EIS800856F
1
States
nerudl Prot «tion
Region V
230 South Dearborn
Chicago, Illinois 60604
July, 1980
jiv/ision
Environmental Final
Impact Statement
Alternative Waste
Treatment Systems
for Rural Lake Projects
Case Study Number 1
Crystal Lake Area
Sewage Disposal Authority
Benzie County, Michigan
nmm
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EPA-5-MI-3ENZIE-CRYSTAL LAKE-LA-80
FINAL ENVIRONMENTAL IMPACT STATEMENT
ALTERNATIVE WASTEWATER TREATMENT SYSTEMS FDR RURAL LAKE PROJECTS
CASE STUDY No. 1: CRYSTAL LAKE AREA SErtAGE DISPOSAL AUTHORITY
3ENZIE COUNTY, MICHIGAN
Prapared by the
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V, CHICAGO ILLINOIS
AND
WAPORA, INCORPORATED
WASHINGTON, D.C.
Approved by:
(John BcGuire
Regional Administrator
July 1980
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LIST OF PREPARERS
This Final Environmental Impact Statement was prepared by
WAPORA, Inc. under the guidance of Alfred Krause, EPA Region V
Project Officer. Mr. Gerald Peters, Jr. was WAPORA's Project
Manager. Mr. Ted Rockwell, EPA Region V, contributed to its
preparation.
Significant input to the Draft EIS was provided by
WAPORA employees and subcontractors, listed in that document.
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EXECUTIVE SUMMARY
Background
The 1979 Draft Environmental Impact Statement (DEIS) on Alternative Waste-
water Treatment for Rural Lake Projects, Crystal Lake area was concerned
with a number of issues raised by the November 1976 Facilities Plan. That
Plan proposed construction of a sewage collection system around all of
Crystal Lake, excepting Beulah and including Benzonia, with discharge to
a central wastewater treatment plant at Frankfort. The issues included:
the high cost of centralized collection and treatment (present worth costs
of $18.4 million) uncertain water quality impacts or improvements in
Crystal Lake, adverse economic impacts to area residents, and uncertain
induced growth and other secondary impacts.
To examine these issues USEPA used a variety of water quality modeling and
sensing techniques. These included a door-to-door sanitary survey of about
25% of shoreline systems, aerial photographic survey of surface malfunctions,
and a special septic leachate survey of the entire lake shoreline.
These studies found that although many on-site treatment systems did not
comply with the sanitary code, only a few were having any impact on the water
quality. Modeling indicated that no possible alternative would have a signi-
ficant effect on lake water quality or trophic status. All suggested that
the only major lake impact posed by the existing systems was the occasional
shoreline concentrations of Cladophora algae. It was also clear that there
were definitely water quality problems in Betsie Lake caused by the existing
primary treatment plants at Frankfort and Elberta.
A wide range of alternatives was developed and evaluated. These ranged from
highly centralized (the Facilities Plan Alternative and some variants) to
composite to largely decentralized (Limited Action and No-Action). All but
No-Action were similar in providing a single replacement plant to serve
Frankfort and Elberta. The composite alternatives proposed varying mixtures
of entirely on-site system maintenance and upgrading, partial sewering, and
cluster treatment systems for the Crystal Lake shoreline. Costs ranged
from $18.4 million for the Facilities Plan Alternative to $7.44 million for
the Limited Action Alternative which would only serve the Crystal Lake shore-
line by on-site maintenance and upgrading on cluster systems.
No-action was rejected for the Crystal Lake area because of localized shore-
line water quality and the existence of some conditions indicating long-term
treatment failure potential for the more poorly designed and installed systems.
The various alternatives' impacts differed greatly only in overall and local
costs. The EIS recommended the Limited Action Alternative, which offered
generally comparable water quality impacts at a much lower cost than any other
alternative.
Comments and Impacts
After the June 1979 publication of the Draft EIS, a Public Hearing was held
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on August 6, 1979 in Frankfort. Several hundred people attended, and a large
variety of cornments was received, most of them in writing. These comments
dealt with a number of subjects:
o questioning costs - particularly operation and maintenence (O&M)
and site-by-site study costs
o questioning general construction costs
o asking clarification of management proposals for the recommended
alternative
expressing concern about non-point sources of water quality input,
especially in view of the limited role of on-site treatment systems
Response;
After the close of the comment period USEPA responded in two different phases.
The first involved several additional studies of Crystal Lake and lasted about
four months. These studies include:
a. Survey of groundwater flow patterns around Crystal Lake to replace
the hypothetical flow estimations in the Draft.
b. A septic leachate survey of Cold Creek to detect possible nutrient
loading sources.
c. A detailed three dimensional survey (the "aquatic productivity study")
of five sample effluent plumes entering the lake, including a complete
survey of aquatic plants and algae.
The second phase was concerned with clarifying Federal, State and local adminis-
trative questions about formation of an on-site Wastewater Management District
to maintain the on-site treatment systems. This work produced the following
results:
o Michigan DNR assigned separate funding priorities to the Frankfort/
Elberta and Crystal Lake portions of the project. This would allow
each portion to precede at its own pace.
o Michigan DNR reviewed the NPDES permit standards for Betsie Lake
in light of new water quality data.
o USEPA developed a new regional standard for project needs documenta-
tion requirements and the relationship to the various steps of the
cost and complexity of work.
o Both Michigan DNR and USEPA worked on methods to reduce the cost and
complexity of detailed site work and to expedite processing of inno-
vative and alternative grant applications.
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o USEPA developed a variety of approaches to simplify easement access
requirements. This process, which is still going on, could altogether
eliminate the expense and complexity of easement acquisition.
USEPA also prepared detailed costing and a work plan for the site-by-site
survey for future Small Waste Flows District operation and maintenence, and
local costs associated with the No-Action alternative. We than combined the
full range of comments and developed responses or revisions of the draft.
The Final EIS
The result, this final EIS, is considerably shorter than the draft. Elements
which were discussed at considerable length in the draft are summarized here,
with emphasis on the new studies, response to comments and explanation of
management procedures and costs. This is consistent with The Council on
Environmental Quality's (CEQ) new National Environmental Policy Act (NEPA)
regulations that became effective after the draft was completed.
Results
The general effect of the new studies was to confirm the earlier ones. The
groundwater flow survey clarified the flow pattern projected in the draft.
The new aquatic productivity suggests that under extreme conditions the septic
tank systems might contribute the same 6.7 percent of lake phosphorus loads
projected in the DEIS. The Cold Creek survey suggested that almost all of the
dry-weather nutrient load was coming from the small tributary that parallels
US 31 above the retention basin.
Similarily, the various administrative changes and developments did not greatly
change information or assumptions. Revision of Betsie Lake effluent limita-
tions impact BOD and phosphorus loads by less than 2 percent. Revisions in
planning of the site-by-site work limit substantial increase in local costs.
Simplification of current easement requirements may reduce costs.
Impact of the new costing studies is also limited; operation and maintenence
were deliberately costed on a very conservative basis, as was the site-by-site
study work. Together these increased annual costs for the Limited Action
Alternative from $49 to $95 yearly for newly sewered areas of Crystal Lake
($82 without amortization of local capital cost shares). Twenty year present
worth costs increase from $7.44 to $7.88 million. This modest increase does
not come near changing the ranking of alternatives.
The comments, too, have produced some changes. The Village of Beulah does
not have any serious plans for expanding its treatment capacity, largely
eliminating any possibility for collection of the northeast shore. Other
comments have led to substantial expansion and clarification of sections of
the draft and appendices, such as a detailed description of the aerial photo-
survey techniques. None of these, however, substantially alters the nature
or ranking of alternatives.
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Recommendat ions
The recommended action, therefore, remains basically as it was in the Draft EIS.
o construction of connecting sewers and a new 0.33 mgd rotating
biological contractor plant to serve Frankfort and Elberta;
o sewer system evaluation surveys and rehabilitation of the existing
sewers in Frankfort and Elberta;
o design and implementation of a small waste flow district for the
remainder of the Study Area;
o site-specific environmental and engineering analyses of existing
on-site systems in the unsewered parts of the proposed service
area;
o repair and replacement of on-site systems as required; and
o cluster systems or other off-site treatment for portions of the
northeast and southeast shorelines.
Should the applicant wish to proceed with this action, we strongly recommend
that careful consideration be given to the sections on Management and
Implementation which discuss the nature and advantages of many of the choices
available. It is also important to begin to develop the management structure
that will operate in the future - so that citizens and local officials can
themeselves take part in the site-by-site design treatment choices. This will
allow all concerned to become familiar with the procedures which will be
needed to maintain and improve area water quality in the future.
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CONTENTS
Page
List of Preparers i
Executive Summary ii
List of Tables viii
List of Figures viii
I - PURPOSE OF AND NEED FOR ACTION
A. The Applicant's Facility Plan and Environmental Impact
Statement Issues 1
1. Cost Effectiveness 1
2. Impacts on Water Quality 4
3. Economic Impact 4
4. Induced Growth and Secondary Impacts 4
B. The Need for Improved Wastewater Management - Betsie Lake 5
C. The Need for Improved Wastewater Management - Crystal Lake 5
1. Groundwater Hydrology 6
2. Analysis of Near Shore Aquatic Productivity Problems 9
3. Cold Creek Survey 14
II - ALTERNATIVES
A. The Facility Plan Proposed Action 15
B. The EIS Recommendation - Limited Action 17
1. Technology Selection 17
2. Community Management 21
3. Cost Estimate 23
4. Implementation 24
C. The No Action Alternative 26
D. Other Alternatives 27
III - AFFECTED ENVIRONMENT AND IMPACTS OF NO ACTION
A. Soils 29
B. Surface Water Resources 29
C. Groundwater Resources 30
D. Population and Land Use 30
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Page
E. Environmentally Sensitive Areas 31
F. Economics 31
IV - ENVIRONMENTAL CONSEQUENCES OF THE ACTION ALTERNATIVES
A. Surface Water Resources 33
B. Groundwater 34
C. Population and Land Use 35
D. Economic Impacts 35
E. Economic Impacts 35
Comments and Responses 39
Comment Letters 61
Appendices:
Appendix A. Aerial Septic System Survey of Crystal Lake
Appendix B. Cost Information
Appendix C. Fourteen Things You Can Do to Keep Crystal
(or Betsie) Clear
Appendix D. Soil Conservation Service Soils Data
Appendix E. Region V Guidance - Site Specific Needs
Determination and Alternative Planning for
Unsewered Areas
Appendix F. Revised Effluent Limitations for Discharge
to Betsie Lake
Appendix G. Sample Easement Form
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FIGURES
Figure Page
1-1 Location of Crystal Lake Study Area 2
1-2 Crystal Lake Study Area 3
1-3 Results of Aerial Shoreline Survey, EPIC 1978 7
1-4 Plume Locations on Crystal Lake 8
1-5 Nearshore Groundwater Hydrology - Crystal Lake 10
II-l Facility Plan Proposed Service Area 16
II-2 Limited Action Alternative 18
TABLES
Table Page
1-1 Nearshore Groundwater Hydrology - Direction and Rate
of Flow of Groundwater as Measured by the Model 10
"Dowser" Groundwater Flow Meter Calibrated Against
Beulah Beach Medium Sand 11
II-l Population Projections and Average Annual Growth Rates
for Crystal Lake Proposed Sewer Service Area 30
IV-1 Financial Burden and Displacement Pressure of the
Facilities Plan Proposed Action and the Limited Action
Alternative - Crystal Lake and Benzonia 37
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Chapter I
PURPOSE OF AND NEED FOR ACTION
A. THE APPLICANT'S FACILITY PLAN AND ENVIRONMENTAL IMPACT STATEMENT ISSUES
The "Crystal Lake Area Facility Plan - Wastewater Collection and Treat-
ment" recommended construction of the facilities which will be described
later in this chapter. The proposed wastewater facilities would be in the
City of Frankfort, the Villages of Beulah, Elberta and Benzonia, and the
Townships of Benzonia, Crystal Lake and Lake. These communities make up the
Facility Planning Area, approximately one-fifth of Benzie County, in the
northern part of the Lower Peninsula on the eastern shore of Lake Michigan.
The estimated year-round population of the areas proposed for sewering (i.e.,
the Proposed Service Area) is 4,400, increasing to about 8,300 in the vaca-
tion season. Figure 1-1 shows the project location within the State of
Michigan. Figure 1-2 delineates the Study Area.
