United States
             Environmental Protection
             Office of Municipal
             Pollution Controi(WHH546)
October 1987' .
Report on the Use of
Wetlands for Municipal
Wastewater Treatment
and Disposal
                                         Printed on Recycled Paper


                                   EPA 430/09-88-005
                Submitted  to:

                 Prepared by:

                OFFICE OF WATER

                 October,  1987



Tills document was prepared for the Office of Water by Robert K.
BastIan,  Peter Shanaghan, and Brian Thompson In the Office of
Municipal Pollution Control with considerable assistance and support
from the following Individuals:  Caren Rothstein and Karen Tarnpw,  ,
Office of Water; David Davis, John Meagher., Suzanne Schwartz, and
others. Office of Wetlands Protection; Steve Bugbee, Office of Water
Enforcement and Permits; Nandan Sen&eremath and Gall Cooper,; Office
of General Counsel.                                            /

Tlxls document contains a rec^iil5'Agency report which, reviews
knowledge^ of the -use of botfc ^natural  and constructed wetlands- for
municipal wastewater treatment -and disposal, including tlie extent" and
circumstances of'this practice,  and summarizes  the regulatory Issues
Involved in response to 'a request  toy  the Honorable Quentin ;H\ v '-     p
Burdlcfc, Chairman of the U.S. Senate  Committee  on Environment and
Public Works.  Additional information and  guidance concerning
projects in which, wetlands play a  role in  the treatment and disposal
of municipal wastewater effluent more recently  issued by the Office
of Water to supplement the report  is  provided as an attachment to the
original report.

  I.   introduction	... ..	. ...	   1
 II.   Wetland Treatment Systems	   2
     A.   Natural Wetlands	   2
     B.   Constructed Wetlands 	   3
III.   Number and Types of Wetland Treatment Systems  .....   5
 IV.   Standards and Permit Requirements 	   8
     A.   Requirements for Discharge 	   8
        1.  MiT^™"™ Technology Requirements  	   8
     • '  2.  Water Quality Standards 	   9
     B.    Section 404 Permit Requirements	   11
  V.  EPA Approach		   12
     A.    Natural Wetlands  	   12
     B.   Constructed Wetlands	   12
     C.   Construction. Grant&.,Eligibility,-. ........	   13
  VI.  Repommendations		14
      A.   Actions  by the Congress	   14
      B.   Actions  by EPA	 .   14

   Attachment A.   Excerpts from "Freshwater Wetlands for
      Wastewater Management Environmental Assessment Handbook"
   Attachment B.   Some Recent Detailed Technical References
   Attachment C.   Letters to/from Senator Burdlck
   Attachment D.  September 20, 1988 Guidance to Supplement
      the October 1987 Burdick Report


    wetlands were once regarded as wasted uland.   It ^is, now
clear that they'provide Irreplaceable-benefits to, people; and •   ^
thS envi?onmenti  Wetlands'provide .natural flood prevention
and pollutant filtering systems and  contribute significantly ,  .
to ground water recharge.  Many sport fish, migratory
waterfowl, furbearers, and other  valuable wildlife live and
breed in wetlands.                                ;;          , , ,:;..-

    Freshwater, brackish, and-saltwater-wetlands, have   ..'.;/,  .....
inadvertently served as  natural water .treatment.systems^for
centuries.   Because of their transitional position in the
landscape between terrestrial and aquatic ecosystems, some
we^andfhave been subjected to wastewater discharges from
both municipal  and industrial sources.  Wetlands have also
received agricultural and surface mine, runoff,  irrigation
return flows,  urban stormwater,discharges,  leachjtes;,^and      -
other  sources  of water pollution.  The impacts  of  such.     ,     ;
discharges  on 'different wetlands has been quite variable.

     it is only in the past  few decades,,  however, -that  th%  ^-'
 claimed use of wetlands for meeting  wastewater treatment and
 othSr watK 'quality objectives has  been  studied and   	
 ?mSlLerited.  The -Iunc£ional .role pf wetlands in water quality
 impediments, has been identified,asVacompelling-argumen^ for   ^
 wetland preservation  and in, some cases r for their creation, ^A ,,, f:
 wetiana pire        Q^er      iagfc. ^..      nave  found evidence -r,
                     . •-  •'. '.•.•. i__l:	• -a _:'  _••' w 3 J.W '• IgVel 'O f r-T=l"'0'1" <*«» t"'.J&¥~!
 ^-----.pn^  -However,  concern, has also", been   .
 SS SSiile  harmful  effects p'f' toxic materials and^pathogenj
 in wastewaters,  and the long-term degradation of wetlands^due
 to the  additioAal nutrient hydraulic  loadings from wastewater
 discharges.   -,,  .••-•.   , .    •_•-..• -. .-  .-..:;;-.^  •--;•. .  ,  •-  .  ., .  ,...<,..

     Due to these concerns, as well'a's other  factors,  there has
 been  considerable interest in, us ing .constructed  (or     •<•••,.•>•
 artificial)  wetlands for wastewater treatment.  Constructed;
 wetlands are engineered systems that  have  been designed: and
  constructed to employ wetland type vegetation to-assist
  treating wastewater  in a more controlled environment than
  occurs in natural wetlands.   ^   '         '        -          • "•

      This report  reviews current knowledge  of the use of^both
  natural and  constructed wetlands  for municipal wast.eyater
  ??eStment and disposal.   TUB extent  and circumstances of this.
  Dracticeare reviewed  and summaries  of the regulatory issues
  involved, as  well as  EPA policies  are presented.  <• \ -  >   ,>;,,;,
                                - 1 -

                             TREATMENT SYSTEMS
A.  Natural Wetlands

    The teirm "wetlands" is a relatively .new expression,
encompassing what for years have simply been referred to as
marshes, swamps,'bogs, and so on.  Wetlands occur in a wide,
?Sge of physical settings at the  interface of terrestrial and
aquatic ecosystems.

    Wetlands are defined by Federal  regulatory agencies as
those areas that are  inundated  or  saturated by surface or
ground water at a frequency and duration  sufficient to
support, and that under normal  circumstances do  support, a
prevaleAce of vegetation typically adapted for  life  in   . .,
laturated soil  conditions.  They ate vegetated  systems,
ranging  from marshes  to forested swamps.   Wetlands occur  in  a
wide range of natural settings  and encompass a  diversity  of.
ecosystem types, while exhibiting a wide  array  of primary
 functions and values  such as  providing wildlife habitat,
around water recharge, flood control, water  quality
 enhancement  and recreational  opportunities (See Attachment A).
 For regulatory  purposes almost all natural wetlands are
 considered waters  of-the United States.

     Wetlands appear"to perform to at least some degree all of
 the biochemical transformation of wastewater constituents that
 take place in conventional wastewater treatment plants, in
 septic tanks and their, drain fields, and  in other forms of
 land treatment.  The submerged and  emergent plants-, their
 associated microorganisms, and  the  wetland so^s- are  _ .    .
 responsible for the;majority of the treatment effected by,the
 wetland.  (See list of some recent  detailed references in
 Attachment B.)

     The use of natural wetland treatment systems is  limited  to
 providing further  treatment of secondary effluent to meet
  downstream water quality  standards.  (Any applicable ^ter
  quality standards  for the wetland itself must  be met near the
  point  of discharge to the wetland.)  Usually the objective  is
  to reduce the  concentration  of Biochemical  Oxygen Demand
  (BOD),  Suspended  Solids  (SS);: and the nutrients nitrogen and
  phosphorus  in  secondary  effluent.  Most  natural wetlands can
  effectively remove BOD,  SS and nitrogen from secondary
  effluents.   However, phosphorus.. removal capability varies
  among individual  wetlands and depends largely on site-specific
  factors,  especially soil type.                        ,

      Other pollutants of concern  in secondary effluent may also
  be removed, in a natural wetland.   Removal and die-off rates of
  pathogens from wastewater discharged  into wetlands have been

                                - 2 -

reported as* very high 'in, some-places1, but "highly variable .in c
others.   However, the variable numbers of coliform bacteria-,;-£>
and salmonella (which are "routinely lised as^indicators of
human pathogens but are also produced by wildlife), greatay    ,, .
complicate moriitoring for human pathogens in-wetlands which
receive wastewater discharges.  The levels of many of the      ,
inorganic arid organic compounds present in wastewater are
greatly reduced as they pass through wetlands.  At least
initially heavy metals appear to be mainly removed by sorption
to wetland soils and sediments, although  long-term studies
have not been conducted to determine exactly how  they are
cycled or lost.  It appears that many of  the organic compounds
that are removed by wetlands are degraded.by microbial
activity associated with the wetlands soil, sediment and
vegetation.             ..,-....  .....           -•         «  t

    While it appears  that many  wetlands have some, capacity for
improving water  quality of wastewater,  runoff,  or industrial
discharges, some wetlands are clearly not appropriate  for
continuous  day-in/day-out use as  a part  of  a wastewater
disposal or treatment system.   The potential  for altering the
biotic  communities' of natural wetlands  when including them in
wastewater  management is  of  great concern to  EPA and groups
 interested  in preserving  existing wetlands.               ,

     The major' costs and energy requirements associated with a
 natural wetlands treatment system, are involved .with
 preapplicatioh treatment, land costs,  minor earthwork, and the
 wastewater distribution system.  In addition:to-the n
uses.  This can be done relatively simply where wastewater
treatment is the only function sought.  They,,can be built in
natural scsttings; or they may lentail extensive earthmbving,
construction of impermeable barriers, or building of
containment such as tanks or trenches.  Wetland vegetation has
been established and maintained on substrates ranging from
gravel or mine spoils to clay or peat,  some systems are set
up to recycle at least a portion of the treated wastewater by
recharge of the underlying ground .water.  Others act as flow-
through systems, discharging the final effluent to surface
waters.      '

    Constructed wetlands have diverse applications and are
found across the country and around the world.  They can be
designed to accomplish a variety of treatment objectives.  The
influent to various constructed wetlands treatment systems
ranges from raw wastewater to secondary effluent.

