statutes, provides that no stationary installation which will reasonably be expected to be a source of air or water pollution shall be operated, expanded or modified without a valid permit issued by the Department of Environmental Regulation. Section 403.088, F.S., concerning water pollution operation permits provides pertinently as follows:
Water pollution operation permits; temporary permits; conditions.--
No person, without written authorization of the department, shall discharge into waters within the state any waste which, by itself or in combination with the wastes of other sources, reduces the quality of the receiving waters below the classification established for them. . .
(3)(a) Any person intending to discharge waste into the waters of the state shall make application to the department for an operation permit. . .
If the department finds that the proposed discharge will reduce the quality of the receiving waters below the classification established for them, it shall deny the application and refuse to issue a permit. . .
A permit shall:
1. Specify the manner, nature, volume, and frequency of the discharge permitted;
3. Contain such additional conditions, requirements, and restrictions as the department deems necessary to preserve and
protect the quality of the receiving waters: . . .
Respondent's implementing regulations provide in part as follow: 17-4.07 Standards for Issuing or Denying
Permits: Issuance; Denial.
A permit may be issued to the applicant upon such conditions as the Department may direct, only if the applicant affirmatively provides the Department with reasonable assurance based on plans, test results, and other information, that the. . .operation. . . of the installation will not discharge, emit, or cause pollution in contravention of Department standards, rules or regulations.
(3) The Department shall issue permits to. . . operate. . .an installation which may
reasonably be expected to be a source of pollution only when it determines that the installation is provided or equipped with pollution control facilities that will abate or prevent pollution to the degree that will comply with the standards or rules promulgated by the Department except as provided in Chapter 403.088, F.S.
(5) The Department may issue any permit upon specified conditions reasonably necessary for the prevention of pollution.
Rule 17-4.24, F.A.C., essentially tracks the requirements for water pollution source operation permits as specified in Section 403.088, F.S.
Rule 17-3.121, F.A.C., specifies the criteria of surface water quality for Class III surface waters which includes the requirement that dissolved oxygen concentration shall not average less than 5 milligrams per liter in a 24 hour period.
Petitioner claims, and Respondent concedes, that the plant meets the basic requirements for an operation permit by the fact that its effluent discharge meets and even exceeds the 90 percent secondary treatment requirements specified in its temporary operation permit, as required in Rule 17-6.01, F.A.C. Although Petitioner's discharge thus meets the "technology-based" surface water effluent limitations required under Rule 17-6.01, Respondent contends that it can require more stringent "water quality-based" effluent limits under Rule 17-
That rule provides pertinently as follows:
17-6.10 Effluent Limitations: Surface Waters.
In addition to any technology-based surface water effluent limitations required under the provisions of Section 17-6.01, F.A.C., all activities and discharges. . .shall also meet water quality-based effluent limitations where necessary to meet water quality
standards.
A water quality-based effluent limit shall be determined by the Department based upon the characteristics of discharge, the receiving water characteristics, and the criteria and standards of Chapter 17-3 and 17-4, F.A.C. and Part II of this Chapter. The Department shall supply the information regarding ambient water quality which is necessary for this determination. . .
Although the above rule requires DER to determine the required effluent limit, no evidence was presented to show that such information has ever been provided to the Petitioner. The rule has been in force since March 1, 1979, which was prior to Petitioner's application for a construction permit. Neither the construction permit nor the temporary operation permit specified any additional requirements, and Petitioner expended almost 245,000 in modifying its plant to achieve the capability for secondary treatment. In the absence of notification
of such requirement, it is considered that Rule 17-6.10 may not now be used as a basis for denying the permit.
The evidence otherwise establishes that Petitioner has provided the requisite "reasonable assurance" that the operation of its plant will not discharge or cause pollution in contravention of Departmental standards, rules or regulations. However, it is also true that the North New River Canal, into which Petitioner's facility discharges, does not meet Class III water quality standards with respect to dissolved oxygen.
Accordingly, Respondent should issue the requested operation permit, but specify the nature and volume of the discharge permitted, and attach specific conditions to such issuance, within the present capability and design of Petitioner's existing facility, as are necessary to reasonably restrict the quantities of nutrients in the effluent to prevent further degradation of the receiving waters.
Posthearing submissions by the parties have been fully considered and those portions thereof which have not been adopted herein are considered to be either irrelevant, unnecessary or unwarranted in fact or law.