The December 1976 Crystal Lake Area Facility Plan was completed and
submitted to EPA by the Benzie County Department of Public Works. The faci-
lity plan, proposing construction of new wastewater collection and treatment
facilities, was developed for the Crystal Lake Area Sewage Disposal Authority
by three consulting firms: Williams and Works, Inc., the lead consultant;
McNamee, Porter and Seeley; and Perla-Stout Associates.
The Crystal Lake Area Facility Plan reviewed existing data on water
quality problems in Crystal Lake and the quality of surrounding groundwater,
as well as information on site conditions such as soil types around the lake.
The Facility Plan concluded that data on high water tables, small lots and
poor soil provided sufficient evidence to link on-site systems to subsequent
water quality problems and, therefore, to warrant sewering the Crystal Lake
shoreline.
The four major issues which the EIS examines are closely related to this
proposal to build sewers around Crystal Lake. The issues are:
1. COST EFFECTIVENESS
Capital cost for the Facility Plan Proposed Action was estimated in the
Plan to be $18.4 million. This is an investment of $2,207 per person or
approximately $8,654 per existing dwelling within the Proposed Service Area.
These per-person and per-household investments would be among the highest in
EPA Region V.
Eighty-one percent of the estimated capital cost would be for new col-
lector and interceptor sewers. Extensive use of pressure sewers as a poten-
tially less expensive alternative to gravity sewers was considered by the
Facility Plan consultants but at the insistence of the State of Michigan was
not evaluated in the facility plan. Reliance on septic tank systems was
briefly considered but was not incorporated into any of the Facility Plan
alternatives. Use of other on-lot sewage disposal methods or small-scale
technologies was not considered.
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BENZIE COUNTY
Figure 1-1: Location of Crystal Lake Study Area
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2. IMPACTS ON WATER QUALITY
Likely impacts of the Facility Plan Proposed Action and alternatives on
water quality were not satisfactorily addressed particularly eutrophication
of Crystal Lake and Betsie Lake and nearshore plant growth in Crystal Lake.
Citizen concern over growth of aquatic plants along scattered shoreline
areas of Crystal Lake resulted in local funding of two limnological investi-
gations of the lake: by Gannon in 1970 and Tanis in 1978. Both studies
documented the presence near some shoreline points of aquatic plants growing
on the lake bottom. The earlier report by Gannon predicted that substantial
increases in plant growth would occur at existing nutrient loading rates.
The report recommended that a sanitary sewer be built around the lake to
collect sewage for treatment and export from the Crystal Lake watershed. The
conclusions and recommendations of this report and statements of the local
sanitarian (Livasy n.d.) were cited in the Facility Plan as the basis for not
relying on septic tank systems around Crystal Lake in the future. The later
report, by Tanis, showed that plant productivity had not increased as pre-
dicted and suggested that "an alternative which addresses specific problem
areas may be more appropriate" than complete sewering of the shoreline.
Neither the Facility Plan nor the limnological reports evaluated quantita-
tively the probable impacts on water quality of sewering or not sewering the
shoreline of Crystal Lake.
The Facility Plan cited a 41% reduction in phosphorus load to Betsie
Lake, resulting in removal of phosphorus from Frankfort and Elberta waste-
water. However, the relationship between such a reduction and lake eutrophi-
cation was not described . The increased nutrient loads due to new and
larger discharges of effluent following population growth were not
calculated.
3. ECONOMIC IMPACT
The estimated user charge for the Facility Plan Proposed Action was $175
per year for each residence or residential equivalent in the new sewer ser-
vice area around Crystal Lake. This charge would amount to 1.9% of the
permanent residents' average annual income. Crystal Lake homeowners would
also pay an initial $1,500 for stub fee and connection charge in addition to
the cost of installing a house sewer to connect the household plumbing with
the public sewer.
The effect of these costs could be to encourage seasonal and fixed
income residents to sell their properties or to convert from seasonal use to
permanent residency.
4. INDUCED GROWTH AND SECONDARY IMPACTS
While the high costs of wastewater collection might force some current
residents to move, the availability of sewers in the Crystal Lake watershed
would make possible construction of new dwellings in greater number and in
higher densities than is presently feasible. The potential for significant
future development is indicated by the substantial number of undeveloped
platted shoreline, second tier and subdivision lots in the area.
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The rate and type of development supported by a central sewer system
could have undesirable impacts. In particular, housing construction on steep
slopes could accelerate soil erosion which, in turn, would increase nutrient
impacts to Crystal Lake or Betsie Lake. In addition, the density and type of
future development feasible with a central sewer system could be considerably
different from what is presently typical of the Crystal Lake area.
B. THE NEED FOR IMPROVED WASTEWATER MANAGEMENT - BETSIE LAKE
The need for upgrading or replacing sewers and two primary treatment
plants serving the Village of Elberta and the City of Frankfort was not an
issue in the EIS. The existing treatment plants discharge to Betsie Lake
which flows through Betsie Harbor into Lake Michigan. Utilizing eutrophica-
tion modeling, the Draft EIS shows 48% of the phosphorus loading to Betsie
Lake resulting from these treatment plants. Removal or reduction of this
phosphorus source will improve the lake's trophic status.
C. THE NEED FOR IMPROVED WASTEWATER MANAGEMENT - CRYSTAL LAKE
The primary source of data on water quality in the Crystal Lake Facility
Plan was a report titled "Crystal Lake Water Quality Investigations," by Dr.
John J. Gannon of the University of Michigan (1970). The Gannon report
concluded that:
the most important source of pollution in Crystal Lake was the inflow
from Cold Creek. Several business establishments and houses along
its north branch contribute phosphates to Cold Creek.
the highest coliform levels and algal concentrations existed in the
waters adjacent to the north shore toward the east end of the lake.
wells along the northeast shore showed significantly higher concen-
trations of nitrate than did wells in other areas. Nitrate levels in
this area generally ranged from 1 to 6 mg/1 as N. (EIS Note: of
the 99 wells sampled on the northeast shore, 45 had nitrate concen-
trations less than 1 mg/1 as N, 50 had concentrations between 1 and 6
mg/1, and 5 had concentrations greater than 6 mg/1.)
Crystal Lake is oligotrophic; dissolved oxygen concentrations in the
deep areas are 7.2 mg/1 or greater.
the algal mass in Crystal Lake will increase three times in a period
of 7 to 10 years.
sanitary sewage should be collected by means of a sewer system that
would encircle the lake; this sewage should then be treated and
discharged outside the basin.
A letter was included in the Facility Plan from Mr. Lyle Livasy, R.S.,
staff sanitarian with the Grand Traverse-Leelanau-Benzie District Health
Department (GT-L-BHD), citing severe soil limitations for on-site systems and
high coliform bacteria counts at two houses on the northeast shore as need
for improved wastewater management.
A series of studies has been conducted during EIS preparation to evalu-
ate in greater detail the water quality and public health problems related to
use of on-site systems around Crystal Lake. In chronological order, the
studied reported in the Draft EIS and their major conclusions are:
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Eutrophication Modeling - On-site sewage disposal systems contribute
an estimated 6.7 % of the phosphorus load to Crystal Lake. Removal
of this source would result in negligible improvement in the lake's
already highly oligotrophic status.
Aerial Photographic Survey - of the 29 identified problem on-site
systems, 10 were found to be actively failing, 12 showed signs of
having failed in the past and 7 were suspected of failure but not
confirmed by field checks. Of these 29 systems, sewers proposed in
the Facilities Plan could have eliminated 9 in the Village of
Benzonia, and 5 around Crystal Lake. Failures detected by this
survey include only those cases where septic tank effluent flows to
the surface of the ground. Figure 1-3 shows the locations of the 29
malfunctions. Appendix A describes the survey methodology.
Sanitary Survey - Interviews with homeowners and inspections of lots
and shorelines produced a substantial amount of information on the
condition of on-site systems around Crystal Lake. Over 50% of the
systems inspected violated the current sanitary code. However, only
3% have had problems with ponding more than once. Six percent have
had backups in the house that could not be attributed to occasional
hydraulic overload or a correctable maintenance problem. Thirty-
four percent of the homes had the green algae, Cladophora, growing
along their shoreline; 10% had "heavy" growths.
Investigation of Septic Discharges - Neither aerial surveys nor
sanitary surveys can detect poorly treated septic tank effluent that
may be entering lakes by way of groundwater. Using a septic leachate
detector, 90 effluent discharges were found entering Crystal Lake.
Sampling and analysis of ground and surface waters in the area of the
plumes showed that they were not seriously effecting lake water
quality. The only significant effect was the stimulation of plant
growth on rocks or logs where the plumes emerge. The highest fre-
quency of plume emergence was along the northeast and southeast
shorelines. Figure 1-4. shows the locations of plumes.
After publication of the Draft EIS in June 1979, three additional
studies were conducted. These were:
1. GROUNDWATER HYDROLOGY
The results of the Investigation of Septic Discharges suggested a signi-
ficant movement of groundwater into and out of Crystal Lake at various Loca-
tions. In the general description of groundwater flow proposed in the Draft
EIS, Crystal Lake intercepts the area's groundwater table. The groundwater
table is not flat but falls from east to west toward Lake Michigan. The
eastern end of Crystal Lake lies below the groundwater table and so acts like
a withdrawal well. Springs at the foot of hills along the north and south-
east shores and the high density of plumes support this. At the western end
of the lake, few effluent plumes are found suggesting that the lake surface
is above the groundwater table, and that outflow of Crystal Lake water is
toward Lake Michigan.
Confirmation of the groundwater flow, suggested by the effluent plume
data, was sought by another method.
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At intervals of about one-half mile along the lake's shoreline, ground-
water flows were measured using a meter which generates a heat pulse, then
measures the pattern of heat dispersion. Soil was excavated to the water
table at three points for each location, the probe was inserted just below
the water level and oriented with a compass fixed on the body of the probe.
Recordings from the three points were averaged to describe the rate and
direction of flow at each location. The results are listed in Table 1-1 and
illustrated in Figure 1-5.
With few exceptions the direction of flow at locations at the east,
north, and west shores was toward the southwest and west. In contrast, flows
along the south shore showed considerable variation. Because measurements
were made at the water table and in a transition zone between groundwater and
the lake, the data reflect local variations in soil porosity, surface drain-
age, size of local recharge areas, manmade diversions and additions (such as
septic tank effluents). On the east, north, and west shores such local
variations appear to be dominated by the regional groundwater flow, which
Crystal Lake intercepts. Flow on the south shore is more subject to the
influence of local factors.
Flow rates below 3 feet per day were found only along the east shore and
at scattered points on the southwest shore. Elsewhere, most flow rates were
between 3 and 12 feet per day. Readings above 12 feet per day were few but,
notably, were found on the northeast and southeast shores.
This new data explains some of the findings of the Investigation of
Septic Discharges (See Figure 1-4), particularly the absence of plumes on the
west shore and the scattered presence of plumes on the south shore. Despite
the time lapse between the two studies, it remains obvious that direction of
groundwater flow determines the emergence of effluent plumes into lakes. It
is also highly likely that rate of flow, along with other factors such as
distance from disposal point to the shore and soil characteristics, influ-
ences the strength of plumes and their effects or\ lakes.
2. ANALYSIS OF NEAR SHORE AQUATIC PRODUCTIVITY PROBLEMS
Prior studies on Crystal Lake and elsewhere had suggested a correlation
between the growths of an algae, Cladophora, and effluent emergence at the
lakeshore. However, these studies did not establish a cause and effect rela-
tionship between effluent emergence and growth of Cladophora. For the
latter purpose, and to evaluate factors controlling effluent plume movement,
five on-site systems close to Crystal Lake were selected for detailed moni-
toring. The sites selected represent worst-case examples of proximity to
shore, depth to the water table and age of dwelling. Monitoring of each site
included:
Location of plume emergence points by three methods including (1)
shallow (18 inches) groundwater sampling along the beach and analysis
by septic leachate detector (2) septic leachate detector scans of the
surface waters at 1, 2, and where possible, 3-foot depths, and (3)
measurement of groundwater flow
Collection and analysis of groundwater samples at 1, 3, and 5 foot
depths below the water table or below lake bottom at 3 to 6 points
along a transect. Transects were determined in the field to be the
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Table 1-1
Nearshore groundwater hydrology - direction and rate of flow of groundwater
as measured by the Model 10 "Dowser" groundwater flow meter calibrated
against Beulah Beach medium sand.