    The advantages of constructed wetlands  are many, and
include:   flexibility in siteilocation; optimized size for
anticipated waste  load; potential to  treat  more wastewater in
a smaller  area than is possible with  natural wetlands; less
rigorous preapplication treatment,  and no alteration of
natural wetlands.  Concurrently,  there are.  some disadvantages
to using constructed wetlands for treatment relative to
natural systems.   The cost  and -availability of  suitable  land
•and the construction costs  for grading  the  site are  added
expenses.   In  addition,  the sites are unavailable  for  use in ,
treatment  during the construction period, and reduced
performance can generally be expected during the  period  in  .
which vegetation becomes  established.  Other possible
constraints are the  costs of plant  biomass  harvesting  and
disposal  if required and the fact that  artificial wetlands,
 like their natural counterparts,  provide breeding habitat for
nuisance, insects or disease vectors, and may generate odors.
When toxics are a significant component of  the municipal
 wastewater to be treated, adequate pretreatment should_be.
 provided to avoid problems of bioaccumulation in wildlife
  (particularly waterfowl)  attracted to the site.

    Under appropriate conditions,' both natural and constructed
treatment systems have achieved higheremoval« efficiencies for,;
BOD, suspended solids, nutrients, heavy metals/trace organic
compounds as well as natural die-off, of pathogens from     '  ,
wastewater.  More that 25 wetland-^related municipal wastewater
treatment projects have been at least partially funded by EPA
construction grants funds, involving projects  in essentially ^ "
all regions of the country (see Figure I which depicts the   "
locations of many of the wetland-related treatment projects in
the U.S. and Canada).  However, rather than a  single concept  '•
for the involvement of wetlands-in~ wastewater  treatment, there
are a number of approaches whereby wastewater  and wetlands
have or could be effectively combined as a part of water-
quality management .projects.  These include:

           .,'-'.                          ' "        -.'••-
    natural Wetlands for Wastevater Disposal  .... In many
areas natural wetlands serve as the receiving  water for
permitted discharges of treated wastewater.  More than  400
such discharges exist in the southeastern States alone, while
there are another  100 or more  in the Great Lakes States.  In
addition much of the runoff from both rural and urban areas ;an
many parts of the  country receives considerable "treatment1' as
it  passes through  natural wetlands prior to entry into  ground
water,  estuaries,  streams and  lakes.  However, any use  of
natural wetlands for^treatment purposes requires (extensive
pre-project review to ensure that,the wetland ecosystem; is  not
unacceptably altered.                   "          ;  ;;  *   -••-•'•
or Creation
                                                        In- the"
 more arid parts  of  the country, .it is not uncommon for    :  . -  .
 wastewater  effluents to serve as the water supply used to  .
 create>  maintain,  restore,  or enhance wetlands.   In some cases
 wastewater  effluent is;the  sole  or major water source for
 valuable wetland habitat (e.g.,  "the Mt;  View Sanitary District,
 project  near Martinez CA, built  as an alternative to a
 deepwater outfall  into Suisun Bay; the Bitter Lake National
 Wildlife Refuge  near Roswell, NM, which depends on the Roswell
 sewage treatment plant effluent  as its main supply of
 freshwater).  Considerable  opportunity may exist for treating
 and utilizing wastewater effluents, drainage water, runoff, or
 other sources as a water supply to enhance or restore existing
 wetlands that are  stressed due to lack of an adequate water
 supply or  other  reasons.  However, some serious environmental
 problems have occurred in such situations where proper
 management  practices were not observed (e,g., the Kesterson
 National Wildlife  Refuge in Merced County, California, which
 received extremely high levels of selenium in the agricultural
 drainage water from the western San Joaquin Valley).

                              - 5 *•

water quality.                                ;
                                                .... The use
„*                      .
 less chance for causing adverse environmental effects,   in
 systems nave ben built  to  simulate natural wetlands,
               (.g.. Aicata.: CA; Incline village. HV;
 Harriman,, NY)
 motoring and evaluation of many of these sites.

I. Location of Some Known Wetland Wastewater Treatment Projects.
                                   -  7 -


A.  Requirements for Discharge

    The Clean Water Act, together with EPA's implementing
regulations, governs the discharge of wastewater  to waters of
the United States, including any wetlands which are considered
waters of the United States (40 CFR Part 122.2).  Municipal
discharges to those wetlands which are considered waters of
the United States, must meet minimum  technology requirements
and conform with State water quality  standards.   The exact
level of treatment required for any discharge  is  specified in
its National Pollutant Discharge Elimination System  (NPDES)
Permit issued by EPA or an authorized State.

    1.  Minimum Technology Requirements

          All municipal wastewater treatment systems,  except
    'for certain  ocean discharges and aquaculture  systems,must
    .achieve the  degree of effluent reduction attainable
    through the  application of secondary treatment prior to
    discharge to waters of the U.S.  (including almost  all
    natural wetlands).  Secondary treatment is most  often
    defined as attaining an average  effluent quality for both
    five-day Biochemical Oxygen Demand  (BOD5)  and Suspended
    Solids  (SS)  of 30 milligrams per liter Tmg/L) in a period
    of  30 consecutive days,-an average  effluent quality of 45
   •' mg/L'for the same pollutants  in  a period of 7 consecutive
    days  and  85  percent removal, of the  same pollutants in  a
    period  of  30 consecutive  days.   Although this definition
     is  based upon the performance  of a large number of
    properly  qperating  wastewater  treatment plants of various
     types,  EPA's secondary treatment regulation does not
     require the use'bf  any of these  specific technologies  to
     achieve the effluent limits,  only that the limits be

           The Clean Water Act and its implementing regulations
     do provide for relaxing some aspects of the  definition of
     secondary treatment under certain circumstances.  The
     most notable case is when Waste  stabilization Ponds (WSP)
     and Trickling Filters (TF): are used as the principal
     biological treatment process.  When this  is  so, the
     facility may be considered as achieving treatment
     equivalent to secondary treatment if  it achieves average
     SOU, and SS of'45 mg/L during a  30 day period,  average
     BOD§ and SS of 65 mg/L during a  7 day period, and 65%
     removal of  these pollutants.  Where WSP's are used the
     State may further adjust upward  the  SS limit for
    , treatment equivalent to secondary treatment  to  reflect
     the effluent  quality achieved within  a specific
     geographical  area.  This provision  allows differing
     geographical/climatic conditions which effect WSP
     performance to be  taJcen  into account.

                              „, Q _

      Permit limits for WSP's or TF's may only be adjusted
where violation of water quality standards will not
result.  In attempting to understand how an average SS
level in excess of 45 mg/L could be considered
equivalent to secondary treatment  (average SS of 30
mg/L) it is important to remember  that the SS
contained in WSP effluent are -largely the result of
the biological treatment process occurring in the pond
and are quite different from the SS in raw wastewater.
WSP effluent SS are, for the most  part, algae, which
occur widely in natural water bodies.  Thus, depending
upon the water body, a WSP effluent high  in SS may not
pose an undue burden.

2.  Water Quality  Standards

       In addition  to meeting minimum  technology
requirements, discharges to waters of the United
States must comply with applicable State  water quality
standards.  Very  few States have established  separate
water  quality  standards for wetlands  and  EPA  has not
yet developed water quality criteria  specifically for
wetlands.   An  internal EPA task force recently
concluded that  the lack of EPA water  quality  criteria
 for wetlands  and the  resulting absence of State  water
quality standards for  wetlands is one of  the  most
 serious impediments  to a  consistent national  policy on
 use of wetlands for wastewater treatment  or discharge.

       EPA is now beginning to look into the feasibility of
 developing water quality criteria and numerical or
 narrative- biological., quality^maintenance,criteria for
 wetlands, which would serve as the basis for ,,.<.'      >
 establishing separate State water quality standards
 for wetlands.   Some activity has  been initiated in
 this area.  For example,  EPA is hosting a scientific
 workshop later this year to help  prepare a research
 plan for developing water quality standards for
 wetlands.  This workshop will explore the feasibility
 of a two-fold approach to water quality  standards for
 wetlands,  addressing both chemical water quality and
 biological integrity of these ecosystems.  Chemical
 water quality standards would aim to  protect wetlands
 and the fish and  wildlife that  use them  from water
 pollution.  The objective of  standards for biological
 integrity  would be to address  impacts from activities
 that  physically  alter wetlands  so that ecosystem processes
 are  impaired  (e.g., discharges  of dredge and fill

        A related project  is being planned to  improve  State
 programs  under Section 401 of the Clean  Water Act  for
 Certifying that discharges  into wetlands and other

                           -  9 -

aquatic sites comply with existing water quality
standards.  The programs of states that have
particularly effective or innovative approaches to
their responsibilities under Section 401 will be
reviewed in detail.  Subsequently, other States will
be encouraged to adopt and build upon the best
approaches that are identified.  Both efforts have
significant potential for improving the level of
protection for wetlands habitat.  However, the
availability of funding for the actual development of
water quality standards for wetlands is contingent
upon budget decisions for FY 89 and beyond.