That Respondent issue a permit to Petitioner for the operation of its sewage treatment plant, with appropriate conditions as designed to protect the receiving waters.
DONE and ENTERED this 27th day of May, 1981, in Tallahassee, Florida.
THOMAS C. OLDHAM
Division of Administrative Hearings The Oakland Building
2009 Apalachee Parkway
Tallahassee, Florida 32301
(904) 488-9675
Filed with the Clerk of the Division of Administrative Hearings this 27th day of May, 1981.
COPIES FURNISHED:
Alfred Clark, Esquire Deputy General Counsel Department of Environmental
Regulation
2600 Blair Stone Road Tallahassee, Florida 32301
Martin S. Friedman and
R.M.C. Rose, Esquires
Myers, Kaplan, Levinson, Kenin and Richards
1020 East Lafayette Street Tallahassee, Florida 32301
Honorable Victoria Tschinkel Secretary, Department of Environmental
Regulation
2600 Blair Stone Road Tallahassee, Florida 32301
=================================================================
AGENCY FINAL ORDER
=================================================================
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
FERNCREST UTILITIES, INC.,
Petitioner,
vs. CASE NO. 81-080
STATE OF FLORIDA, DEPARTMENT OF ENVIRONMENTAL REGULATION,
Respondent.
/
FINAL ORDER
BY THE DEPARTMENT:
On May 27, 1981, the duly appointed hearing officer of the Division of Administrative Hearings submitted to the Department and all parties a Recommended Order consisting of findings of fact, conclusions of law, and a recommendation. A copy of the Recommended Order is attached and incorporated in this Final Order as Exhibit "A". Pursuant to Section 17-1.68, Florida Administrative Code, and Section 120.57(1)(b)8, Florida Statutes, the parties were allowed ten (10) days in which to submit exceptions to the hearing officer's Recommended Order. On June 8, 1981, Respondent's attorney submitted his Exceptions To Recommended Order And Memorandum. On June 10, 1981, Petitioner filed its Reply To Exceptions. Neither party requested oral argument as allowed by Department rules. The Recommended Order thereafter came before me, as head of the Department, for final agency action in this matter.
RULINGS ON EXCEPTIONS
I have considered Respondent's Exceptions To Recommended Order And Memorandum together with Petitioner's Reply To Exceptions. Respondent's exceptions are dealt with as follows:
Exception number one is directed at paragraph one of the hearing officer's findings of fact. Having reviewed the record, I see no need to reject the findings of the hearing officer in that paragraph, but rather to supplement them. Respondent's exception is well taken in asserting that the undisputed testimony presented by both parties in this case reveals that prior to 1979, the subject plant was not meeting secondary treatment requirements, was the subject of Department enforcement action and was issued permits for the purpose of upgrading the plant to meet secondary treatment requirements. (See testimony of Hamilton Collins Foreman, Jr., transcript pages 11-15).
Respondent's exception number two is irrelevant to the outcome of this proceeding, in light of the dispositive issues discussed below. It is accordingly rejected.
Respondent's exceptions number three and four are dispositive of this case, and merit repeating here.
In paragraph four of the recommended conclusions of law, the hearing officer states:
"Although the above rule [17-6.10] requires DER to determine the required effluent limit, no evidence was presented to show that such information has ever been provided to the Petitioner. The rule has been in force since March 1, 1979, which was prior to Petitioner's application for a construction permit.
Neither the construction permit nor the temporary operation permit specified any additional requirements, and Petitioner expended almost $245,000 in modifying its plant to achieve the capability for secondary treatment. In the absence of notification of such requirement, it is considered that Rule 17-6.10 may not now be used as a basis for denying the permit."
As Respondent's attorney notes, the nature of the "information" concerning which there was an "absence of notification" is unclear and he offers two possibilities for discussion. If the hearing officer meant that the Department did not "supply the information regarding ambient water quality" as required by Section 17-6.10(1)(a), Florida Administrative Code, then the hearing officer was in error, as a matter of law. The "information" required by the subject rule is the water quality data upon a water quality-based effluent limitation is calculated; the Department, as opposed to the applicant, supplies this "information" (to itself, not the applicant) and makes the determination of the effluent limit required to meet surface water quality standards.