Station # Flow Direction Flow Rate (ft/day)
1 324° NW 1.8 1 1-0
2 290° NW 2.1 ± 1.1
3 282° NW 7.1 ± 2.1
4 285° NW .9 ± -4
5 288° NW .9 ± -0
6 252° w 2.0 ± -8
7 245° SW .3 ± -6
8 280° NW .9 ± «9
9 288° NW .9 ± «0
10 288° NW .9 ± «0
11 187° S 2.7 ± -0
12 359° N 7.8 ± 1-9
13 280° w .9 ± -°
14 260° W 6.6 ± 1-4
15 253° SW 4.6 ± 1.3
16 253° SW 8.2 ± 1-3
17 248° SW 16.8 ± 7.1
18 274° W 11.4 ± 5.8
19 258° w 6.8 ± .6
20 240° SW 6.4 ± 2.5
21 276° w 6.4 ± 2.4
22 254° SW 16.4 ± 10.9
23 335° NW 14.1 ± 4.5
24 246° WSW 6.4 ± 1.3
25 23° NNE 5.5 ± -0
26 277° W 4.6 ± 1.3
27 218° SW 7.3 ± 1.3
28 280° W
29 156° SSE 9.6 - 5.8
30 230° SW 5.0 - 1.9
31 360° N 10.5 - .6
32 324° NW 7.7 - .6
33 17° NNE 5.5-2.6
34 274° W 3.2 - .6
34 290° WNW 1-4 - .6
36 308° NW .9 - .0
37 232° WSW 9.6 + .6
38 226° SW 28.7 + 3.2
39 276° W 5.9 + .6
40 270° W 5.9 + 3.2
41 260° W 7.7 + 1.9
42 242° SW 8.6 + .6
43 264° W 6.8 + .6
44 234° SW 5.0 + 3.2
11
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45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
264°
25°
274°
268°
337°
268°
263°
269°
351°
303°
281°
297°
84°
275°
325°
119°
W
NE
W
W
NNW
W
W
W
N
NW
W
NW
E
W
NW
SE
5.9 + 1.
3.6 + 1.
2.7 + 1.
4.8
+
,0 +
,1 +
9 +
3.6 + 1.
.5 + .
.6
,6
.6
,6
,5 + 2.3
10
2
5
5
4
4
5 _
7.3 + 3.2
9 + 3.2
6 + .0
8 + .6
9 + 3.2
12
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center line of the effluent plume. Parameters analyzed were dis-
solved oxygen, hydrogen ion concentration (pH), relative fluores-
cence, total dissolved solids, orthophosphate, total phosphorus,
nitrate nitrogen, nitrite nitrogen, ammonia nitrogen, organic nitro-
gen, chlorides, sodium, and iron. Field data for one residence
was misinterpreted, resulting in a transect that missed the effluent
plume except at one point next to the drainfield.
Collection and analysis of soil and sediment samples at selected
points along the plume transect. Parameters analyzed included per-
cent moisture, total volatile solids, cation exchange capacity,
water-extractable phosphorus, weak acid extractable phosphorus,
phosphorus sorption, water extractable nitrates, total kjeldahl
nitrogen and particle size distribution.
Description of aquatic plant growths and nutrient analysis of se-
lected plants.
Interviews with the residents to determine design, location, and
usage of their sewage disposal systems.
Three wells and two septic tanks were sampled and analyzed for the
same parameters as the groundwater samples.
The main conclusion drawn from these studies is that effluent plumes are
a source of nutrients stimulating near-shore plant growth. The growths are
highly localized to the point of effluent emergence but, within these limited
areas, are very dense. The spatial extent of the growths varied from site to
site and appears to be limited by non-nutrient factors, especially the avail-
ability of stable substrate such as rock and log jetties. Despite very great
site differences in amount of sewage generated and nutrient concentration in
groundwaters near the shoreline, Cladophora growth was found at all sites and
the density of growth on stable substrates was extraordinarily high at 120 to
270 grams dry weight per square meter of substrate. It is not clear from the
data which constituents of the effluent plumes are responsible for this
growth. While phosphorus is suspected, one of the sites had very low phos-
phorus concentrations in its groundwater yet had Cladophora density as high
as any site. Nitrogen compounds, vitamin B-12, and sulfates are other nutri-
ents which Cladophora requires for growth.
In addition to the Cladophora algae mats firmly attached to cobbles on
the lake bottom were found on all five lots. These mats are inconspicuous
since they are generally less than one-eighth inch thick and are brown or
grey because of trapped, fine sediment particles. Correlation of these algal
mats with effluent plume emergence was not attempted. It is possible that
the mats include considerably more biomass than the Cladophora beards since
the larger, conspicuous algae are limited to stable substrates washed by
effluents while the mats may be more widespread. The algae mats were pri-
marily composed of many species of diatoms with minor representation of
blue-green algae by the filamentous Oscillatoria, a common bottom-dwelling
alga. Species composition of these mats was surprisingly similar among the
five sites.
At two of the oldest sites (21 and 35 years) a third vegetation type was
found, the rooted vascular plant, Potamogeton. In comparison to Cladophora,
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which was growing in a narrow band within the splash zone on rocks and logs,
Potamogeton plants were rooted between cobbles which pave the shallow lake
bottoms in places. The distribution of these plants coincided with the
general areas of plume emergence on these two lots.
The attenuation of phosphorus by the saturated soils under these lots
did not follow expected patterns. Phosphorus attenuation within the plumes
could not be monitored at two of the five sites: one site had little or no
phosphorus throughout the transect and the transect was missed on second
site. At the other three sites, phosphorus attenuation between the soil
disposal systems and shorelines was slight or could be explained by dilution.
For the two permanently occupied sites, average total phosphorus concentra-
tion in groundwater near the lake shore was 3 mg/L.-P., more than enough to
satisfy the phosphorus requirements of the near-shore plants.
These two sites are representative of worst-case conditons: they are
premanent residences, had received higher than normal use in the weeks pre-
ceeding sample collection, were close (40 and 90 feet) to the lake, and used
dry wells for effluent disposal. The 3 mg/l-P represents approximately a 25%
breakthrough rate. Using this information, data from the sanitary survey on
Cladophora density, and some crude modeling, a weighted breakthrough rate of
8% for all houses near the lake was calculated. This is very close to the
assumption used in the Draft EIS to model the septic tank phosphorus contri-
bution to the lake.
3. COLD CREEK SURVEY
In July 1979 Cold Creek and one of its tributaries were monitored with a
septic leachate detector to seek sources of fluorescent materials. In 1978,
Cold Creek was identified as a significant source of both fluorescent mate-
rials and conductivity. Controversy over the source of these materials led
to the 1979 survey.
The 1979 survey found very slightly elevated fluorescent and conductance
readings in Cold Creek proper between its mouth and its confluence with a
small tributary which flows south parallel to US Route 31 joining Cold Creek
just above a man-made settling lagoon. Above this confluence the readings
for Cold Creek were at background levels. The south-flowing tributary,
however, had substantially elevated readings but not as high as the 1978
readings at the mouth of Cold Creek.
The data on Cold Creek remains difficult to interpret. The 1979 survey
suggests that the source of fluorescence and conductivity detected in 1978 is
neither the Beulah sewers which cross Cold Creek nor the watershed as a
whole. The source appears to be located in the small subwatershed northeast
of Beulah but is yet unidentified. Possibilities include both wastewater
discharges (from active or abandoned on-site systems or illegal discharges)
and natural sources of fluorescent chemicals (decaying vegetation in the
marshes adjoining the tributary or decaying wood wastes at an abandoned
lumber mill reported to be in this area). It should be noted that the septic
leachate detector does not locate any non-point source of nutrients other
than wastewater discharges and decaying vegetation. Eroded soils and agri-
cultural fertilizers can be sources of high non-point nutrient loads that
would not be detected except by conventional sampling and analysis.
14
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Chapter II
ALTERNATIVES
A. THE FACILITY PLAN PROPOSED ACTION
The Facility Plan recommended construction of a sewer system to serve
all of the developed areas around Crystal Lake, the Village of Benzonia, US
Route 31 south of the Village and Homestead Road east of Benzonia. Thirty-
five miles of 8-inch to 18-inch gravity sewer, 15 miles of 1^-inch to 14-inch
force main, and 35 lift stations would be required to served this ares. See
Figure II-l.
A new .89 mgd rotating biological contactor (RBC) wastewater treatment
plant would be constructed at a publicly owned site in the City of Frankfort.
Chemical additions to the RBC effluent and micro-screening of the secondary
clarifier effluent would reduce the phosphorus in the plant effluent to 1
mg/1 or less. Chlorination of the final effluent prior to discharge to
Betsie Lake would be provided.
The existing primary treatment plants at Frankfort and Elberta would be
abandoned. New interceptor sewers would be installed to connect sewers at
each site to the new RBC plant.
Sanitary sewer evaluation surveys and sewer rehabilitation were proposed
for the existing sewer systems in Frankfort, Elberta, and Beulah. Rehabili-
tation of Frankfort's system would include construction of new storm sewers
and modifications to the existing combined sewers in order to eliminate
direct discharge of sanitary wastes to Betsie Lake due to overflows.
The Village of Beulah decided not to participate in the regional system
and will continue to operate its lagoon and infiltration basin treatment
system. The Facility Plan recommended that, in addition to sewer evalua-
tion and rehabilitation, groundwater monitoring wells be installed at the
treatment plant and that a standby electric power generator be provided for
existing lift stations. By the Village's choice, these measures would be
funded by the Village without assistance from state or Federal grants.
Cost developed in the Draft EIS for the Facility Plan Proposed Action
are:
1980 Construction Costs -
(including engineering, legal,
and contingency costs)
Future Construction Costs -
Annual Operation and Maintenance
Expense -
1980 Local Cost -
1980 Average Annual User Charge
$17,303,000
$2,467,000
$181,400/yr
$l,010,000/yr
$110/yr Frankfort
and Elberta
$720/yr New service
areas
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16
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The 1980 Average Annual User Charge includes all operation and mainte-
nance costs for the year plus annual payment on the debt of privately as well
as publicly financed construction costs of an interest rate of 6-7/8% with a
payback period of 30 years. This charge for the new service areas is
strongly influenced by the eligibility of the 50 miles of new sewers. EPA
made a preliminary eligibility determination that makes 40% of the cost for
these sewers eligible.
Implementation of the Facility Plan Proposed Action would include con-
ventional procedures that are adequately described in the Facility Plan.
B. THE EIS RECOMMENDATION - LIMITED ACTION
For the existing sewer service areas in Frankfort, Elberta and Beulah,
the EIS Recommended Action is the same in concept as the Facility Plan Pro-
posed Action except that the new RBC plant in Frankfort would only need to
handle .32 mgd. Another possible exception is that site specific analysis,
lack of off-site treatment locations and cost-effectiveness analysis may
show that treatment at Beulah's plant of residential wastewaters collected
from the northeast and southeast shores of Crystal Lake would be economically
and environmentally attractive.
For the unsewered parts of the Proposed Service Area (see Figure II-2),
this Limited Action would continue the use of existing on-site systems
wherever feasible. In addition, the community's role in managing on-site
systems would be expanded to include, at least, supervison of system main-
tenance, monitoring of present or potential underground potable water
sources, and collection of user charges to recover the costs involved.
Many elements of this approach, including likely maximum costs can be
sketched now, but the final details will not be known until: 1) house-by-
house analysis allows a selection of treatment methods for each house and 2)
the applicant and community decide on the method and degree of management to
be provided. The two considerations are discussed below.
1. TECHNOLOGY SELECTION
Identification of on-site systems' problems and the causes of their
problems is the first step to be taken specifying technologies for individual
residences. Site specific analysis is necessary to accomplish this. The
analysis should be sequential, beginning with accessing available health
department records, interviewing residents on the use and maintenance of
their systems, inspecting the site for obvious malfunctions and inspecting
the location and condition of any on-site wells or springs. Based on the
information gathered, additional investigations may be warranted to identify
the cause and possible remedies for recognized problems. Examples of addi-
tional investigations keyed to problems are:
Problem Investigations in Sequential Order
Recurrent Backup in House or Install and monitor water meter
Surface Malfunction
17
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18
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Inadequate Separation Distance
from Septic Tank or Soil Absorp-
tion System to Well
Inadequate Separation Distance
from Septic Tank/Soil Absorption
System to Lakeshore, or Inadequate
Separation Distance from Soil
Absorption System to Groundwater
or Evidence of Increased Plant
Growth
Septic Tank or Soil Absorption
System Size or Design Suspected
of Being Less than Code Requires
Septic Tank or Soil Absortion
System Size or Design Known to
be Less than Code Requires
Uncover pump and inspect septic tank for
obstruction and groundwater inflow
Rod house sewer and effluent line
Excavate and inspect drainfield distri-
bution lines, if present
Determine soil absorption system size and
degree of clogging by probing and sample
pit excavation. Note soil texture and
depth to groundwater.