      In lieu of separate wetland standards some States
have simply applied water quality standards, for
adjacent streams or lakes to wetlands.  These water
quality standards are often inappropriate for wetlands
because wetlands are vastly different ecosystems.
Research has shown that wetlands can effectively
provide additional removal of.pollutants from
secondarily treated wastewater prior to its entering a
stream or  lake without significant  impact on the
wetland itself.  Thus many wetlands can, without harm,
accept higher  loadings of nutrients and SS from   .  ,
municipal  wastewater sthan can many.. streams or  lakes.
This, of course, assumes that contaminated materials
are not contained  in the SS at  levels that would be
harmful to fish and wildlife, or would pose threats" to
human health.  Water quality  standards  for wetlands
need to reflect these concerns.

     There are a number of cases where  advanced polishing
by natural wetlands has been  recognized in State-issued
NPDES permits.  In these cases  the  permit calls• >for the
wastewater entering the wetland to  meet  secondary
treatment  limits and-the water  quality  standards  for  the
wetland while  the  water  flowing out of  the wetland into an
adjacent  stream must meet  more  stringent  water quality
standards  for  the  adjacent stream,      ,     ;

    ,; In some cases permits contain seasonal  variations in
discharge requirements.   For  example,  a higher level  of
nutrient  removal may  be  required during the  summer than
during the winter.  Natural  wetlands  may be  well  suited to
meeting such seasonal  requirements since their peak
pollutant removal  and transformation  capacity occurs
 during the summer  growing season.

      The  State of  Florida, in 1986, established standards
 for the use  of wetlands for treatment.   These standards
 are considerably more complex than conventional water
 quality .standards.  Florida's wetland standards include
 design criteria and regulation at three levels:   effluent
 limits;  standards to be met within the treatment wetland;

                         -  10  -

    and standards for discharge from the wetland to downstream
    water bodies.  The Florida standards contain traditional
    physical and chemical parameters as well new "wetland
    biological quality"  standards.   Thus the standards
    recognize and allow wetland treatment. capacity to be used
    while at the same time protecting the unique values and
    functions of wetlands and the water quality standards of
    the receiving waters.

         However, Florida is the only state having such
    standards at present.  In most cases the NPDES permitting
    authority must review the use of wetlands systems to
    achieve downstream water quality standards on a case-by-
    case basis.  This situation has led to different findings
    in similar situations where .questions .have- been raised
    concerning the use of natural wetlands for providing
    advanced treatment of secondary effluents.

B.  Section 404 Permit Requirement

    Generally proposals to use natural wetlands for wastewater
treatment involve some alteration of the wetland, such as
building dikes.  It is generally necessary to obtain a permit
for the discharge of dredged or .fill material from the Army
Corps of Engineers (or appropriate State Agency) under Section
404 of the Clean Water Act before such construction would be

    Regulations established by EPA under Section 404(b)(l) are
primarily intended to protect existing wetland values.  The
Corps of State review for the Section 404 permit will require
determination that the impacts of dredged or  fill material on
the wetland do not constitute significant degradation; that .,
there are no practicable-, environmentaliy'-preferable
alternatives; that unavoidable  impacts have been minimized;  •
and that unavoidable  impacts are mitigated through practicable
compensatory actions.  An additional determination by the
Corps also requires that the proposed wetland alteration is  in
the public interest.  The proposed modification will also
require a review under the National Environmental Policy Act
(NEPA), consideration of other  applicable Federal laws and
executive orders  (such as the Endangered Species Act), and
any applicable State  laws governing wetland  filling or other
                           - 11 -

                       V. EPA APPROACH
A.  Natural Wetlands

    EPA regulates wastewater discharges to those natural
wetlands which are considered waters of the United States
through the Clean Water Act NPDES permit program.  Municipal
discharges to such wetlands must meet minimum 'technology-based
requirements and conform with applicable State water quality
standards.  In the current absence of separate water quality
criteria or State water quality standards  for wetlands, EPA
considers a conservative case-by-case approach, often  combined
with pilot testing, to be most appropriate for evaluating  the
use of natural wetlands for municipal wastewater  discharge and
treatment.                ,                     "'

    A recent  internal EPA Task Force concluded that .natural
wetlands  should  continue to be viewed primarily  as protected
water bodies,  and that,  in the absence  of  water  quality
criteria  for  wetlands,  it  is  not  possible  to broadly identify
conditions where they could be  safely regarded  as part of  the
 "treatment  system".  Therefore,  the agency continues to review
 requests  for  treatment  systems  involving discharges  (treated
 to secondary- or  equivalent  to secondary levels)  to natural
 wetlands  using a conservative,  case-by-case approach.   For
 example,  EFA's Region IV (in Atlanta) has prepared a      _
 Freshwater Wetlands for Wastewater Management Handbook (EPA
•904/9-85-135) which provides guidance for such case-by-case
 evaluation.   -

 B.  Constructed Wetlands

     •EPA encourages -the "use' of-constructed (artificial) wetland
 systems through the innovative and  alternative technology
 provisions of its construction grants program.  Constructed
 wetlcind treatment systems can often be an environmentally
 acceptable, cost-effective, treatment option particularly for
 small communities.  This 'technology also  has the advantage of
 expanding wetland-type habitats, although these  systems rarely
 achieve the  same  level of biological complexity  as  natural
 wetlands systems, and their  ecological values are
  correspondingly'"less than for natural  systems:

      in general,  current EPA  regulatory and construction grants
  policies create fewer problems  for consideration of
  constructed  wetlands as a treatment option.   In those cases
  where  €he constructed wetlands  systems are designed,  built  and
  operated for the purpose of  wastewater treatment,  the
  constructed  wetlands  treatment  systems are not  considered
  waters of  the U.S.  (40  CFR Part 122.2).   As a result some
  constructed  wetland systems  are currently.being used to treat
  primary effluents to meet  secondary or advanced treatment
  requirements in a number of locations across the.country.
  Operational controls can be designed to closely regulate flow,
                               .'  "
                              -  12  -

application rate, and detention time to meet desired seasonal
variations in operation and treatment needs.  Plant species
can be selected and utilized on various bases such as nutrient
uptake efficiency, ease of culturing or harvesting, value as
biomass,  etc.

C.  Construction Grants Eligibility

    As with other -land treatment systems, land purchases for
constructed wetland treatment systems are clearly eligible for
funding under the construction grants program.  The
eligibility of natural wetlands for funding, however, remains
a more complicated issue due to the case-^by-case approach
which is necessary in determining eligibility.  Still, under
certain limited circumstances natural wetlands-may be
considered eligible for grant funding.  Such projects must
involve the wetlands in meeting more stringent downstream
water quality requirements, and must be found to be both cost-
effective and environmentally sound.  In addition, the
facility must have a current NPDES permit that reflects
minimum treatment technology and State water quality
requirements into and out of the wetlands.  As noted above,
these proposals must be reviewed on a case-by-case basis and
may require a Section 404 permit.
                             - 13 -

                    VT.  RECOMMENDATIONS

A.  Action by tne Congress

    We do not believe that any legislative changes are
necessary at this time to provide additional authorities
concerning wetlands for wastewater treatment and disposal.

B.  Action by EPA

    EPA  is talcing a number of actions which may help  resolve
the questions regarding the  extent to which natural wetlands
may be used to help treat municipal  wastewat-er.-. The  most
important of these is EPA's  exploration of water quality
criteria for wetlands.  The  first step  is to  examine  the
current  scientific data and  possible approaches, and  to
develop  a research plan to  fill in the  missing information.   A
kev  component to developing, appropriate criteria is  additional
 information on  the  response  of  wetland ecosystems  to  various
 tvpes and  rates of  discharges.   In addition,  EPA will
 encourage  and (when funds are available)  participate in
 monitoring  current  wetland wastewater treatment sites to^
 determine  the fate  of toxics and their impact on wildlife
 uling tnl  system; and the differences in ecological functions
 of constructed versus natural wetlands.  Currently, use of
 constructed, rather than, natural, wetlands is generally
 preferred by EPA when projects for Wastewater treatment are
                               - 14 -




                   September 1985
               CTA Environmental, Inc.

      Gannett Fleming Corddry and Carpenter, Inc.



 .     .  Wetlands  have many important roles  in, the  maintenance  of
    ecosystems and watersheds.  The terms  functipn and value are
    often used together to describe or characterize a wetland. Wet-
    land  functions  are  the inherent processes  or  capabilities  of
    wetlands.  Most of the values of wetlands  relate directly to these
    functions: for example, the'water quality enhancement func-
    tions of wetlands are one of  their great  values.  Some wetland
   . values,  such as  visual-cultural  values, are somewhat inde-
    pendent  of  wetland  function.   Typically the  functions  and
    values of wetlands are interrelated.