In this case, the record reveals that the Department did supply the required "information" and make the required determination, and this fact is at least implicitly recognized by the hearing officer in paragraphs four and five of his findings of fact. In any event, I agree with Respondent's exception that it is erroneous to read Section 17-6.10(1)(a), Florida Administrative Code, as requiring the Department to supply this "information" to each permit applicant.
As Respondent's attorney notes, a more likely reading of the hearing officer's language, quoted above, is that it expresses his view that because the Department failed to notify Petitioner that it would have to meet water quality- based effluent limits when a construction permit was issued in 1979 and a temporary operation permit was issued in early 1980, those limits cannot now be imposed. I agree with Respondent's attorney that the hearing officer is in error as a matter of law if this was his intended meaning.
Prior to issuance of the construction and temporary operating permits, Petitioner's sewage treatment plant was not even meeting secondary treatment requirements, and an upgrade of the plant to meet those secondary treatment requirements was the purpose of initially issuing and then extending those permits. The record and the hearing officer's findings of fact (paragraphs two and three) reveal that petitioner was specifically notified that issuance (and subsequent modification) of the construction permit:
". . .should not be construed as an intent to permit this facility for waste flows in excess of 0.25 MGD. An evaluation of the quality of the surface waters receiving your discharge and the effective of such increased discharge would have to be made before processing a request for an increase in permitted flow." (Emphasis supplied) (Exhibit 7)
and that the temporary operating permit was issued: ". . .to give the permittee a reasonable
period of time to complete construction of the modifications outlined in DER permit DC
06-21789, and for subsequent assessment of the discharge's effects on the receiving water.
The permit is short term in recognition of these intentions." (Emphasis supplied) (Exhibit 8)
It is therefore obvious to me, based on competent substantial evidence in the record which is undisputed by any other evidence introduced or considered, that Petitioner was notified that, in spite of issuance and extension of permits for secondary treatment, modifications of the plant to meet more stringent water quality-based effluent limits might be required. At the time these permits were issued, it would have been impossible for the Department to specify the exact limits required, because the limits were not determined pursuant to Section 17- 6.10, Florida Administrative Code, until May, 1980 (Exhibit 3). It was not until after the limits were determined that Petitioner applied for a permit to operate its plant at an increased capacity, but still at a secondary treatment level. Because the effluent limit was determined to be "no discharge" and because Petitioner's application was complete pursuant to Section 120.60, Florida Statutes, the Department proceeded to formulate final agency action.
Section 403.088(1), Florida Statutes, prohibits the discharge of any waste which "by itself or in combination with the waste of other sources, reduces the quality of the receiving waters below the classification established for them". In this case, uncontradicted evidence in the record and the hearing officer's findings reveal that the North New River Canal is below standards (the classification) for dissolved oxygen, and that the subject sewage treatment plant, under present and requested treatment levels, would discharge concentrations of oxygen demanding substances which contribute to the receiving water body's continuing failure to meet standards, mainly for dissolved oxygen. It Is also clear that an increase in discharge, as requested in the permit application, would continue if not increase this negative impact.
While it may be that this continuing failure to meet standards in the receiving waters is not due to Petitioner's plant discharge alone, but is rather the result of that discharge in combination with the discharges from other sources, as implied by the hearing officer in finding of fact number eight, this distinction does not change my ultimate conclusions. In an earlier Department case, the subject hearing officer recognized the applicability of Section
403.088 standards not only to the water quality impacts of "isolated" discharges, but also to the combined effects of several discharges into a receiving water body. See City of Orlando, Florida v. State of Florida, Department of Environmental Regulation, DOAH Case No. 76-1573, Department Final Order dated July 8, 1977. In fact, the hearing officer found in that case that
"It is of course incumbent upon the Petitioner to establish eligibility for the desired permit. Rule 17-4.07 requires the applicant to provide Respondent with 'reasonable assurances' that its proposed activity -- in this case, continued operation of a sewage treatment plant -- will not cause pollution in contravention of law. Further, Rule 17-4.24 specifically requires Respondent to deny the application if it finds that the proposed discharge will reduce the quality of the receiving waters below the classification established for them. This rule must be read in conjunction with the basic statute, Section 403.088(1), which prohibits discharge of wastes into waters which by itself or in combination with waste of other sources, reduces the quality of the receiving waters below the established classification."