Inspect well for proper seal, vent,
drainage and grouting
Sample well and analyze for fecal coliform
bacteria, nitrates and fluorescence
Monitor groundwater flow if aquifer is
shallow or unconfined
Monitor groundwater flow direction and
rate.
Locate effluent plume vicinity of lake-
shore using groundwater probe and fluo-
rescent analysis
Sample groundwater in leachate plume at
lakeshore. Analyze for total phosphorus,
total Kjeldahl nitrogen, nitrate, nitrogen,
and fecal coliform bacteria
Inspect property to assess feasibility of
replacement or upgrade
If feasible, document system inadequacies
by probing and sample pit excavation.
Inspect property to assess feasibility of
replacement or upgrade
In the selection of technologies of individual sites, it is strongly
recommended that:
alternatives other than those covered by existing codes be considered
stal;e and local officials legally responsible for permitting on-site
systems be involved in selections
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the availability and cost of skilled manpower for maintaining and
monitoring innovative or sub-code systems be weighted against the
feasibility and cost of requiring conventional on-site systems or
off-site systems
that there be a multidisciplinary team, consisting of the sanitarian-
administrator and available specialists in a number of fields (see
Management Section) to advise the Sanitary Review Board on a case by
case basis
that the individual homeowner should be informed of the different
options being considered (and their costs) when technology selections
are being made. His opinion and advice should be solicited.
Utilizing information gained from the site analysis, feasibile approa-
ches to solving any problems should be discussed with the owner. Primary
criteria for identifying the appropriate technology should be cost, benefits,
and risk of future failure. Undoubtedly, eligibility for Construction Grants
funding will be considered also. General guidelines for eligibility of on-site
technologies are presented below:
Replacement of facilities of obviously inadequate design will be
eligible if feasible. Cess pools are an example of obviously inade-
quate facilities. Septic tanks which are in very poor repair or are
substantially smaller than required by state codes are another
example. Small drainfields, dry wells or unusually designed systems
are not of obviously inadequate design.
Parts of systems which cause recurrent surface failures, backups or
contamination of potential drinking water aquifers are eligible for
repair or replacement. This does not apply to water using fixtures.
Systems which fail because they are abused will not be eligible un-
less the abuse is terminated and the usage of the system is docu-
mented by water meter readings and/or reinspection of the system.
Facilities which are not currently causing public health or water
quality problems may be eligible for repair or replacement if similar
systems in the area are failing. "Similarity of systems" includes
design and site characteristics which are shown to be contributing to
failures.
Compliance with state and local on-site design regulations in design
of repairs and replacements is desired where feasible and effective.
Compliance is not a condition of eligibility if sub-code design, or
alternative processes can reasonably be expected to eliminate or sub-
stantiate mitigate public health and water resources problems. Inno-
vative designs will similarly be eligible with the added condition
that inspection and monitoring commensurate with the degree of risk
be assured. For sub-code, alternative or innovative systems, it is
expected that water conservation devices commensurate with the degree
of risk for hydraulic overloading will be installed at owner or
applicant's expense.
For this Study Area, methods will be eligible which modify the flow
or chemical characterisitcs of effluent plumes that enter Crystal
20
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Lake if the modification might reduce the nearshore plant growth.
Such methods will be considered innovative. Monitoring of their
effectiveness will be required.
On-site systems built after December 1977 are not eligible for repair
or replacement but will be eligible for site analysis. Accommodation
of new water uses added since December 1977 will not be a basis for
determining eligibility. Systems adequately designed for the build-
ing they serve but malfunctioning because of hydraulic or organic
overloading or other abuse will not be eligible except as explained
above.
It is recognized that some developed lots may never be serviceable by
on-site technologies. Off-site treatment and disposal will be eligible for
Federal funding if:
1) a public health or water resource contamination problem is docu-
mented that cannot be abated by any combination of on-site conven-
tional, innovative, sub-code, flow reduction or waste restriction
methods, or
2) the life cycle costs of off-site treatment and disposal for an
individual building or group of buildings is less than costs of
appropriate on-site technologies for the same buildings.
The recommendations apply only to existing systems - the community
compounded the risk of on-site system failures by permitting these systems in
their present form and leaving their maintanance to the responsibility of
their owners. EPA is recommending and funding the Limited Action alternative
to help the community and system owners minimize the risk, thereby protecting
water quality and the public health. For systems to be built for new hous-
ing, EPA makes no recommendations on the permitting process since the Agency
does not presently expect to be funding remedies for their failures.
2. COMMUNITY MANAGEMENT
In regard to funding privately owned on-site systems, current EPA regu-
lations (40 CFR 35.918-1) require that
...the grant applicant shall:... Certify that such treatment
works will be properly installed, operated, and maintained
and that the public body will be responsible for such actions.
This requirement also applies to publicly owned-site systems.
Within this limitation, communities have a wide range of options avail-
able. Many of these options were discussed in the Draft EIS, Section
III.D.2. To add depth to the subject, three additional topics and their
interrelationships are discussed here. They are: risk, liability and scope
of the applicant's responsibilities.
"Risk" as used here refers to the probability that wastewater facilities
will not operate as intended, thereby causing water quality or public health
problems or inconvenience for the user. Whether centralized, small scale, or
on-site, all wastewater facilities have inherent risks, the degree of which
is dependent on skill in design, construction, operation, and maintenance.
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"Liability" as used here refers to the responsibility of various parties
to minimize risk and to accept the consequences of facility failure. In the
past the state or county has accepted liability for facilities around Crystal
Lake only so far as permitting and inspection activities minimized risk. The
consequences of facility failure rest with the systems' owners. In building
a sewer around Crystal Lake, Benzie County essentially would have accepted
liability for all failure except for plumbing and house sewer blockages.
With the Limited Action Alternative, the community still has the opportunity
to assume increased liability in whatever manner it sees fitthe only limi-
tation being that the Benzie County Department of Public Works will be re-
sponsible for actively identifying failures of interest to the community
(inconvenience for the user not included) and attempting to remedy the fail-
ures. Strictly speaking, the DPW's responsibility under 40 CFR 35.918-1
applies only to those individual systems funded by EPA.
Many of the assumptions made in describing and costing the Limited
Action Alternative were based on the applicant playing a very active role in
improving, monitoring and maintaining all wastewater facilities around
Crystal Lake. EPA encourages this but does not require it. The scope of the
DPW's responsibilities depend on how much liability for wastewater facilities
it wants, and is legally capable, to assume. EPA will, by funding facility
planning, design and construction, assist the DPW in meeting those liabili-
ties it assumes which reduce the risk of water quality and public health
problems.
To illustrate the range of approaches the applicant might take, three
management scenarios are described below:
Minimum Management Requirements
The Benzie County Department of Public Works would act as the recipient
and distributor of Construction Grant funds. Homeowners who wished to
improve their on-site facilities could apply to the DPW for this assistance.
After documenting that minimum requirements for on-site system eligibility
are met, the DPW would receive the funding and distribute it to homeowners
who show proof of satisfactory installation. These homeowners would be
assessed an annual fee thereafter to cover the cost of a site inspection
perhaps every three to five years and would be required to show proof of
appropriate maintenance activities as part of the site inspection. A ground-
water monitoring program would include taking well water samples during the
site inspection.
With this approach, neither the County nor the municipalities would
incur any long-term debt. The DPW would not necessarily have any responsi-
bility for or interest in permitting future on-site systems. Lacking a
comprehensive site inspection and evaluation program, it is unlikely that all
water quality and public health problems would be identified on abated.
Liability for facility malfunctions would remain wholly with the owners.
Comprehensive Wastewater Management
This is the approach recommended for adoption by the applicant. It
involves instituting the small waste flow district concept discussed in the
Draft EIS. See particularly pages 141-144 and 185-186 and Appendix K. All
22
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buildings within the district's service area boundaries would be included.
At a minimum each building's wastewater system would be covered in the site
specific analysis, and would be inspected at intervals. Owners or residents
of each building would be responsible for a user charge to repay their share
of necessary operating costs. The local debt for construction of each system
can be directly assessed to individual homeowner's, as in the Minimum Manage-
ment scenario, or they could be funded as long term debt.
This approach should identify all wastewater generation, treatment and
disposal problems in the service area, and should insure that future problems
are minor or short lived. In contrast to the Minimum Management scenario,
the higher level of responsibility resulting from this approach would allow
the authroity greater discretion in sharing liability for facility operation
with the resident or building owner.
Watershed Management
The applicant's concern with prevention and control of water pollution
need not be restricted to wastewater facilities. It is obvious from the
local funding of prior water quality studies by Dr. John Gannon in 1970 and
Fred Tanis in 1978 and from comments on the Draft EIS that citizens of the
Study Area are greatly interested in maintaining the water quality of Crystal
Lake. If that interest is expressed in the form of willingness to pay for
additional governmental services, the Comprehensive Wastewater Management
scenario could be augmented by the following functions:
non-point source monitoring
non-point source control
education of residents and visitors about individual pollution con-
trol practices, costs and benefits
inventory the biological resources of the lake and its tributaries
research the chemical, hydrological and biological dynamics of the
lake
coordinate with other local, state, and Federal agencies on pollution
control activities and funding.
3. COST ESTIMATE
In response to comments on the Draft EIS, the cost estimate of the
Limited Action Alternative has been reviewed in detail. Two cost elements
have been revised upward: the engineering, legal and contingency fee, and
operation and maintenance costs. These revisions are discussed in more
detail in the Comments and Responses under the "Alternatives" heading.
The revised price parameters for the Limited Action Alternative are:
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Frankfort Unsewered
and Elberta Service Area
1980 Construction Cost -
(including engineering, legal,
and contingency costs) $3,897,100 $1,936,800
Future Construction Costs 553,400 93,800/yr.
Annual Operation and
Maintenance Expense 53,500 113,500
1980 Local Cost 120,733 131,996
1980 Average Annual User
Charge 100 95
4. IMPLEMENTATION
As recommended in the Draft EIS, the Limited Action Alternative has been
divided into two projects, one for the centralized facilities in Frankfort
and Elberta, the other for municipalities around Crystal Lake. Michigan
Department of Natural Resources has given separate priority ratings to the
two projects, both of which are in the fundable range.
Since publication of the Draft EIS, Michigan DNR has revised the
effluent limitations for the new Frankfort treatment plant to allow higher
BOD and suspended solids concentrations. The new limitations are:
Parameter 30-day Average 7-day Average_
5-day BOD 30 mg/1 45 mg/i
Total Suspended Solids 30 mg/1 45 mg/1
Fecal Coliform Bacteria 200/100 ml
pH 6-9
Total Phosphorus 1.0 mg/1
Specific aspects of implementing the Crystal Lake project were discussed
in Section V.B.2 of the Draft EIS. Modifications to those discussions are:
Ownership of On-Site Systems Serving Seasonal Residents - The state-
ment was made that privately owned systems serving seasonally occu-
pied residences are not eligible for Federally funded renovation
and replacement. EPA Program Requirements Memorandum 79-8, issued
very shortly before the Draft EIS went to print, modified this policy
to allow eligibility of seasonally used, privately owned on-site sys-
tems as long as the responsible public agency is given " complete
access to and control of" the system. See Comments and Responses
under the "Implementation" heading.
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Completion of Step I Requirements for the Small Waste Flow District -
Michigan DNR has requested that the site-specific environmental
and engineering data base be developed as part of a Step I grant
amendment instead of with a Step II grant as recommended in the Draft
EIS. In response to this, and the very different proposals of other
states, EPA Region V developed a new memorandum clarifying project
needs documentation. It provides that at most a representative sam-
pling (15 to 30 per out) of site-specific data base need be developed
in Step I. The remaining 70 to 85% should be done in Step 2 (see
Appendix E). Other remaining Step I requirements remain as stated on
pages 186-187 of the Draft EIS.
For the purposes of technology selection and organization development in
Step 2 and construction supervision in Step 3, the grantee will establish a
Sanitary Review Board. The boards's responsibilities will be to:
supervise the direction and progress of the site specific analysis
insure homeowner input to technology selection
encourage community participation in the management and technology
decisions to be made
review and act on any proposed facilities designs which are not in
conformance with present regulations
provide an appeal process for owners who object to the technology
selected for their property and
insure that site analysis and technology selection is conducted by a
multidisciplinary team consisting of persons with knowledge and
experience in soil science, water chemistry, geohydrology, waste-
water characteristics, innovative, alternative and conventional de-
centralized treatment technologies and practical aspects of decen-
tralized system construction and maintenance.