        The following 16 functions Tanrf-values of wetlands summarized
    in Table 2-2 are widely accepted.
    Table 2-2. Primary Wetland Functions and Values


    •r •'•••••   • .      '  •   '  . •;    .       .,.%...•".-,
    Hydrology /Meteorology
       Flood control
       Saltwater intrusion control
       Grouridwater supply
    r,   Microclimate regulation ,

    Water Quality

       Water quality enhancement

    Ecology              ;

       Habitat for threatened and endangered species
    ,   Waterfowl breeding and habitat
       Wildlife habitat
       Freshwater fish (and some marine species)
       Aquatic productivity
       Nutrient/material cycling

    Cnlttrral Resources             ,         T
      1 - .. 'TV' .                 ...
       Harvest of natural products
       Recreation and aesthetics

2.3.1 Geomorphology

        Erosion Control.  Located between  watercourses and  up-
     lands,  wetlands help  protect uplands from  erosion.  Wetland
     vegetation can reduce shoreline erosion in several ways,  includ-
     ing:  (1) increasing stability of the sediment through binding
     with its  roots, (2) dampening waves through friction and (3)
     reducing current  velocity through  friction.   These processes
     reduce turbidity and  thereby  improve water quality.  Rich,
     alluvial  soils,  which build up in wetlands,  also contribute  to

        V/etland vegetation  has been successfully  planted to reduce
     erosion along U.S. waters. While most wetland plants need calm
     or sheltered water for establishment r they  will effectively con-
     trol erosion once established.  Willows, aiders,  ashes,  cotton-
     woods,  poplars, maples  and elms are particularly good stabil-
     izers.  Successful  emergent plants  in freshwater areas  include
     reed canary grass, reed,  cattail,  and bulrushes.  Sediment
     deposition in freshwater wetlands also acts to decrease siltation
     in downstream systems such as estuaries.  ,
2.3.2 .Hydrology/Meteorology                      ,

        Flood Control.   Wetlands  temporarily store flood waters and
     thus reduce downstream losses of life and property.  Since de-
     struction from floods in the U.S. runs'from $3 to $4 billion each
     year, the  damage-diminishing  function of wetlands is vitally
     important.                                  ,   ,

        Rather than  having all flood waters flowing rapidly down-
     stream and  destroying private  property and crops, wetlands
     slow the flow of water, store it  for some time  and slowly release
     stored waters downstream. ,.In  this ..way, .flood .peaks of tribu-
     tary streams are  desynchronized and  all flood  waters do not
     reach  the mainstem  river at the  same  time., This  function
     becomes  more important in urban areas, where development has
     increased the  rate  and volume of surface  water runoff and the
     potential for flood damage (U.S. FWS 1984).

        Saltwater Intrusion'Control.  The flow of freshwater through
     wetlands creates groundwater pressure that prevents saltwater
     from invading  public  water supplies.   This  is  important only
     where freshwater  wetlands interface with-an  estuarine environ-
     ment (U.S. FWS 1984).      ,.'••••       '  '        f

        Groandwater Supply.  There is  considerable debate over the
     role  of wetlands in ground water recharge.   Recharge potential
    "of wetlands  varies according to numerous  factors,  including
     wetland  type,  geographic location,  season,   soil' type,  water
     .table location  and precipitation.   Depressional; wetlands  like
     cypress domes in Florida and prairie potholes in the Dakotas may

    contribute  to  groundwater recharge.  Floodplain wetlands also
    may do this through overbank water storage (U.S. FWS 1984).
    As a result, the protection of this function could be a factor in
    addressing current and future water supply problems.

       Microclimate regulation.  Although less is known  about the
    role  of wetlands  in  regulating climatic  conditions than  about
    many other wetlands functions, available data indicate this may
    be a  significant  wetland  function.  In  some  cases  wetlands
    appear to modify air temperatures,  affect localized precipitation
    and   maintain  global atmospheric  stability.   Most  available
    information concerning the modification of air temperatures and
    regional precipitation  is pertinent for Florida wetlands,  which
    comprise such a large  percentage (30%) of the state.  It has been
    suggested  that thunderstorm activity could  decrease in Florida
    as  a  result  of  draining  wetlands, thereby modifying  water
    budgets (EPA 1983).

2.3.3  Water Quality

        Water  Quality Enhancement.  Wetlands act as natural water
    purification mechanisms.  They remove silt, and filter out and
    absorb nutrients  and many pollutants such  as waterborne toxic

        Water  quality enhancement is  dependent on wetlands  soils,
     vegetation, flow  through-time, water  depth and  related  pro-
     cefses. Many communities throughout the United State?, includ-
     ing  more than 400 communities in the Southeast, have benefitted
     from  the  capabilities of wetlands to enhance water quality by
     incorporating   wetlands  into   their  wastewater  management
     systems (EPA 1983).

 2.3.4 Ecology   	

         Habitat for Threatened and Endangered Species.  More than
     20 percent of  all the plant and animal species on^ the Federal
     Endangered or Threatened Species list  are dependent on wet-
     lands  for food  and/or  habitat.   Fifteen  wetlands  dependent
     species on the federal list are found only in the Southeast.  Addi-
     tionally,  each  state has a list of protected species and many of
     these in  each  state are wetlands dependent:  Alabama - 25
     species; Florida - 31 species; Georgia - 6 species; Kentucky -14
     species;  Mississippi  -.14 species; North Carolina - 8'  species,
     South Carolina - 13 species; Tennessee - 13  species (EPA 1983).
         Waterfowl Breeding and Habitat.  Over 12 million ducks nest
      and breed annually in northern U.S. wetlands. This area, when
      combined  with  similar  habitats  in  the  Canadian .Prairies,
      accounts for 60  to 70  percent of the continent's breeding duck
      population.  Waterfowl banded in North Dakota have been recov-
      ered in 46 states,  10 Canadian provinces and territories, and t*

 other countries.  Some 2.5 jmillion of the 3 million mallards in the
 Mississippi Fly way and. nearly 100 percent of our 4 million wood
 ducks  spend  the  winter I in flooded bottomland  forests and
 marshlands throughout the South.
                    '     'i      .       ,.  . ,
    Bottomland forested wetlands of the South are  primary win-
 tering grounds for North American waterfowl areas, as  well as
 important  breeding  areas for wood ducks,  herons,  egrets and
 white ibises.  Even  wild turkeys  nest in bottomland hardwood
 forests.  Other common  bird  inhabitants  include  barred owls,
 downy and redbellied woodpeckers,  cardinals,  pine  warblers,
 wood  peewees,  yellowthroats and wood thrushes  (U.S. FWS

    Wildlife Habitat.   Wetlands provide  food and shelter for a
 great variety of furbearing animals and other kinds of wildlife.
 Louisiana marshes alone yield an annual fur harvest worth $10 to
.$15 million (U.S. FWS 1984);

    "fuskrats,  beavers and nutria are the most common fur bear-
 ers dependent on wetlands.  Muskrats are the most wide ranging
 of  the  three, inhabiting; both  coastal  and  inland  marshes
 throughout the country. :In contrast, beavers  tend  to  be re-
 stricted to  inland  wetlands,  with  nutria limited  to  coastal
 wetlands  of  the South.   Other  wetland-utilizing  furbearers
 include otter,  mink, raccoon, skunk and  weasels.  Other mam-
 mals also frequent wetlands, such as marsh and swamp rabbits,
 numerous mice, bog lemmings and shrews.  Larger mammals may
 also be observed. Black bears  find refuge and food in shrub
 wetlands in South  Carolina, j for example (U.S. FWS 1984).

    Turtles, snakes,  reptiles  and  amphibians  are all  common
 residents., of .wetlands -in., the .Southeast..., Alligators. range from
 Florida to North Carolina to !the north, and Texas to  the west.

    Freshwater Fiah.  Many iof the 4.5 million acres of open water
 areas found in inland  wetlands are ideal habitat for such  sought
 after species  as  bass,  catfish,  pike,  bluegill,  sunfish, and

    Most freshwater fishes can be considered wetland-dependent
 because:   (1)  many  species feed  in wetlands  or upon wet-
 land-produced food;  (2)  many fishes use wetlands as nursery
 grounds and (3) almost all important recreational fishes spawn  in
 the aquatic portions of wetlands.  Bottomland hardwood forests
 of  the South serve as nursery and feeding grounds for young
 warmouth and largemouth bass, while adult bass feed and spawn
 fh  these, wetlands.   River  swamps in Georgia  produce  1,300
 pounds of fish per acre.  The bottomlands of the Altamaha River
 in  Georgia  are spawning grounds  for the hickory shad and
 blueback herring.  Southern  bottomland forested wetlands are
 also the  home of the edible red swamp crayfish, which burrow

   down to the water table when Hooding waters recede (U.S. FWS

       Aquatic Productivity.  Wetlands are among the most produc-
   tive ecosystems in the  world.  Wetland  plants are particularly
   efficient converters of  solar energy.  Through photosynthesis,
   plants  convert sunlight  into  plant  material  or biomass  and
   produce oxygen as a by-product.  This  biomass  serves as food
   for a  multitude of animals,  both  aquatic and terrestrial.  For
   example,  many waterfowl depend heavily  on seeds  of  marsh
   plants, while muskrat eat cattail tubers and young shoots.

       Generally,  direct grazing of wetland plants is limited,  so the
   vegetation's major food, value is produced when it dies and frag-
   ments,  forming detritus.  This detritus forms the base of an
   aquatic food web which supports higher consumers.   Wetlands
    can be  regarded  as  the farmlands of the aquatic environment,
    producing  great  volumes  of food annually.  The majority  of
    non-marine aquatic animals depend, either  directly or indirect-
    ly, on this food source (U.S. FWS 1984).

       Nutrient and  Material Cycling.  Implicit  in the  discussion of
    several other wetland functions and  values is the importance of
    wetlands  to downstream ecosystems.  Wetlands that are hydro-
    loglcally connected to surface  waters often serve as an import-
    ant source of nutrients and organic matter.  Wetlands serve to
    break down organic matter, such as dead vegetation,  and to
    cycle  nutrients  so these  materials are  useable in downstream
    ecosystems. This function is  essential  to many  freshwater and
    marine organisms in downstream waters  and  estuaries  (Day

2.3.5.  Cultural Reaiodvees •"-«-•

        Harvest of Natural  Products.  A  variety of natural products
    are produced in freshwater wetlands,  including timber,  fish,
     water fowl, pelts and  peat. Wetland grasses are hayed in  many
     places  for winter livestock feed.  During  other seasons,  live-
     stock graze directly in wetlands across  the country.  These and
     other products are  harvested  by man for his use and provide a
    livelihood for many people. The standing value alone of south-
     ern  wetland forests is  $8 billion.  Conversion  of  bottomland
     forests to agricultural  fields (e.g., soybeans) in the  Mississippi
     Delta has reduced these wetlands by 75 percent.