Indeed, the facts of that case show that the receiving waters in question did not meet the dissolved oxygen levels required of Class III waters, as in this case. The hearing officer there concluded that while an operation permit should be denied, the permit applicant was still free to apply for a temporary operation permit, under Section 403.088(4), Florida Statutes.
For the reasons stated above, Respondent's exceptions number three and four are accepted and the hearing officer's conclusions of law number four, five and six are rejected.
For the reasons stated in the immediately preceding paragraph, Respondent's exception number five is likewise accepted.
I take note that in its Exceptions To Recommended Order And Memorandum, Respondent's counsel suggests that given the hearing officer's findings and the record in this case, it appears that Petitioner might be eligible for a temporary operation permit issued pursuant to Section 403.088(4), Florida Statutes (a suggestion consistent with the hearing officer's recommendation in the City of Orlando case cited above), or site specific alternative criteria issued pursuant to Sections 17-3.031 or 17-3.061(3), Florida Administrative Code, which would enable the Department to issue an operation permit, as requested. Unfortunately, those matters were not properly before the hearing officer as part of the instant permit application, nor are they properly before me at this time. Accordingly, this Final Order is entered without prejudice to Petitioner's right to seek relief and obtain operation or temporary operation permits pursuant to these provisions.
CONCLUSION
Having considered the Recommended Order, including the findings of fact, conclusions of law and the recommendation of the hearing officer, as well as the exceptions and memorandum filed by Respondent and the reply filed by Petitioner, and having reviewed the entire record in this case, including exhibits, it is ORDERED:
The hearing officer's findings of fact are adopted in toto, along with the minor additions made in my rulings on exceptions above, as the findings of fact of this agency.
The hearing officer's conclusions of law number one and two are adopted.
The hearing officer's remaining conclusions of law are rejected and the discussion of the applicable law contained above substituted as the conclusions of law of this agency in this matter.
The hearing officer's recommendation is rejected, for the reasons outlined above. Accordingly, petitioner's request for an operation permit is DENIED.
This denial is without prejudice to Petitioner's right to seek appropriate relief under the temporary operation permit provisions of Section 403.088(4), Florida Statutes, or an operation permit with site specific alternative criteria issued pursuant to Sections 17-3.03 or 17-3.061(3), Florida Administrative Code.
DONE AND ENTERED this 10th day of July, 1981, in Tallahassee, Florida.
STATE OF FLORIDA, DEPARTMENT OF ENVIRONMENTAL REGULATION
Terry Cole/for VICTORIA J. TSCHINKEL
Secretary
Twin Towers Office Building 2600 Blair Stone Road Tallahassee, Florida 32301
FILING AND ACKNOWLEDGMENT
FILED, on this date, pursuant to S120.52 (9), Florida Statutes, with the designated Department Clerk, receipt of which is
hereby acknowledged.
7/10/81
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished by United States Mail to Thomas C. Oldham, Hearing Officer, Division of Administrative Hearings, The Oakland Building, 2009 Apalachee Parkway, Tallahassee, Florida 32301 and to Martin S. Friedman, Esquire, Myers, Kaplan, Levinson, Kenin and Richards, P.A., 1020 E. Lafayette Street, Tallahassee, Florida 32301 this 10th day of July, 1981.
SEGUNDO J. FERNANDEZ
Deputy General Counsel
State of Florida, Department of Environmental Regulation Twin Towers Office Building 2600 Blair Stone Road Tallahassee, Florida 32301
Telephone: (904) 488-9730
| Issue Date | Proceedings |
|---|---|
| Jul. 14, 1981 | Final Order filed. |
| May 27, 1981 | Recommended Order sent out. CASE CLOSED. |
| Issue Date | Document | Summary |
|---|---|---|
| Jul. 10, 1981 | Agency Final Order | |
| May 27, 1981 | Recommended Order | Allow Petitioner to discharge treated water into substandard waterway with caveat the effluent must be improved in quality. |
JAMES R. REGAN vs. DEPARTMENT OF ENVIRONMENTAL REGULATION, 81-000080 (1981)
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J. P. WARD vs. OKALOOSA COUNTY AND DEPARTMENT OF ENVIRONMENTAL REGULATION, 81-000080 (1981)
FREDDIE PRESSLEY vs. DEPARTMENT OF ENVIRONMENTAL REGULATION, 81-000080 (1981)