Description of the grantee's organization of this review board and the
qualifications of individuals proposed for the Step 2 site analysis and
technology selection should be included in the application for Step 2 funds.
The Step 2 grant will be contingent upon review and approval of the applica-
tion by the Technology Section of EPA Region V's Water Division.
It is recommended that the necessary technical expertise be sought from
several sources such as:
the Grand Traverse-Leelanan-Benzie District Health Department
Benzie County Department of Public Works - existing staff or new
hires
corporate consultants
individual consultants
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universities
Northwest Michigan Regional Planning and Development Commission
Similarly, if assistance in developing the organizational structure of
the review board and supporting activities is needed, legal and management
consulting services should be sought and, within reason, they will be grant
eligible.
For the purpose of long-term continuity, it is recommended that at least
one person be hired by the DPW to have an active role in Steps 2 and 3 work,
to act as the review board's staff, and to provide technical expertise in the
future.
C. THE NO ACTION ALTERNATIVE
The No Action alternative is broadly defined as an EPA rejection of
Construction Grants applications for the Study Area. More specifically, the
implication of this is that the sewers and treatment plants in Frankfort and
Elberta would not be upgraded. In the unsewered parts of the Study Area, the
Health Department would continue to issue permits for new septic tank systems
on suitable lots and to require correction of surface malfunctions.
With the No Action Alternative, the Village of Elberta and the City of
Frankfort would violate State and Federal effluent discharge requirements
when interim limitations expire. Betsie Lake would maintain its eutrophic
status. Additional flows to these primary treatment plants would be prohi-
bited because they are already overloaded.
The need for improved wastewater management around Crystal Lake is less
clear. The number of on-site systems experiencing serious or recurrent
malfunctions is small less than 10%. The impacts of individual on-site
systems on Crystal Lake water quality are variable but, taken together, the
systems have not been shown to adversely affect the lake. The most notice-
able impact of the systems is stimulation of localized plant growths on and
near beaches of approximately one-third of the lake frontage properties.
With the No Action Alternative, health authorities will continue to have
inadequate information with which to design on-site system repairs appro-
priate to the problems and their causes. They are unlikely to have the time,
personnel, or monitoring capabilities to be able to specify innovative
attempts to solve the problems. The result will be increasing numbers of
holding tanks on small lots and on lots with high groundwater.
No Action does not mean no cost. Assuming that existing systems will
fail at a rate of two percent per year and be replaced by a mix of holding
tanks, conventional drainfields or dry wells, or mound systems, the present
worth of the No Action Alternative for only the Crystal Lake service area
only could be $1,823,700. This compares to $4,006,200 for the Limited Action
Alternative and $13,421,700 for the Facilities Plan Proposed Action (Crystal
Lake portion only).
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D. OTHER ALTERNATIVES
Many other alternatives have been considered in the applicant's Facili-
ties Plan and in EPA's Draft EIS. Alternatives considered and reasons for
their rejection or other status are summarized below:
FACILITIES PLAN ALTERNATIVES
Alternatives
Status
Optimum Operation - Beulah STP
Optimum Operation - Frankfort and
Elberta STPs
Accepted by the Village of Beulah. No
government grants requested.
Sites too small for required upgrading.
Land application east of Benzonia
Rejected in Facilities Plan on basis of
cost-effectiveness.
Meter water use and base sewer
charge on use to reduce waste-
water flows
Hypothetical. Should be seriously con-
sidered if water mains are extended.
Rehabilitate sewer systems in
Frankfort, Elberta, and Beulah
Separate combined sewers in
Frankfort
Rotating biological disc (RED)
Activated sludge
Physical-chemical treatment
Treatment and reuse
Sludge incineration
Digestion, dewatering, and land
disposal of sludge
Incorporated in EIS Recommended Action
for Frankfort and Elberta. Beulah not
participating in grant application.
Incorporated in EIS Recommended Action
without further review.
Selected as treatment process in Facil-
ities Plan along with chemical addi-
tions, microstraining, and chlorination.
Incorporated in EIS Recommended Action
without further review.
Rejected in Facilities Plan because of
RBD's lower energy requirement, lower
operating cost, ease of operation, and
reduced risk of upsets.
Rejected in Facilities Plan on the
basis of cost.
No feasible alternatives due to types
of local industries.
Not economically feasible.
conserve nutrients.
Does not
Incorporated in EIS Recommended Action
for new Frankfort plant without addi-
tional review.
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No Action Rejected in Facilities Plan on basis of
failure to address pollution problems.
EIS ALTERNATIVES NOT ALREADY CONSIDERED IN FACILITIES PLAN
Residential flow reduction by
various devices
Laundry detergent phosphorus
ban
Pressure Sewers
Vacuum sewers
Small diameter sewers
Alternative toilets - various
designs
On-site treatment and disposal
various designs
Off-site treatment and disposal
various designs
Septage disposal by co-treatment
at Frankfort RBC plant
Expected to be effective in maintaining
the operability and minimizing impacts
of on-site systems in the EIS Recom-
mended Action.
Implemented by Michigan DNR prior to
EIS process.
Extensive use of pressure sewers re-
jected because of lack of need. Could
be advantageous in the design of small
waste flow systems.
Rejected in preference to pressure
sewers for comparison with gravity
sewers. Could be advantageous in the
design of small waste flow systems.
Rejected due to marginal cost advantage
over conventional gravity sewers for
large collection systems. Could be
advantageous in the design of small
waste flow systems.
Not specifically incorporated in EIS
Recommended Action but could be useful
where control of nutrients is sought.
Incorporated in EIS Recommended Action
for Crystal Lake area - discharging
systems excluded from use.
Incorporated in EIS Recommended Action
for Crystal Lake area where shown to be
worth the expense and trouble - dis-
charging systems excluded from use.
Mentioned as a possibility - needs addi-
tional analysis.
Septage disposal by land application Mentioned as a possibility - needs addi-
tional analysis.
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CHAPTER III
AFFECTED ENVIRONMENT AND IMPACTS OF NO ACTION
A. SOILS
Soils in the study area were formed from materials deposited by gla-
ciers. They generally contain high proportions of sand and, with some excep-
tions, are permeable.
Much of the unsewered development in the Proposed Service Area is lo-
cated around Crystal Lake on soils developed originally as submerged lake
terrace. Lowering of the lake in 1873 exposed this sandy terrace. The
terrace's elevation above lake level and groundwater varies from one location
to another. A number of home-sites around Crystal Lake have less than three
feet of soil above the groundwater table.
Because of the soil's permeability in most developed places, particu-
larly the lake terrace, surface malfunctions and backups of existing on-site
systems are expected to recur but at a low rate even with the No Action
alternative. High permeability of lake terrace soils also suggests that
septic tank effluents may not be adequately treated before emerging into the
lake. Survey data and detailed site investigations suggest that treatment,
particularly removal of nutrients, is variable. With the No Action Alterna-
tive, any systems which provide especially poor treatment would not be lo-
cated and modified to provide adequate treatment.
Building of new dwellings and on-site systems will continue under the No
Action Alternative. Some erosion will occur because of this activity.
B. SURFACE WATER RESOURCES
Crystal Lake occupies approximately 15 square miles; its tributary is
Cold Creek. Betsie Lake occupies approximately 0.4 square miles. Its
primary tributary is the Betsie River, and it is itself tributary to Lake
Michigan.
Crystal Lake, despite a retention time greater than 60 years, is gener-
ally clean, clear and oligotrophic. At a distance from the shoreline, the
Lake has shown little change in productivity in 10 years. Conversely, Betsie
Lake, with a retention time of 2 days, is eutrophic. For both lakes, phos-
phorus has been identified as the limiting nutrient.
With the No Action Alternative, Betsie Lake is certain to remain eutro-
phic. Crystal Lake will remain oligotrophic. Near-shore plant growth around
Crystal Lake may increase in frequency and severity. Judging from the worst
examples studies during the 1979 Aquatic Productivity Study, this type of
growth will not obstruct recreation or degrade water quality.
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C. GROUNDWATER RESOURCES
Groundwater serves as the source of drinking water for Beulah, Elberta
and Frankfort. Water supplies in the remainder of the Study Area consist of
individual and small community wells. Water is generally plentiful and of
good quality, although hard. A 1969 survey of 165 wells around Crystal Lake
indicated no contamination by indicator bacteria; nitrates were generally
present at concentrations ranging from 0-2 mg/1. The concentration of ni-
trate in 2 wells exceeded the Drinking Water Standard of 10 mg/1.
Sampling of groundwaters on lots adjacent to Crystal Lake indicated that
concentrations of nitrogen compounds (including nitrate and compounds which
could oxidize to nitrate, i.e., ammonia and organic nitrogen) exceeded 10
mg/1 only in the core of effluent plumes. As long as ungrouted new wells are
not located where effluent plumes will be allowed, the potable groundwater
supplies should maintain adequate quality even with the No Action Alterna-
tive.
D. POPULATION AND LAND USE
Approximately 60 percent of the Proposed Service Area population are
seasonal residents, located primarily in the unsewered areas surrounding Cry-
stal Lake.
The total in-summer population of the Proposed Service Area in the year
2000 is projected to be approximately 12,500, a 47% increase over the 1975
figure. The average annual growth rate for the 28-year period from 1972 to
2000 is expected to be 1.5%, slightly higher than the historical rate of
1.4%. The largest absolute increase in combined permanent and seasonal
population is projected for Crystal Lake Townshipnearly 2,000 additional
persons or 83% by 2000while Benzonia Village, Beulah Village and the City
of Frankfort are expected to increase by only 10 to 20% in that time.
Summary estimates of permanent and seasonal population and average
annual growth rates for the years 1975 to 2000 for the Proposed Service Area
are presented in Table III-l.
Table III-l
POPULATION PROJECTIONS AND AVERAGE ANNUAL
GROWTH RATES FOR CRYSTAL LAKE PROPOSED SEWER SERVICE AREA
Population Average Annual Absolute Change
Component 1975 2000 Growth Rate (1975-2000) (1975-2000)
Seasonal 4,098 6,742 2.0% 2,644
Year-round 4,420 5,748 1.1% 1,328
Total 8,518 12,490 1.5% 3,972
With the No Action Alternative, growth in the Proposed Service Area
would be limited to sites suitable for on-site systems. Because of this
restriction, population may not grow at the rate projected. Based on number
of platted lots and soil characteristics near presently developed areas, the
year 2000 total population is estimated to be 7% below the projection above.
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Land use in the Service Area consists of: three small urban centers
(Frankfort, Elberta, and Benzonia); permanent and seasonal single family
residences; agricultural areas devoted to row crops and orchards; and open
land consisting of woodlands, wetlands, and sand dunes. The aesthetic appeal
of the area has resulted in substantial residential development around Crys-
tal Lake. Most commercial areas are located in the village centers and along
major highways.
Significant increases in residential acreage would be likely within the
proposed Crystal Lake Service Area regardless of the treatment alternative
adopted. Residential acreage is projected to increase by 77% by the year
2000 even under the No Action Alterantive.
E. ENVIRONMENTALLY SENSITIVE AREAS
Environmentally sensitive areas within the EIS Study Area include wet-
lands, sand dunes, steep slopes, prime agricultural lands, flood hazard
areas, habitat of three plant species classified as "threatened" by Federal
and state agencies, an historic site in the Village of Benzonia, and four
possible archaeological sites.
Of these, only steep slopes around Crystal Lake are likely to be ad-
versely impacted by any of the alternatives, including No Action. Pressures
to develop marginally suitable sites with on-site systems will increase as
more favorably located sites are developed. Accelerated soil erosion that
could result from construction activities and vegetation removal can be
mitigated by adherence to the Sediment and Erosion Control Act of 1972.
The location and character of the four archaeological sites in Lake and
Crystal Lake Townships have not been specified so that impacts on them by any
of the alternatives are indeterminate. Prior to construction of any waste-
water facilities on publicly owned land in these Townships, the Michigan
State History Division will require an archaeological survey.
F. ECONOMICS
The permanent resident population of the Study Area Township is charac-
terized by low incomes. Of this population, 17% are people living on fixed
incomes that are below the average for all of Michigan's retirement age
population. Income characteristics of the seasonal residents cannot be
determined.
In regard to the No Action Alternative, were Frankfort and Eberta to
construct, fund and operate the new facilities without State or Federal
support, the average annual user charge per household would be approximately
$280 per year compared to $100 if state and Federal funding is provided.