        Wetlands also support fish and wildlife for man's  use.  Com-
     mercial  fishermen  and  trappers  make  a  living  ^.™£
     resources.  Many commercial species (catfish, carp and buffalo
     fish) depend on freshwater wetlands for  habitat, nutrients or
     organic matter»   Furs  from beaver, muskrat, mink,  nutria and
     otter yielded roughly $35.5  million in 1976.   Louisiana is  the
     largest  fur-producing state,  and  nearly  all  furs  come  from
      wetland animals.

    Many  wetlands produce peat, a resource  used mainly for
horticulture and  agriculture in  the United States. Peat raining,
however,  destroys wetland|s and their  many associated values
(U.S. FWS 1984).           i
                          .1             '
    Recreation and Aesthetics.  Many recreational activities take
place in and around wetlands.  Hunting and fishing are popular
sports. Waterfowl hunting is a major activity in wetlands,  and
bJg game hunting is also important locally.

    Other recreation in  wetlands is  largely non-consumptive:
hiking, nature observation and  photography, swimming, boating
and ice-skating.  Many  people simply  enjoy  the beauty  and
sounds of nature aiid spend their leisure time walking or boating
in  or near  wetlands observing plant  and animal  life.   The
aesthetic value of wetlands [is extremely difficult to  evaluate or
place a dollar value upon. Nonetheless,  it is very important. In
1980 alone, 28.8  million  people  (17 percent of the U.S. popula-
tion) took special trips to observe, photograph or feed wildlife.
    Figure 2-3 graphically depicts many of the major wetlands
functions .and values. These functions and values are important
to the use of wetlands  for.  waste water management for  several
reasons.  First and foremost, th«y provide the basis for water
quality standards and  th4  nphdegradation  of existing uses
Existing uses, as represented by the list of beneficial wetlanu
functions and values, must  be clearly identified and protected
by a waste water management plan incorporating wetlands.

    While few wetlands  will  exhibit all 16 attribu.tes_liated,,.lhe.-
existing values must  be identified for each prospective site.  Not
only do these functions  and values serve as a basis for regula-
tory considerations,  they also impact site screening, engineering
design, operation and monitoring  of a prospective  wetlands  dis-
charge.   Wastewater management  objectives must be considered
in light of environmental protection.  The Handbook emphasizes
the importance of  wetlands'  functions and values in each of the
three  major  subject areas I addressed:  institutional,  scientific
and engineering considerations.

  Figure 2-3.  Relationship Between Wetland Functions and Values.
   Periodic Inundation      Wetland Functions      Ecological Services
                                                               Fooa and naoitat
                                                               Food cnam support

                                                               FleodMiuc rMueuon
                                                                ater aualitv
                                                               > Shor«uw •ration control
SOURCE 0".c. at r«mcw«T *IM>HMI>II



U.S. EPA. September 1985.  Freshwater Wetlands for Wastewater
Management Environmental Assessment Handbook.  EPA 904/9-85-
135.  U.S.  EPA Region IV, Atlanta. GA.  474pp.

U.S. EPA, 1983.'  The Effects of Wastewater Treatment
Facilities on Wetlands in the Midwest.  Technical Report.  EPA
905/3-83-002.  U.S. EPA Region V, Chicago, IL.  264pp.

U.S. EPA/U.S FtWL Service, 1984.  The Ecological Impacts of
Wastewater on Wetlands, An Annotated Bibliography.  EPA 905/3-
84-002.  300pp.

Bastian. R.K. and J. Benforado, In Press.  Water Quality
Functions of Wetlands:  Natural and Manmade  System.   IN:   D.
Hook  (ed) Proceedings of the International symposium  on
Ecology  and Management of Wetlands.  Croom Helm LTD,
Beckenham, Kent.UK

Brinson, M.M. and F.R. Westall, 1983.   Application of
Wastewater to Wetlands.  Rpt. No. 5, Water Research inst.,
Univ.  of North Carolina, Raleigh, NC.   26pp.

Godfrey, P.J.,  E.R. Kaynor,  S.  Pelczarski and J. Bentorado
 (eds.).  1985.   Ecological Considerations  in  Wetlands  Treatment
of Municipal Wastewaters.  Van  Nostrand Reinhold Co., New
York.  N.Y.   473pp.

Hammer,  D.E.  and R.H. Kadlec,  1983.   Design  Principles for
Wetland  Treatment  Systems.   EPA 600/2-83-026.  243pp.

Horwitz, E.L.,  1978.  Our Nation's  Wetlands, An Interagency
Task Force Report  Coordinated by the President's  council on
 Environmental Quality.   CPO, Washington,  D.c.  70pp.

 Kadlec,  R.H.,  June 1987. Using Wetlands  to  Mitigate the Water
 Quality of sewage  Effluent.   IN:   Nix, S.J.  and P.E.  Black
 (eds).  Proceedings of  the  Symposium on Monitoring,  Modeling,
 and Mediating Water Quality, AWRA,  Bethesda, MD.   pp. 415-427.

 Kadlec,  R.H. and J.A. Kadlec, 1979.  Wetlands and-Water
 Quality.  IN:  Wetland Functions and Valuesi , The State4Of,Our
 Understanding.  AWRA, Bethesda, MD.  pp.436-456.

 Mudroch, A. and J.A.  Capobianco, 1979.  Effects of Treated
 Effluent on a Natural Marsh.  JWPCF 51<9):2243-2256.

 Nichols, D.S., 1983.   Capacity of Natural Wetlands to Remove
 Nutrients from Wastewater.'  JWPCF "55(5):495-505.

 Nixon,  S.W. and* V. Lee, In  Press.  Wetlands  and Water Quality:
 A Regional Review  of Recent Research  in the  U.S. on  the  Role
 of Freshwater  and  Saltwater Wetlands  as Sources, Sinks,  and
 Transformers  of N, P and Heavy Metals.  Prepared by  the  Univ.
 of Rhode  Island for  the U.S. Army Corps of  Engineers, WES,
 Vicksburg, MS.

 Reddy,  K.R.  and W.H.  Smith  (eds.:,  1987.  Ao^iatic Plants tor
 Water Treatment and  Resource Recovery.  Magnolia Press,  Inc.,
 Orlando,  FL.   1032pp.

  Zedler, J.B.  and  M.E.  Kentula, 1985.   Wetlands Research Plan,
 Novemoer  1985.  U.S. EPA ERL-Corvallis, OR.   118pp.


                          WASHINGTON. D.C  2:460

                               NOV   2I98T
                                                     THE ADMINISTRATOR
Honorable Quentin N.  Burdlck
Chairman, Committee on  Environment
  and Public Works
United States Senate
Washington, O.C.  20510

Dear Mr. Chairman:

    I an pleased to forward to you  our report on  the use of wetlands for
municipal wastewater treatment and  disposal,  prepared 1n response to your
May 4, 1987 request.

    The  report  indicates that there are a number of approaches whereby
wastewater and  natural  or constructed wetlands may be effectively combined as
a part of water quality management projects.   Almost all natural wetlands are
waters of the United States and discharges to these wetlands must comply with
Clean Water Act requirements.  Such wetlands may be used tc provide nutrient
removal  or high level effluent polishing for municipal  wastewater discharges.
On  the  other  hand some constructed wetlands are designed and built for the
express  purpose of treating municipal wastewater.  Such wetlands are not
waters  of the United States and may be used to comply with the minimum
 techno 1 ogy  requirements of the Clean Water Act.  Land purchases for
 constructed wetlands treatment systems,  and under certain*limited    i
 circumstances natural  wetlands, are eligible  for funding under the
 construction grants  program.

     We do not recommend any  legislative  changes  at this time.   However,  the
 Agency is taking actions which may help  resolve  the questions regarding the
 circumstances under which natural  wetlands may be used  to help treat municipal

      Please do  not hesitate to contact me if you have any  further questions.

                    *-•• » *4»»'»'tf»-» ^ A

                                     tVIHBJIMPff a»0 PU«Ue
                                 "ASMNOTCM.ecas 104171

                                    May 4, 1987
Hz. Lee Thomas
Environmental Protection Agency         •  .     ,
401 K St S.W.                             -..                      ,
Washington, D.C.  20460                                          '

Dear Mr. Thomas:

I  racantly  learned  that  the  Environmental Protection Agency has
.considered  the  option o£ using wetland areas for disposal or
traataent qf municipal savage.

1  have  a particular interest in plans to use wetland areas for
disposal of sewage  from the City of Devils Lake  in my hone State
oto North Dakota., While I understand that the wetlands disposal
cctun  is  no -longer under active consideration  in tne case of the
City off Devils  Lake, I am interested in, and concerned about, the
general question of the use of wetland areas for sewage disposal
or treatment.                                         '

 I would like you to prepare a report on  the. general, subject  of
 use of wetlands for municipal sewage disposal  and discharge  and
 related activities.
                                      '.   •    '  .' '   , ' • r
 Your report should provide  a  full  assessment  ofi the extent and
 circumstances of this practice,  summarize the legal issues
 involved, review the  Agency's policy with regasd to this.
 practice, and provide recommendations of actions which .should be
 taken by the EPA or  the Congress to address this issue.
 Please provide  this  report to my office within  thirty days.  I
 you are.unable  to  prepare this report within this  time period,
 plisase contact Mr. BoblDavison  (224-7139) or Mr. Jeff Peterson c
  the  Environment and Public Works Committee staff • (224-7069) .  '

  Thank  you  for  your "cooperation  in  this  important siattar.  .
          f -    * jf*  • - '••-•
  Quantir. M. 3urdicl<


                     WASHINGTON, D.C.  20460
                                     2 0 1988
SUBJECTi/TJse of Wetlands for Municipal Wastewater Treatment
FROM:     Rebecca W. Hanmer, Acting Assistant Administrator
            for Water (WH-556)

TO:       Water Division Directors, Regions  I -  X.

    Tills memorandum provides information and guidance concerning
projects in which wetlands play a role in the treatment and
disposal of municipal wastewater effluent.  Attached you will find
OW Guidance to Supplement tla.e October 1987 Burdlck "Report on the
Use of Wetlands for Municipal Wastewater Treatment: and Dlpsosal",
as well as a copy of the Burdick report.

    The report was prepared by the Office of Water at the request
of Senator Quentin N. Bur dick. Chairman of the  Senate Committee on
Environment and Public Works, to attempt to  provide a full
assessment of the extent and circumstances of the use of wetlands
for municipal wastewater treatment and disposal, a summary of the
legal issues Involved, a review  of pertinent agency . policy ,  and
recommendations of actions which need to be  taken by EPA or the
Congress to address this issue.  The  supplemental guidance was
developed to summarize a- number -of  internal- agency -issues
addressed during preparation of  the  report,  and to provide some
general guidance.

     The following  are the  Headquarters  contacts on  this matter who
had the lead in their respective offices for preparation  and
 review of  the  report.  Please feel free to contact  them if you
 have any questions:   Karen Tarnow (382-5686) on my  immediate
 staff,  Bob Bastian (382-7378) in OMPC,  John Meagher (382-5043) in
 OWF, Steve Bugbee (475-9539) in OWEF, Nandan Kenkeremath
 (382-7700) in OGC.


 cc:  CG Branch Chiefs
      Water Permits /Compliance Branch Chiefs
      Section 404 Coordinators
      Regional Counsels



                     WASHINGTON, D.C. 20460
                               *       :            '     OFFICE or
                        September 20, 1988             .WATER

SUBJECT:  OW Guidance to Supplement the October  1987 Burdick
          "Report on the Use of Wetlands  for  Municipal Wastewater
          Treatment and Disposal"

When Are yfl-ftT~n*g Wa-fcerg of 1:he United  States?

    The definition of waters of the U.S.'  under 40 CFR Part 122.2
includes most wetlands.  Wetlands which are adjacent to other
waters  of the United States (other than wetlands) are
automatically waters of the U.S.  In  addition, other wetlands
(often  called "isolated wetlands") are  waters of the U.S. if their
use, degradation or destruction would or could affect interstate
or foreign  commerce.  Some examples  of  an adequate interstate
commerce connection are if the wetlands are or could'be used by
interstate  or foreign travelers  for  recreational or other
purposes, contain  or could contain fish or shellfish which could
be sold in  interstate or  foreign commerce, or are or could be used
for  industrial  purposes by industries in interstate commerce.  In
addition. Isolated wetlands  that are or could be utilized by
migratory waterfowl  are regulated as waters of the U.S.

     As  discussed below, constructed wetlands which are designed,
built -and  operated as wastewater treatment systems are in  general
excluded from the  definition of  "waters of the U.S."  (see  40 CFR
 122.2,  exclusion for waste* treatment'. systems). • Pending  additional
 rulemaking, the decisions of whether these waste treatment  systems
 are  considered waters of  the U.S. must be made on a  case-by-case
 basis.                                            /.,'''

 jfre*-n Can TTa-biriral Wfttf1 *-"rt*i H* XlnaA T?rrr K-p-Pl-nati-fc  PQl±sh±pg?

     Almost all natural wetlands  are  waters  of the U.S. '  Municipal
 discharges to those wetlands which are considered waters of the
 U.S. are,  therefore, subject; to  the  provisions  of the Clean Water
 Act and must meet minimum technology requirements and conform with
 all applicable  State water quality standards including the "free
 froms" and other narrative standards.   Thus, nothing less than
 secondary effluent (or equivalent to secondary effluent where
 trickling  filters or waste stabilization ponds are  used), may be
 discharged.to  a natural wetland., If State water quality standards
 applicable to  the wetland require more stringent,,or additional

effluent limitations \  they, too must be met at the point of
discharge to the wetland.  However, tinder circumstances where
secondary (or equivalent to secondary) effluent limitations are
met and all State water quality standards applicable to the
wetland are also met,  If more stringent water quality criteria
apply to a downstream surface water body, natural wetlands can be
used to provide additional assimilation of conventional and
nonconventlonal pollutants.  In limited situations natural wetland
treatment systems could provide certain communities, especially
small communities, with alternatives to more costly and complex
advanced treatment plants.  However, effluent found to contain
potentially harmful levels of toxins should not be discharged to
natural wetlands or any constructed wetlands serving habitat
functions.  .                                    .

gase—By-Ca,se Evaluation of Proposed Natural Wetland Treatment
Systems                                                .

    Some natural wetlands can provide  advanced effluent polishing
for conventional and nonconventlonal pollutants on a seasonal If
not year-round basis without damage to their ecological functions
and values.  The Office of water  and several Regional Offices have
been looting into many of the technical  and administrative issues
associated'with such practices!for several years.  However,  in the
absence  of appropriate water quality criteria  for wetlands it Is
impossible to broadly identify  the conditions  under which they can
safely function as  part  of the  treatment system,  mien such
practices are allowed, a comprehensive monitoring system  must be
in place.  At a minimum,  the monitoring  program  should be designed
to help  avoid harmful accumulations of toxic materials present in
trace amounts in  the wastewater and to detect  changes  in  the plant
and  animal  communities due to  changes  in water flow and
characteristics caused by the  wastewater discharge.

     Therefore, proposals for  treatment systems involving  discharge
 of secondary (or  equivalent to secondary) effluent  to  natural
wetlands that  are to provide  additional  treatment to  the  effluent
to meet  higher downstream treatment requirements for  conventional
 and nonconventlonal pollutants should be reviewed by  the  Regions
 on a case-by-case basis.  'The Region's wetlands  protection staff
 should be consulted ,on all such cases.  Region IV's Freshwater
 Wetlands for Wastewater Management Handbook (EPA 904/9-85-135;
 September 1985)  provides one  source of guidance  for such
 case-by-case evaluations.

     Proposals to use  natural wetlands for effluent  polishing may
 Involve some alteration of'the" wetland,  such as  building dikes.
 Such construction activity may require a Section 404 permit,
 review under the National Environmental Policy Act, consideration
 of other applicable Federal laws and executive orders (such as the
 Endangered Species Act), and any applicable State laws governing
 wetland filling or other alteration.


      .  Wetlands Treatment Systems NPDBS Permit Recnii-rements

    All  effluent discharges Into wetlands which, are waters of the
U.S. require a National Pollutant Discharge Elimination System
(NPDES)  permit.  Municipal NPDES permits must contain minimum
technology-based limits and conform with all applicable State
water quality standards including the "free froms" and other        '
narrative standards.  In those cases where a natural wetland will
be used either on a seasonal or year-round'basis  for effluent
polishing, the NPDES permit must contain secondary (or equivalent
to secondary) effluent limits consistent with 40  CFR Part  133,
plus any additional limits and/or monitoring requirements
necessary to protect the wetlands and achieve water quality
standards for the wetlands, adjacent and downstream waters.  These
water quality-based limits must be implemented in the NPDES permit
at the point of discharge into the wetlands  (i.e., at
end-of-pipe).  In addition to meeting wate-a?  quality standards  in
the wetlands, the end-of-pipe water quality-based limits necessary
to achieve adjacent and downstream water quality standards may be
established based on the degree of effluent  "polishing" provided
by the wetlands.

    There are  a number of cases where effluent  polishing by
natural wetlands has been recognized in State-issued  NPDES
permits.  See,  for  example, the attached case summaries  for  the
Eoughton  Lake, HI and Cannon Beach, OR  projects.       .

Const Tti ot Ion Grants Eligibility of Natural Wetlands     ; .

    Under certain limited circumstances the acquisition of a
natural wetland which will serve  to polish municipal wastewater
. effluent  may be eligible for  construction grant funding.A
determination  as to eligibility  can be  made only after a thorough
case-by-case evaluation  has shown that  the natural wetland
 alternative is both cost effective and. environmentally sound.   The,
 latter  determination must be  made in consultation .with ..the *-•-.,
 Region's  wetland protection staff.   In the case of Houghton Lake,
 MI. pond treated secondary effluent  is applied to state-owned
 wetlands  on a  seasonal basis  to  achieve phosphorus and ammonia
 removal while  the  wetland is  maintained open and acceptable for
 public  access.  On the other hand,  at Cannon Beach,  OR,  natural
 wetlands, which were purchased as a construction grant eligible
 component,  receive secondary pond effluent on a seasonal basis to
 meet seasonal advanced treatment requirements for BOD and SS prior
 to discharge to the receiving stream.

     Such funding is only available where the management of the
 wetlands is recognized in a NPDES permit as the method for
 achieving*downstream water standards.  This management may occur
 beyond the discharge point, which would be the discharge to the
 wetlands itself.  In addition, the NPDES permit must require that
 discharges into the wetlands must meet secondary (or equivalent to
 secondary)' treatment limits and'any limits based on water quality
 standards for the wetlands before funding can be made available.

     Natural wetlands treatment systems can  be  funded as either
 innovative  or alternative technology under  provisions of  the  .
 Innovative  and Alternative Technology  program,  depending  upon the
 experience  with the type of wetland system to  be used.