This charge would cause a 40-50% significant burden and 10-15% displacement
pressure (see Section IV.E.).
The costs of No Action in the Crystal Lake municipalities will fall most
heavily on homeowners who must install holding tanks. A homeowner with four
residents generating 45 gallons per person per day and paying $45 per 1,000
gallons pumped would be paying almost $3,000 per year for sewage disposal.
Although this could be reduced substantially by installation of effective
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flow reduction devices and negotiating with the hauler, the cost would still
be substantial. The high cost would be an incentive for the homeowner to
find other, perhaps dangerous, means of disposing of wastewater.
As long as their systems do not fail, other homeowners could get by with
very minimal expense, perhaps $45 every 10 years for maintenance pumping of
their septic tank. Residents whose systems fail but who can make a standard
repair would incur a one-time expense of perhaps $1,000 to $2,000. If dosed
mound systems were necessary, costs could be as high as $5,000.
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CHAPTER IV
ENVIRONMENTAL CONSEQUENCES OF THE ACTION ALTERNATIVES
This chapter presents the environmental impacts of the conceptual or
system alternatives embodied in the Facilities Plan Proposed Action and in
the EIS's Limited Action Alternatives. Please note that the Limited Action
Alternative is not at present a set of explicit construction proposals for
each building--it is an approach, based on the assimilative capacity as well
as the environmental sensitivity of the local natural resources, that relies
on environmental management in the form of continuing attention to the use
and effects of small-scale systems, and the ability to make balanced deci-
sions, including exceptions, in the best interest of the local environment.
A. SURFACE WATER RESOURCES
For Betsie Lake the water quality impacts are nearly identical for the
two alternatives. The difference in flow (year 2000 flows of 0.89 mgd vs.
0.33 mgd) will result in lower nutrient, organic and chloride loads on the
lake with the Limited Action Alternative. However, the difference in total
phosphorus load to the Lake is only one percent. Either alternative will pro-
duce a substantial reduction in the Lake's phosphorus loading43 percent for
the Facilities Plan Proposed Action and 44 percent for Limited Action. The re-
sult is expected to be a reduction in aquatic plant growth and improved water
quality. Both alternatives would eliminate the occasional raw sewage dis-
charges from Frankfort's combined sewers.
The Facilities Plan Proposed Action would nearly eliminate wastewater
and septic tank effluent discharges to Crystal Lake. It is believed that
much of the algae and plant growth on beaches associated with these dis-
charges would go away over a period of one-to-three years. Beds of aquatic
plants near the mouths of tributaries are expected to be unaffected by the
Facilities Plan Proposed Action. The trophic status of Crystal Lake will not
be measurably affected. With this alternative, there exists the possibility
of pumping station breakdown and significant raw wastewater discharges to the
Lake (up to .5 mgd). Careful design and close supervision of the pumping
stations would minimize this possibility.
The Limited Action alternative would not totally eliminate algae and
plant growth on beaches. Decreases in the occurrence and density of these
growths would be achieved in places where off-site treatment (holding tanks
or cluster systems and other small-scale measures) is selected. Improvement
would also occur where repair of on-site facilities (elimination of dry
wells, relocation of filter fields) reduces or eliminate seffluent plumes
reaching the lake. Research on measures to change the flow and quality of
effluent plumes could lead to additional mitigation of these growths. Ex-
amples of such measures include but are not limited to:
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removing garbage grinders
flow reduction
aerobic treatment
chemical additions to septic tank effluent
non-discharging toilets
capture of effluent plumes for lawn irrigation
laundry detergent phosphate ban (already in effect)
seasonal modification of groundwater by lake level control.
The Limited Action Alternative would not improve the projected trophic
status of Crystal Lake. However, the productivity is expected to remain very
low. Beds of aquatic plants near the mouths of tributaries would remain.
Small wastewater pumping units (300 to 5000 gpd) may be required for
cluster systems or individual homes. Reliable alarm systems and periodic
maintenance (1 to 4 times per year) will be needed to insure against backups
or overflow to the lake. Since the magnitude of spills with the Limited
Action Alternative are about two orders of magnitude less than with the
Facilities Plan Proposed Action, the possible impacts of equipment failure
are much less.
B. GROUNDWATER
The Facilities Plan Proposed Action would eliminate the discharge of
wastewater effluents to the groundwaters around Crystal Lake. As discussed
above, this would reduce nearshore plant growths stimulated by the enriched
groundwaters. The threat of well water contamination from septic tank ef-
fluents would be removed. However, actual improvement in the potable ground-
water supply would be minor at best. Well water quality, as sampled in 1969,
was satisfactory except for high nitrates of undetermined origin in a few
wells.
The Limited Action alternative would detect and reduce or eliminate in
the shallow groundwater around Crystal Lake. The plumes can change, with
time, in size slope, and strength, depending on wastewater or groundwater
characteristics. At present, wells day within these plumes, particularly
ungrouted wells, could receive nitrate and other chemical loads.
The Limited Action Alternative would eliminate the hazard to drinking
water by 1) inspecting existing wells and filter fields, 2) sampling wells
that are down gradient or within 50 feet of septic tanks or soil absorption
systems, and 3) selecting on-site or off-site measures to stop actual or
possible drinking water contamination.
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These repair measures might include elimination of dry wells and filter
field repair or relocation. Cluster systems sites would receive geohydro-
logic surveys, and well water would be monitored at regular intervals. In
all cases except for new construction on lots with more than 5 feet to
groundwater, costs for these measures are included among the analysis or
maintenance costs of the Limited Action Alternative (see Appendix B). Also,
actual repair (grouting, etc.) of wells may often prove less expensive than
treatment modifications.
C. POPULATION AND LAND USE
Population projections used for the design of alternatives in the EIS
were based on recent growth trends and data from a variety of sources. The
design projections did not incorporate any constraints or inducements due to
the amount of developable land or other complex economic, demographic or land
use factors.
Examination of development potential as an impact of centralized sewage
treatment, however, suggests that the amount of developable land and the
density of development will both be greater with sewers than without. Trans-
lated into population increases, it is estimated that actual year 2000 popu-
lation in the existing and proposed service areas with the Facilities Plan
Proposed Action would be as much as 19 percent higher than the design popula-
tion, or 14,860 instead of 12,390 total, in-summer population. In contrast
the projection for the Limited Action Alternative is 7 percent less than the
design population, or 11,620.
The population projections suggest an increase of 36 to 74 percent over
1975 figures. Because of the different densities at which development is
likely to occur, the estimated percent increases in developed land are much
closer. For the Crystal Lake service area, residential acreage is projected
to increase by 77 percent with the Limited Action Alternative versus 88 per-
cent with the Facility Plan Proposed Action. The amount of new nearshore
development would be particularly constrained with the Limited Action Alter-
native because the stock of land developable with on-site systems is small.
Much of the new development would occur on relatively large back lots. In
contrast a sewer would give nearshore acreage high development potential and
could support commercial and resort uses. If the Limited Action Alternative
were chosen, developers might wish to acquire unbuildable shoreline lots as
multi-family access and recreation sites.
E. ECONOMIC IMPACTS
The economic impacts of either alternative would be the net benefits of
improved water quality on the economy of the community and direct cost to
system users.
The City of Frankfort will likely realize the greatest water quality
related economic benefits from either alternative. Improved water quality
may result in increased use of the City's marina for lake fishing activities
and in increased tourism.
Economic benefit may be realized by approximately 180 lakeshore homeown-
ers around Crystal Lake due to disappearance of nearshore plant growths with
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the Facilities Plan Proposed Action. The Limited Action Alternative would
offer similar benefits to lakeshore owners receiving off-site treatment or
substantial system upgrading. This benefit could be realized as increased
property resale value, assuming that the present growth is detracting from
property values.
The estimated direct cost to system users is the most significant dif-
ference between the two alternatives in terms of either environmental or
social impacts. The economic impact of these costs is of most consequence
for system users in the Crystal Lake watershed. WittL the Facilities Plan
Proposed Action the 1980 average annual homeowner's cost around Crystal Lake
would be $718. This figure would drop to $610 if the 20% reserve fund were
eliminated. It would drop to $212 if both the reserve fund were eliminated
and all sewers in the watershed were determined to be eligible for Construc-
tion Grants funding. (Crystal Lake's sewers in the Facilities Plan Proposed
Action were preliminarily determined in the Draft EIS to be 40 percent
eligible. Nothing has occurred that would increase that figure).
In contrast, the 1980 average annual homeowner's cost around Crystal
Lake for the Limited Action Alternative is $95.
The impacts of these user charges can be defined in terms of the per-
centage of the population facing significant financial burdens and displace-
ment pressure. Significant financial burden is defined as a charge greater
than 1.5 to 2.5% of total income depending, the variable threshold rate being
determined by level of income. Displacement pressure is the stress placed
upon families to move away from the service area as a result of costly user
charges. It is measured by the percentage of families who would have to pay
5% or more of their income.
Table IV-1 presents the significant financial burden and displacement
pressure rates for the various user charges listed above.
"Average annual homeowner's cost" includes one residences equal share of
his community's 1980 debt retirement cost plus 1980 operating expenses plus a
reserve fund contribution of 20 percent of his debt retirement share. To
this is added an equivalent annual payment for private costs (such as house
sewers) as if they were paid at 6-7/8 percent for 30 years.
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Table IV-1
Financial Burden and Displacement Pressure of the
Facilities Plan Proposed Action and the Limited Action Alternative
Crystal Lake and Benzonia
1980 Average
Annual
Homeowner's Displacement Financial
Cost Pressure Burden
Facilities Plan Proposed Action - $ 718 50-60% 85-98%
4Q% sewer eligibility and
20% capital reserve
Facilities Plan Proposed Action - $ 610 40-50% 85-98%
40% sewer eligibility;
no capital reserve
Facilities Plan Proposed Action - $ 212 5-10% 30-40%
100% sewer eligibility;
no capital reserve
Limited Action as costed in the $ 50 1% 5-10%
Draft EIS
Limited Action as costed in the $ 95 1-5% 10-15%
Final EIS
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Comments and Responses
Substantive comments received on the Draft EIS have been compiled and
paraphrased in this section for response. The individual letters received
and those from the public hearing are reproduced following this section.
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Crystal Comments and Responses(C and R)
Water Quality
C. Several comments related to the nutrient load carried by Cold Creek into
1 Crystal Lake. The Draft EIS lacked alternatives for controlling this
single largest source of phosphorus. More generally, it failed to
examine water quality control measures unrelated to sewage treatment;
and it implied that Beulah sewers or stormwater runoff were the source
of nutrients in Cold Creek. [Pastene, Jervis, Bletcher, Manville]
R. The action which is the subject of the EIS is EPA funding of centralized
1 wastewater management facilities around Crystal Lake, in Frankfort and
in Elberta. A number of related issues emerged during preparation of
the EIS. The inventory and control of non-point nutrient sources,
especially Cold Creek, was one. However, resolution of related issues
would have required additional time and resources and might have
detracted from resolving the initial issues cited on pages 15 and 16 of
the Draft.
Cold Creek's role as the single largest phosphorus source should not
divert the reader's attention from the non-point nutrient sources found
throughout the Crystal Lake watershed. Some, like surface runoff from
forested areas, cannot be effectively reduced. Others, e.g. treatment
systems near the shoreline, can be eliminated only at great cost but
could be controlled at reasonable cost. Appendix C contains a list of
control measures immediately available to homeowners.
Another effective tool could be education of farmers and other
landowners in regard to soil erosion control and fertilizer usage. The
Northwest Michigan Regional Planning and Development Commission and the
US Soil Conservation Service offer assistance in the inventory and
control of non-point sources. Laboratory facilities built at the new
treatment plant serving Frankfort and Elberta could help in a program to
inventory and monitor non-point sources in the Crystal Lake watershed.
As discussed on page 60 of the Draft EIS, stream flow and phosphorus
data from Cold Creek indicate that non-point sources contribute much to
the stream's phosphorus load. The data do not rule out the possibility
that sources cited by Tanis (Beulah stormwater, possible sewer leaks)
also contribute.
To obtain additional data on possible Cold Creek discharges, Dr. William
Kerfoot conducted a "Septic Snooper" Survey in July 1979 from the mouth
of Cold Creek to a point north of the Cold Creek sedimentation lagoons.