     Can Cmagfearnctetl Tte-falanAs Be tTsed For Wastewater Treatment?

    tfhen assessing constructed wetlands for municipal wastewater
treatment a distinction should be made between those constructed
wetlands deisigned, built and operated as wastewater treatment
systems, and those constructed wetlands designed, built and
operated to provide many of the functions and values of natural
wetlands (e.g., wildlife habitat) in addition to providing
wastewater treatment.  This is necessary in order to help
determine which wetlands are waters of the U*S. and, therefore,
the degree of wastewater treatment that is necessary prior to
placing the wastewater into the constructed wet land unit for
further treatment.  Generally, man-made bodies of water which are
designed, built and operated as i wastewater treatment systems are
not waters of the U.S.

flnTlfitfTOn1sad- Waetewa-bor Treatment Wetlands

    Constructed wastewater treatment wetlands  can be designed,
built and operated as municipal j wastewater treatment systems .
See, for example, the attached case  summary  for  the Gustine, CA
project.  These are highly engineered  systems  designed to  maximize
the treatment  of  municipal wastewater.   Any  other functions they
may provide must  be 'incidental -fco  the  treatment  of wastewater.
Through the Innovative  and Alternative technology provisions  of
the construction  grants program1, EPA has been encouraging  the  use
of constructed wastewater treatment  wetlands.   The construction
costs  for  these systems, including land acquisition,  have  been and
remain eligible for  up  to 75% construction grants funding.

     Constructed wastewater  treatment wetlands that are designed,  .
built ,  and operated as  wastewater treatment systems are generally
 not considered to be waters of the U.S.  Thus the restrictions
 which apply to natural wetlands do not generally apply to such
 constructed wastewater treatment wetlands.  Influent, to these
 constructed wastewater treatment wetlands may range from raw ,
 wastewater to secondary effluent or better.             ,

             Multiple Use Wetlands
     There are many constructed wetlands which are designed, built
 and operated to provide, in addition to wastewater treatment,
 functions and values similar to those  provided by natural
 wetlands.  See, for example, the attached case summaries for the
 Martinez, CA; Arcata, CA; and Incline  Village,  NV projects.

     The Martinez project involves wetlands which provide only
 incidental treatment of secondary effluent from a regulatory
 point-of-view because they were constructed for the  benefit of
 wildlife habitat, as an alternative  to  a more expensive deepwater
 Bay outfall and diffuser.  On the other hand, the Arcata project
 involves wetlands  constructed to provide  year-round  wastewater
 treatment followed by a wetland discharge, in lieu of a Bay


outfall and diffuser, through a pre-existing coastal wetland area
managed as a wildlife sanctuary to help enhance wildlife habitat
and overall Humboldt Bay area use.  Finally, the Incline Village
project involves wetlands designed for both effluent disposal into
a non-discharging wetland and wildlife habitat enhancement.

    Under certain circumstances such constructed multiple use
wetlands may be considered waters of the U.S. and as such would be
subject to the same protection and restrictions on use  as natural
wetlands.  This determination must be made  on a case-by-case
basis  and may consider factors such as the size and degree of
isolation of the constructed wetlands and other appropriate
factors   Where such constructed  multiple use wetlands  are found
to  function as waters of the U.S., municipal discharges to such
systems must be limited to  secondary or equivalent  to  secondary
effluents and any more stringent  «ffluent-requirements necessary
to  meet applicable  water quality  standards. The Region's wetlands
protection  staff should be  consulted on all such cases.

      Finally,  in some cases a municipal wastewater discharge may
 be the sole water  supply for a constructed multiple purpose
 wetland which becomes waters of the U.S.   As long  as the discharge
 to such a wetland continues, the wetland would continue to be
 considered waters  of the U.S.   However, aside from any contractual
 arrangements which may be entered into, a municipal discharger is
 not bound to supply water to the constructed wetland in
 perpetuity, even if the wetland achieves a high level  of
 ecological complexity.


                       CANNON BEACH,  OREGON
                           CASE SUMMARY

PROJECT TYPE:   Use of seasonally operated natural wetlands to upgrade
existing wastewater stabilization ponds treating the wastewater from a
permanent population of 1,200 which swells with, summer tourists1to
4,000.  The ponds provide secondary equivalent treatment (30 mg/1 BOD
and 50 mg/1 SS as monthly averages) prior to stream discharge from
November 1 through .April 30.   Prom May 1 through October,31, pond
effluent is further treated in the wetlands system to achieve monthly
average BOD and SS levels of 10 mg/1 prior to discharge to Ecola Creek.

GRANT FUNDING:  75%, including 10% I/A grant awarded in 1982; eligible
grant expenses included land acquisition costs.  The capital costs and
the operation and maintenance requirements were significantly lower
than those of any of the conventional alternatives.

PRE-EZISTING SITUATION:  Secondary treatment via three-cell
stabilization pond system, followed by chlorination and discharge into
a small tidal slough that drains into Ecola Creek.  System incapable
of meeting summer discharge requirements.

PROJECT EVOLUTION:  The project as originally  envisioned would  have
involved  creation  of a 15-acre constructed wetland within an existing
natural wetland  located adjacent to  the  secondary  treatment  ponds.
After receiving  an approved  Section  404  permit,  the  15  acre  site was
to be stripped of  its  existing vegetation and re-planted with
bullrush,  burreed,  and wapatto to  be harvested each  fall.   Concerns
raised by the U.S.  Fish tf  wildlife Service and other  resource agencies
forced reconsideration of  this proposal.  It  was determined that the
adverse effects  of redistributing  and destroying most of the wetland
 could not be  effectively mitigated by enhancement  of waterfowl and
 aquatic species  habitat,  and that,  if .possible, the existing wetland
 should be used in its natural condition.  The project as ultimately
 built uses the natural filtering capacity of the existing wetland
 vegetation.                                   t           *       ,

 PROJECT DESIGN:   Enclosure of approximately 15 acres of'existing  ,
 alder/spruce/sedge wetland by earthen dikes 12 feet wide and 0.5'to 7
 feet high (2.5 ft. average).  Detention time in the wetland is
 approximately 10 days;  Sections of the dike were intentionally made of
 gravel » cobbles to help alleviate the potential effects of flooding
 by allowing flood water from the nearby stream to flow through the
 treatment site to downstream areas.                .

 NPDES PERMIT:  Specifies seasonal discharge limitations of  10 mg/1  BOD
 and  SS as monthly averages at the point of the wetland discharge to the
 creek for the period  May 1 to October 31; and specifies .limitations at
 the  point of the  secondary treatment ponds' discharge to the creek  for
 the  period November 1 to April 30.

 MONITORING:  Conducted on the quality of  lagoon influent, lagoon
 effluent (at Outfall  *1), wetland influent, wetland  effluent (at
 Outfall  #2),  and  wetland background (in diversion ditch upgradient  of
 wastewater introduction).         ......

                     EOUGHTON LAKE, MICHIGAN
                           CASE SUMMARY

PROJECT TYPE:   Upgrade of aerated ponds treating the wastewater from a
seasonally variable population, averaging approximately 8,000, by
establishment  of a seasonally operated natural wetlands wastewater
treatment/discharge system.  The ponds provide secondary treatment as
well as storage during the non-irrigation season.  Unchlorinated
secondary pond effluent is applied to the Porter Ranch peat lands of
the Houghton Lake Wildlife Research Area from approximately May 15 to
September IS.   The project is required to achieve year-around monthly
averages of 30 mg/1 BOD, 4 mg/1 CBOD, 20 mg/1 SS, and 0.5 mg/1 Total P,
as well as a requirement of 0.5 mg/1 NE3-N  (as N) from Hay 16 to
October 15 for its two points of surface water discharge to Bear Creek
and Dead Horse Creek which flow into the Huskegon River.

GRANT FUNDING:  75% grant awarded  in 1977;  no grant  funds for land ,
acquisition Involved since the wetlands are State-owned and their use
for the wastewater project is authorized through a special use permit
issued by the Wildlife Division, Department of Natural Resources,
State of Michigan.  The  capital costs and the operation and maintenance
requirements of the wetland  system were significantly lower than those
of any available  alternative.

PRE-EXISTING SITUATION:   Individual household septic tanks with leach
field drainage entering  Houghton Lake.  Secondary treatment via aerated
ponds alone was incapable of meeting advanced treatment/discharge
requirements.  Discharge to  Great  Lakes watershed required phosphorus
removal.                         ,

PROJECT:  EVOLUTION:   The  wetlands  system was developed as  a more
cost-effective  alternative to expanding existing seepage  beds and
upland irrigation system for disposal  of  secondary  effluent  while
providing advanced ..treatment.   Research  and pilot  scale testing
provided background data; full scale (1.1 MGD design)  system was
 constructed Jind placed in operation in 1978.

 PROJECT DESIGN:   Pond treated secondary effluent is distributed over a
 16-week period each year across the width of the 1,500 acre
 sedge-willow/leatherleaf-bog birch peatland at a rate of about 1 MGD
 (not to exceed 2.5 MGD) through a series of 100 small gated openings
 in a 3,200 ft.  irrigation pipeline system mounted oh a wooded walkway
 across the wetland which is maintained by the wastewater authority.

 NPDES PERMIT:   Specifies seasonal (May 16 to October 15) ammonia
 nitrogen and fecal collfprm limits and year-round BOD, CBOD, SS,  and
 Total P requirements for the wetland discharges to  the creeks and
 compliance jwith requirements of the DNR Wildlife Division's special
 use permit for applying secpndary effluent  to the stateowned wetland -
 including maintaining the wetland open and acceptable for public
 access.    ,             , .    .

 MONITORING:  Conducted  on pond effluent (i.e.,  wetland influent),
 within wetland surface  & ground water quality,  wetland effluent
 discharges to Bear Creek and Dead Horse Creek,  and  downstream water
 quality; wetland hydrology,  soils, vegetation & wildlife.

                          MARTINEZ-, CALIFORNIA
         ;'                     CASE SUMMARY

PROJECT TYPE:   Establishment by tie Mt. View Sanitary District (MVSD)
of a constructed wetland system with chlorinated secondary effluent to
create a wetland environment for the benefit of wildlife and migratory
waterfowl that would also improve water cjuality and avoid the building
of an .expensive deepwater outfall into Suisun Bay.

GRANT FUNDING:  75% grant awarded in 1974; no grant funds involved In-
land acruisition since the wetland area that was created as an
alternative to a deepwater outfall was not considered  to be  an integral
part of the treatment system in terms of  the discharge permit issued  by
the Regional California Water Resources Control Board.   The  capital
costs and operations and maintenance reoTiirements  were significantly
lower than those of any available  alternatives—  :

developed in  1974 by MVSD as an  alternative  to constructing a 15-inch
diameter, 9,000  ft. long  pipeline  and outfall plus pumping facilities
 C1977 estimated  capital costs were $2.8 million  and .$130,000/yr OtfM)  or
 abandonment of the  existing treatment facilities and transport of    _
 untreated wastewater to a nearby community's treatment plant that would
 have to be  expanded to handle  the additional flow (1977 estimated costs
 to MVSD for conveyance  of the  wastewater and. expansion of the treatment
 facilities  were  $8.9 million;  MVSD's share of OffM costs were

 PROJECT DESIGN:   Conventional treatment proceeding the wetland involves
 comminution,  primary and secondary sedimentation, high rate trickling
 filtration and. effluent drlorination/deciilorination design to provide
 full secondary treatment of 1.6 MGD dry weather flow with a hydraulic
 capacity of 8 MGD wet weather flow.  The wetland  system was created  on
 20 3 acres jof, land that had. previously been a brackish water marsh,  but
 had been diked and drained early in the  1800's.   The  wetland was
 designed to provide maximum wildlife habitat while avoiding nuisance
 situations.  Habitat types include open  water mixed with stands  of
 emergent vegetation, islands, areas covered by floating vegetation,  and
 areas with cultivated wildlife  foods,  plus mud flats,  levees, and
 adjacent land With grasses, brush and  trees.  The total plant  flow
 passes  through  the wetland into Peyton Slough which discharges  into
  Suisun Bay.   When the project flow was 0.7 MGD there  was  a 10-day
  detention time  in the wetland;  land  usage was 17  acres/MGD.   At design
  capacity of  the treatment  plant,  there will be  a ,5-day detention time
  using 12 acres/MGD.

  NPDES PERMIT:  Specifies discharge limitations  of 30  mg/1 BOD and TSS
  as monthly .averages  at the discharge from the  high rate trickling
  filter following  chlorination/dechlorination.

  MONITORING:   In addition to standard monitoring of the effluent quality
  from the conventional portion of the treatment plant, MVSD keeps "^ack
  of the numbers and types of animals and plants supported by the wetland
  habitat, including numerous species of migratory waterfowl and

                       GUSTINE, CALIFORNIA
                           CASE SUMMARY

PROJECT TYPE:   Upgrade of existing stabilization ponds with, a design
capacity of 1  MGD treating a relatively high strength! wastewater
(ranging between 300 and 3,000 mg/1 BOD) from a small agricultural
town, including both, domestic and commercial sources - primarily from
dairy products industries.  The ponds serve as the pretreatment system
for the constructed wetland cells to meet monthly average BOD and TSS
levels of 30 mg/1 prior to discharge to Los Banos Creek which flows
into the San Joaquin River.       i

GRANT FUNDING:  75%, including 10% I/A grant and pilot testing awarded
in 1986; no grant funds for land acquisition involved since city-owned
land for the constructed wetland was available; a one-year pilot test
program (using a 0.4 ha constructed cattail marsh) was undertaken to
develop the final design criteria for the .system. . -The capital and  .
operations costs and energy requirements made the stabilization
pond/constructed wetlands system considerably more cost-effective than
any of the other alternatives considered.

PRE-EXISTING SITUATION:  Advanced primary treatment via  14
stabilization ponds; discharge of final effluent to adjacent duck
hunting clubs for land irrigation and wildlife was terminated by the
adjacent land owners.  Modified disposal operation involving discharge
into Los Banos Creek could not consistently comply with  secondary
effluent limitations.             ,

PROJECT DESIGN:  Effluent taken fr|om any of the  last  seven  of 11
stabilization ponds, operated  in series, is further treated in 24
constructed cattail marsh cells (each about 0.4  ha in size; 11.6 m
wide,  337 m long) which  are operated in parallel.  Effluent from each
cell flows over an adjustable  weir which controls  water  depth in the
cell.  Detention time in the constructed cattail marsh cells can be
controlled at 4 to  11 days.

NPDES  PERMIT:  Specifies discharge limitations  of 30  mg/1 BOD and TSS
as monthly averages at the discharge to the creek and that  the average
daily  discharge shall not exceed  1.0 MGD.

MONITORING:   Conducted on water quality of  influent,  effluent, and
receiving waters.

                           ARCATA,  CALIFORNIA
                              CASE SUMMARY

land acquisition because land was city-owned.

iS;«irttiiad £ or Arcata to be part of a $25 million Humboldt Bay

          oSam began operation in 1980 to evaluate this concept as^an
        tvl t5 complete^ phase out of the pond discharge from Humboldt
  ay    accordance with the State Water Resources Control Board s   Bays

 and Estuaries Policy."                                    '

                  Three 1-acre marshes were  constructed as  treatment
       wildlife populations in the Humboldt Bay area.   The Poshing
       ds are operated  at  a depth of  0.5 m providing a theoretical
  resdnle tLePof  about  189  days.  Th631"-acres- of disposal wetlands
  are Slrtted at  a  hydraulic  loading  of 0.07 USD/acre- as -recommended .for
  Sols?ll conservancy marshes  also help reduce BOD and ammonia l^els
  Shils achieving  some removal of phosphorus from the effluent leaving
  Si polishing  wetlands.   Cattail and bullrush dominate the PP^J^^
  marshes whili  a  wide diversity of  vegetation is present in the Arcata
  Marsh and Wildlife Sanctuary.

  NPDES PERMIT:   Preliminary project standards for BOD and  SS  Cor NR -

  would mle? these  standards.  The- disposal marshes  allowed the  *ȣ
  svStem to meet NPDES  requirements consistently,- in spite of  start . up
  Sobfems associated with the conventional portion of the P^  -"^^
  upgrades.  , Fecal  coliforms  were also greatly reduced by the  polishing
  marsh during, this period. ^    . :,>;/,;  _ _..,;     ^ ,  ..: ', . _•; '..'  ,.,% .,;  „. ;.
   MONITORING:   An integrated monitoring program deveiaPedMa^5;a|n
   Snot  Srofiram is being continued to monitor the. Arcata.. Marsh and
   5Sdlll I laSStuary aria for water quality, fish tissue' ^sid^kes
   vegetation patterns, and various special studies in conjunction with

   Humbolt State University.

                        INCLUDE VILLAGE, NEVADA
                              CASE SUMMARY

PROJECT TYPE:  Establishment by the Incline Village General  Improvement
District (IVGID) of a constructed, nondischarging wetland  system that
was designed for both, effluent disposal and wildlife habitat
enhancement.  The wetland system is part of a no-discharge wastewater
treatment/disposal-system initially being implemented as an  alternative
to providing nutrient removal prior to effluent discharges to  the
Carson River.  The wetland system was put into operation in  1984.  The
wastewa,ter treatment system serves a permanent population  of about
8,000 which swells seasonally to about 15,000, treating a  dry  weather
flow of approximately 1.6 MGD.  Effluent is used to irrigate pasture
from April  15 - October 1 until 1995 when the wetlands will  be the sole
disposal method and accomplish the goal of no direct discharge to the
Carson River.

GRANT FUNDING:  85%, including 10% I/A, grant, awarded in  1982; eligible
grant expenses included land acquisition costs.  The nondischarging
system, which initially combines seasonal pasture irrigation with
seasonal discharge to a constructed wetlands, was found to be  the most
cost effective alternative to nutrient removal for continued river
discharge during winter and to eventually achieve the goal of  no direct
discharge to the Carson River.

the north shore of Lake Tahoe, could  not discharge its effluent into
Lake Tahoe.  Consequently the District pumped its secondary  effluent
out of the  Lake Tahoe Basin via a  30  km pipeline and discharged to the
Carson River.  The effluent was used  to irrigate pasture  from April  15-
October  1 and discharged to the Carson River during the winter.  The
wetlands concept was developed inj response to an order  from  the Nevada
Division of Environmental Protection  prohibiting future direct
discharges  to the  Carson River.

PROJECT  DESIGN:  The 906-acre project site's created wetlands contains
four  cells  that can be operated  in series  or in parallel,  but  are
normally operated  in series.  They include  central  channels  and
islands.  Each  cell is divided  into four  subcells.   Separate outlets  to
the  cells allow for individual management  of each  cell as required.
Water depths  in the created wetlands  range  from  15  cm to  about 1 m.   An
 overflow area receives all effluent in excess  of the  percolation and
evapotranspiration capacity  of  the created wetlands.   Seasonal storage
 (which contains an area  of  open water with three islands  for wildlife
use)  is  provided to store excess effluent  during cool,  wet  seasons.
Habitat  enhancement includes  the creation of  entirely new permanent  and
 seasonal wetlands.  Bullrush and cattail are dominating the seasonal
 wetlands.   The  created wetlands also serve to  expand a nearby warm
 water (-spring fed) wetland  area used extensively  for  migratory

 NPDES PERMIT:   No  NPDES  permit  is currently required for this
1 non-discharging system,  although one may be obtained in the future to
 deal with any potential  releases.:

 MONITORING:  Very limited        i