At the time there were no indications that sewers crossing Cold Creek
below the settling lagoons were leaking. Readings for fluorescent
materials, however, were significantly higher along a small tributary
flowing south into Cold Creek just above the settling lagoons. The
fluorescent materials which suggest wastewater or organic decay products
could have come from abandoned soil absorption systems or the former
lumber yard east of Highway 31. The source of fluorescent materials
could have been either wastewater or organic decay products from the
lush vegetation in the area.
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C. The lack of effluent plumes along the western shore of Crystal Lake and
2 explanations of this based on groundwater outflow raise the possibility
that private wells may be contaminated by septic tanks in this area.
[Jones]
R. Outflow of lake water toward Lake Michigan was confirmed by hydrology
2 studies conducted in July 1979 after publication of the Draft EIS. It
is likely that some wells are directly down-gradient from septic tanks
and soil disposal units. Given the variable directions of groundwater
flow around the lake, there are probably more down-gradient wells in
addition to those along the western shore.
This situation does not appear to pose a problem, however. The available
well water quality data, reviewed on page 49 of the Draft EIS, show no
bacterial contamination of any wells and no higher incidence of nitrates
than in any other segment of the lakeshore. Indeed, the highest
incidence of elevated nitrates was along the north shore where
groundwater flow is predominately toward the lake.
Inspection and resampling of wells down-gradient from on-site systems or
within 50 feet of sewage disposal systems is grant eligible as part of
developing the site-specific environmental and engineering data base for
design of the EIS's recommended Limited Action Alternative. It is in-
cluded in costs for the site-by-site work in Appendix B. Use of a sep-
tic leachate detector for rapid preliminary analysis of well water
samples collected door to door is an inexpensive means for preliminary
screening for effluent presence.
Soils
C. The role of the Soil Conservation Service in evaluating lots for instal-
3 lation of on-site systems is explained by SCS's State Conservationist,
Mr. Arthur H. Cratty. SCS does not accept, reject, or permit sites for
on-site systems. SCS assists the responsible officials by providing
soils identification and soils limitations. [Cratty]
R. Comment noted. 3
C. SCS is not preparing a soil survey of Benzie County as stated on page 31
4 of the Draft EIS. [Cratty]
R. Comment noted.
4
C. The EIS should not compare soil SCS data with health department data on
5 site suitablility for septic tank systems. The section on soil and soils
limitation is not clear, not consistent and should be rewritten.
[Cratty]
R. The message of Section II.A.3.a, "Soils Suitability for Septic Tank
5 Absorption Fields", was not clearly stated, it is true. The message is
that the three sources of soil suitability information would result in
three entirely different conclusions about soil suitability for on-site
systems. Within the proposed sewer service area, SCS found all tested
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sites to have limitations such as wetness or slow percolation, or to
pose pollution hazards to shallow water supplies. If this information
were to be used as the sole basis for planning wastewater facilities
here, continued use of on-site systems would have been rejected as an
option.
Another source of information, health department permit records, indi-
cates that 56% of the sites around Crystal Lake are suitable. Comparison
of SCS and health department data was not intended to imply that either
agency was right or wrong regarding soil suitabilityonly that sole
reliance on either source would result in different conclusions.
The third source of information, data collected on actual performance of
existing systems, yields another conclusion altogether. Extensive field
work done for the EIS showed that fewer than 8% of the existing systems
around Crystal Lake have ponded or backed up more than once. A 1970
survey of 165 lakeshore wells found no bacterial contamination and only
limited amounts of nitrate. Despite the facts that more than half of
the existing systems do not comply with current design standards, that
all are located in soils with identified limitations, and that most are
inadequately maintained, nearly all are working well. The conclusion
based on performance data is that continued use of on-site systems
should not only be considered as an option but should be selected for
implementation as long as appropriate engineering and management
techniques are included.
C. In the soil studies provided by SCS, was depth to the seasonal high
6 water table determined by actual water level measurements or by inter-
pretation of soil profiles? [Jervis]
R. The data provided by SCS are reproduced here in Appendix D. Actual
6 depth to water table is provided for many sites in addition to estimated
depth to seasonal high groundwater level. The measured depth was in all
cases deeper than the seasonal water level. Please note that depth to
groundwater under the shoreline lots is directly controlled by lake
elevation which is controllable at the lake outlet.
The statement on page 34 of the Draft regarding seasonal high water
table is in error as a result of a last minute additional change. The
statement implies that all sites tested around the lake had high water
tables. Twenty-four of the 74 sites had estimated depths to seasonal
high groundwater level greater than 60 inches. The statement on page 34
should read:
"Shoreline Sites. Soil borings taken by the SCS in Autumn
1978 (by letter, R. Larson, 1 December 1978) from shoreline sites
showed that all 74 sites sampled either had limiting factors of
a seasonally high water table or slow permeability, or posed a
pollution hazard to shallow water supplies."
Field Data Collection
C. The Final EIS should include better descriptions of the Septic Snooper
7 study and the aerial photographic survey. [Bletcher; Jones]
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R. Techniques used by EPA's Environmental Photographic Interpretation
7 Center were not described in the Draft EIS. A description is provided
in Appendix A of this Final EIS. The EPIC data in Figure 11-15 of the
Draft EIS did not include the malfunction data. The revised Figure 1-3
included in Section I.C. of this Final EIS shows the locations of
suspected and confirmed malfunctions.
The methods used for the Septic Snooper study are presented in Appendix
C of the Draft EIS. It is sufficiently detailed for the intended audi-
ence of the EIS--municipal officials, state and Federal decisionmakers,
and the public.
All readers should know that the use of septic leachate detectors such
as ENDECO's Septic Leachate Detector is still experimental. Technical
questions have yet to be fully resolved concerning the universal pre-
sence of brighteners and whiteners in wastewater from individual homes,
the effects on plume strength of fluorescent compound absorption by
different soils, the effects of plume configuration on plume
detectability and correlations between plume strength and nutrient
break-through. EPA is conducting additional research on these topics to
improve both the applicability of the equipment and interpretation of
the data it generates.
Readers should also understand that EPA's conclusion on the acceptabi-
lity of continued use of on-site systems is based on many sources of the
data, not just the Septic Leachate Detector. The Detector is just
thatit locates plumes for sampling by conventional methods. It was
not used in the EIS process in any other way then to locate individual
plumes.
C. EPA and Michigan Department of Natural Resources use different assump-
8 tions regarding phosphorus input to lakes from shoreline septic tank
systems. The difference in loading could be high in some cases.
[Czuprenski]
R. Both agencies' methods use assumptions which will seldom, if ever, be
8 valid for all lakes or for all dwellings around a lake. For instance,
both methods assume that effluents from all lakeshore dwellings will
reach the lake. The Septic Snooper studies on Crystal Lake and 34 other
glacial lakes in EPA Region V show that this is not the case except in
very unusual situations. The results from both methods are, therefore,
likely to be conservatively high.
Another important assumption is the breakthrough rate, i.e. the per-
centage of phosphorus discharged from any system to the soil which will
end up in a lake. The EPA National Eutrophication Survey used a loading
of 0.25 Ib./capita/year, equivalent to about 8% breakthrough. According
to the commentor, Michigan DNR bases breakthrough on the phosphorus
absorbing capacity of local soils. The commentor cited a figure of 45%
for soils in Oakland County.
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While the Michigan DNR method incorporates at least some locally rele-
vant data, neither method provides more than a rough, conservatively
high estimate of septic tank loading to lakes. In many planning situa-
tions, an estimate by either method may suffice. However, when expen-
sive engineering or management decisions rest on such estimates, the
decision maker should get local field verification of the assumptions,
and not fret over the superiority of one agency's assumptions over
another's.
Appropriate field verification methods are being developed and demon-
strated by EPA. As mentioned above, several studies designed to resolve
technical questions regarding effluent plume detection are planned for
spring and summer 1980. A new technique to better determine the
strength and configuration of subsurface plumes at the shoreline is also
going to be evaluated.
C. Did the aerial photographic survey performed in summer 1978 by EPIC miss
9 surface malfunctions because of foliage? [Jones]
R. The draft EIS noted this possibility. Whether there were any
9 other malfunctions active at the time of the overflights cannot be
accurately assessed.
The commentor implied, as others have directly stated, that summer is
not the best time of year for this type of survey. This is true for two
reasonsthe possible interference by foliage and the higher like-lihood
of surface failures in spring. Optimal timing of this and other field
studies was not feasible.
C. The sanitary survey was conducted during September and October when few
10 of the seasonal residents would have been occupying their dwellings. The
survey should have been conducted during summer months. [Jones]
R. The best time to conduct a sanitary survey in a recreational community
10 is early summer when evidence of temporary (spring) malfunctions would
still be apparent and when the greatest number of residences will be
occupied.
It is not true that few seasonal residents were surveyed. In the Draft
EIS page 5 of Appendix F-l states: "Although the survey took place in
October, seventy-six percent of the homes surveyed were seasonal, i.e.,
used less than ten months of the year..." How many of these "seasonal
residences" are used only during summer was not stated.
Alternatives
C. Engineers felt that costs estimates for various facilities were too low
11 and that the level of design detail for the EIS alternatives was not
comparable to what is expected in a facilities plan. [Force, Jones,
DPW]
R. EPA recognizes that the level of detail in design and costing used in
11 preparing the EIS is not as refined as may be expected by the state,
especially for a selected alternative. The costs also do not reflect
the highly inflated costs of centralized facilities in Michigan.
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However, the costing methods used were consistent from one alternative
to the other. The cost rankings of the EIS alternatives and of the
Facility Plan Proposed Action as recosted for the EIS are unlikely to
change. EPA feels that no amount of increased design and costing effort
is going to change the basic conclusion that continued use of on-site
systems in the Crystal Lake area is cost-effective compared with cen-
tralized systems.
C. Specific questions were raised regarding the cost of detailed site
12 evaluation, operation and maintenance, and cluster system construction.
All of these comments suggested that the present worth of the recom-
mended Limited Action Alternative as presented in the Draft EIS is low.
[Jones, Force, DPW]
R. Lacking any cost data based on experience, the Draft EIS assumed that
12 the 25% engineering and legal contingency rate used for conventional
sewerage facilities could also be applied to the Limited Action
Alternative. While there are still no hard data available, a more
detailed estimate has been made of the costs for a detailed site
evaluation. This would constitute the largest part of contingency costs
for the Limited Action Alternative. Assuming the 1384 unsewered
build-ings in the Proposed Service area surrounding Crystal Lake would
be sur-veyed, the site evaluation cost is estimated at $501,700. See
Appendix B for details and assumptions. This compares to $321,000 for
the 25% contingency factor on the construction of on-lot repairs and
cluster systems in the Limited Action Alternative.
Operation and maintenance costs for unsewered areas were based in the
Draft EIS on information provided by decentralized facilities management
agencies in California and Washington. These agencies reported varying
levels of services and costs. From the agency information, $30 was
selected as the cost for inspection and administration. $50 every five
years for septic tank pumping was selected for O&M of on-site systems.
More detailed estimates have been prepared since publication of the
Draft EIS. The new details and assumptions are presented in Appendix B.
These conservatively high estimates result in a 1980 O&M of about $81
per year per household compared to $40 per year with the O&M assumptions
used in Draft EIS.
Construction costs for cluster systems were based on assumptions that
were felt to be valid for their intended use in the Crystal Lake area.
These assumptions include moderate housing density (75* road frontage on
one side of a road) and close proximity of suitable soils. Any number
of factors can be suggested which would result in higher costs per
household. However, until the need for off-site treatment is demon-
strated on a site specific basis, and actual field data are available
for cluster system design, revision of the cluster system costs is
unfounded. The revised cost estimates for detailed site evaluations and
O&M will increase the costs of the Limited Action Alternative above
those presented in the Draft EIS. The present worth increases from
7,218,100 to $7,887,200 or 9%. (Please note that the present worth of
the Limited Action Alternative was over estimated by $231,100 because
the salvage value of future on-site systems was calculated improperly.)
45
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Average annual local costs for Crystal Lake households would increa.se
from $49 per year to $95 per year.
Please note that the proper performance of cluster systems is dependent
not only on careful construction, like any on-site system, but also on
quality of actual materials operating experience in the rest of the
country suggests that septic tank effluent pumps should probably have
rotors and fittings of at least "300" grade stainless steel.
By comparison, if all Facility Plan sewers around Crystal Lake were
eligible (the Draft EIS estimated 40% eligiblity), the average annual
local costs for Crystal Lake households would be $273 including a 20%
capital resource contribution, approximately three times the
re-estimated household cost for the Limited Action Alternative.
C. A more detailed breakdown of the assumptions and costs of the Limited
13 Action Alternative including future costs should be provided. [Jones]
R. This information is presented in Appendix B and summarized in the text
13 of this Final EIS.
C. The reliability of on-site and cluster systems cannot be determined and
14 does not provide a long-term solution to wastewater needs in the Crystal
Lake watershed. [Force, Jones]
R. There is sufficient information on the condition and effects of the
14 existing on-site systems to predict that their continued use in most
areas around Crystal Lake will be acceptable for years to come. The
existing systems are up to 50 years old; many are undersized and poorly
maintained. Yet the failure rate is low at present and can be reduced
even further and kept at very low levels with the procedures recommended
for the Limited Action Alternative.
The Draft and Final EIS's recognize that some segments and individual
homes may not be upgradeable to provide reliable wastewater treatment.
Costs for the Limited Action Alternative, therefore, include six cluster
systems to serve 125 residences. An inspection of possible cluster
system sites was requested of and provided by the Soil Conservation
Service. Detailed hydrogeologic investigations of any proposed cluster
system sites will be required prior to approval and installation.
Three key requirements for maximizing the reliability and
cost-effectiveness of the Limited Action Alternative are:
Selection of appropriate technologies for each home based upon
well-planned and executed site analysis;
Provision of adequate community supervision of all wastewater
facilities; and
Measurement of and designing with the natural assimilative
capacity of local soil/groundwater/surface water resources.
46
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The Limited Action Alternative may not be the optimal solution for
Crystal Lake beyond the year 2000. Housing density, demands for com-
mercial development and difficult on-site system problems could increase
to the point that centralized treatment becomes economically justifi-
able. If and when that point will be reached cannot be predicted.
EPA's judgment, based on a considerable amount of data which will be
tested and augmented by the site specific evaluations, is that the point
has not been reached yet and will not be reached within the next 20
years and perhaps, never.
C. A cost-effective analysis of septage disposal options was not presented
15 in the Draft EIS. [Force, Jones]
R. Again, the EIS's level of detail in design and costing was not intended
15 to satisfy all facilities planning requirements.
The need for proper disposal of septage and two disposal options appro-
priate for different EIS alternatives were discussed on page 117 of the
Draft EIS. In alternatives which involve use of septic tanks, pumping
once every five years at a cost of $50 per pump was included in the
cost-effectiveness analyses. This cost includes $15 for either land
application or treatment in the Frankfort-Elberta STP. Selection of
this cost was based upon a review of literature dealing with septage
disposal.
C. The Draft EIS's estimated cost for a 0.32 mgd wastewater treatment plant
16 at Frankfort is low. EPA should prepare a revised cost estimate based
on 1979 bids for similar work in Michigan. [Force]
R. The commentor's analysis of this cost is based on a Facility Plan esti-
16 mate of $2,746,000 for a 0.32 mgd treatment plant. The Facility Plan,
however, shows a 0.44 mgd plant for this price (Alternative 4, pages
6-24 of the Facility Plan).
Treatment plant costs in the Draft EIS were based on a combination of
EPA cost curve data for small treatment plants and data from the Facili-
ty Plan. Costing procedures were the same for all alternatives.
This comment raises an issue which was not addressed in the EIS--the
unusually high costs of wastewater facilities in Michigan. Unofficial
comments have been made that use of cost curve data is not valid for
Michigan projects because of locally inflated prices. To the extent
that this is true, decentralized facilities may save even more than
estimated in the Draft EIS.
IMPLEMENTATION
C. The Draft EIS does not provide sufficient information concerning the
17 number of on-site systems needed to prepare a true cost-effectiveness
analysis of the recommended Limited Action Alternative. The Draft EIS
recommended that the detailed site evaluations for Crystal Lake be
prepared in Step 2 of the Construction Grants sequence. These evalua-
47
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tions are necessary for proper cost-effectiveness analysis and should,
therefore, be done in Step 1. It is recommended that the evaluations be
conducted prior to finalization of the EIS. [Hinschon, Jones]
R. The data collected on Crystal Lake's on-site systems is more extensive
17 than is ever available for communities of this size. EPA recognizes
that additional observation and analysis of these systems may alter our
understanding of their use and their effects on the environment. How-
ever, it is the Agency's judgment that changes, based upon new data,
in the recommendation for Limited Action will be changes in detail, not
in concept. The Agency is prepared to fund 85% of the detailed site
evaluation as a Step 2 grant (75% if conducted with a Step 1 grant) in
order to, first, provide necessary information for site specific facili-
ties design and, second, verify or modify our conclusion that continued
use of on-site systems will be environmentally acceptable in the Study
Area.
The Agency feels that the alternatives' cost estimates are presented in
sufficient detail to determine cost-effectiveness. For those alterna-
tives which include continued use of on-site systems (EIS Alternatives
3-6 and the Limited Action Alternative), factors subject to uncer-
tainty were estimated conservatively high, especially the percent re-
placement of septic tanks and drainfields. In addition, costs for
operation and maintenance and for the site specific analysis have been
reexamined for this Final EIS in more detail and with conservative esti-
mates. (See Comments and Responses on Alternatives.) Boosting these
cost estimates has made no difference in the ranking of the recom-
mended Limited Action Alternative. It appears unlikely that additional
improvements in the cost estimates based on actual designs will alter
the rankings either.
To clarify the site-specific work needed in Step 1 or Step 2, EPA Region
V prepared a memorandum clarifying needs documentation procedures.
(Appendix E.) The great majority of any such work should take place in
Step 2.
For these reasons and because of the 50% savings to the applicant, EPA
will fund the site specific evaluation as a Step 2 grant.
C. The Draft EIS does not indicate whether EPA's requirements for justifi-
18 cation of advanced secondary treatment at the Frankfort-Elberta plant
have been met. [Force]
R. In the past three months, the Michigan Department of Natural Resources
18 has revised effluent standards for discharge to Betsie Lake. Instead
of a BOD limit of 10 mg/1 and suspended solids limit of 10 mg/1, sec-
ondary treatment (30 mg/1 BOD and 30 mg/1 suspended solids) will be
allowed. Michigan DNR's correspondence on this is included as Appendix
F.
The large reduction in phosphorus load to Betsie Lake that would result
from chemical additions and filtering of the Frankfort-Elberta plant's
48
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effluent was discussed in the Draft EIS. The phosphorus limitation
of 1 mg/1 is predicted to improve the trophic status of Betsie Lake.
Chemical additions to the effluent for phosphorus removal will have
the side benefit of reducing BOD and suspended solids below 30 mg/1 BOD
and 30 mg/1 suspended solids under most operating conditions.
The change in BOD and suspended solids limitations removes the need
for final filtration of the effluent. The microscreen proposed in the
Facility Plan and adopted in the EIS for the Frankfort-Elberta plant
is, therefore, not necessary. The microscreen would reduce the effluent
phosphorus concentration from 1 mg/1 but the expense is not justified by
the 3% lake load reduction.
C. Division of the project into two parts, a municipal treatment project
19 and a rural lake project, may jeopardize solution of Crystal Lake's
water quality problems because the latter are less obvious and more
difficult of solution. [Bletcher]
R. Michigan DNR has informed EPA that the two pro-
19 jects have been assigned new priority numbers and that both are high
enough to receive additional funding without delay.
C. The Michigan Environmental Review Board adopted the Draft EIS with the
20 proviso that the planning for the Village of Beulah be coordinated with
the study for the Crystal Lake Area. The President of the Village of
Beulah, however, has clearly stated that the Village will not partici-
pate in any future projects elsewhere around Crystal Lake. [Env. Review
Board, Michigan Environmental Board Manville]
R. In the recommended Limited Action Alternative there is the possibility
20 that detailed site analysis and geohydrologic studies will show sewering
the northeast and southeast shores of Crystal Lake to the Beulah system
to be the optimum solution for these identified problem areas. Because
of this possibility, it is hoped that the Benzie County Department of
Public Works and the Village will maintain a cooperative relationship.
Based upon the fact that the Beulah treatment and disposal lagoons have
been hydraulically overloaded in the past, they probably could not
handle the additional flows without upgrading the lagoon system.
C. Two comments dealt with the legal authority for establishment of an
21 entity to provide the community supervision of decentralized facilities.
One cited the relevant Michigan Public Acts (40, 185, and 342) and
the Michigan Public Health Code as providing necessary mechanisms for
a small waste flows district. The other stated that Michigan has no
statute authorizing units of local government to manage waste facilities
other than those connected to conventional collection systems, but then
concluded that a special management agency is not really necessary for
upgrading and maintaining on-site systems. [Jones, DPW, Intercom]
49
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R. The 1976 study by Otis and Stewart indicated sufficient management
authority already existed under Michigan law. Preliminary legal surveys
by a number of the 208 region water quality management agencies indi-
cated that authority to manage decentralized wastewater treatment sys-
tems. Preliminary discussions with Michigan DNR staff and the Michigan
Attorney General's office suggests that existing public health and
police powers allow a county to obtain access and maintenance authority
by passage of a county ordinance; a written Attorney General's opinion
is being requested to clarify this portion of the question. In addition
Concerns about legal authority and interagency conflicts were raised in
the Draft EIS. Several questions relevant to local options were posed
on page 141 of the Draft EIS. A sequence of steps, including a broad
outline on management organization design, was also presented.
EPA is reluctant to recommend specific resolutions for these concerns
because so many management options are available. Local citizens
and elected officials should evaluate, decide on one and implement it at
their own initiative.
There was nothing explicitly stated in the Draft EIS about a new agency.
Depending on the results of the site specific evaluation, the actual
wastewater technologies selected, identification of functions to be
provided and analysis of the capabilities of existing organizations, it
may well be that the only legal instrument needed is a memorandum of
understanding between the Benzie County Department of Public Works and
the Grand Traverse-Leelanau-Benzie District Health Department and a
contract with Frankfort for water sample analysis at the new treatment
plant's laboratory.
Included in II.B.2. is a discussion of three possible levels of manage-
ment approach possible for Crystal Lake water quality and wastewater
treatment management. While EPA can recommend an approach, final selec-
tion of any one or a combination of these is up to the applicant.
On the other hand, it might also turn out that difficult legal, juris-
dictional and personnel problems will be encountered. It is unlikely
that such problems will be unique to Crystal Lake or to Michigan. EPA
wishes to encourage the spirit expressed by one of the commentors:
"...if we must do it first at Crystal Lake, then let it be here." EPA
believes it can be done, that the benefits are worth the cost and that
Crystal Lake is an excellent place to start.
C. Another potential problem, cited by the applicant, is the possibility of
22 jurisdictional conflicts with the Tri-County Health Department. [DPW]
R. The health department should be a valuable resource in terms of legal
authority and technical expertise.
Present State health department policies, as expressed in response to
the Draft EIS for a similar project in Emmet County, are dependent on
State codes and standards. The approach proposed in the Limited Action
Alternative is dependent on local data regarding performance of existing
50
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systems. The State's approach is entirely appropriate as a basis for
permitting on-site systems for new buildings. State and local health
authorities may exercise whatever constraints they are legally enabled
to use in order to minimize the somewhat unpredictable public health
and economic risks resulting from system failure. In the case of exist-
ing on-site systems, the risks, including the economic risk of building
a new sewer system, can be quantified by direct measurement and objec-
tive environmental and engineering analysis. We believe we have used
the latter approach in the Draft EIS and recommend it to the applicant
and other interested parties when considering the fate of either indi-
vidual on-site systems or an entire community of them.
C. Seasonally used, privately owned on-site systems do not qualify for
23 Federal grants for repair, renovation or replacement. Since the popula-
tion along the shoreline of Crystal Lake consists mainly of seasonal
residents, Federal assistance may not contribute to correcting existing
problems. [Intercom]
R. About the same time that the Draft EIS went to press, EPA Headquarters
23 issued Program Requirements Memorandum 79-8, which states:
Perpetual or life-of-project easements or other binding
covenant running with the land affording complete access
to and control of wastewater treatment works on private
property are tantamount to ownership of such works.
Therefore, seasonally used, privately owned on-site systems can qualify
for funding.
C. Easements must be obtained for both publicly and privately owned systems
24 giving the Department of Public Works access for inspection and main-
tenance. Some property owners may not voluntarily grant these, particu-
larly where cluster system drainfields are concerned. [Intercom, DPW,
Jones]
R. The access issue can be discussed for three cases: on-site systems for
24 which access is voluntarily granted by the property owner; on-site sys-
tems for which access is not voluntarily granted by the property owners;
and off-site systems.
The legal authority of the Benzie County Department of Public Works to
enter into voluntary easement agreements is the same as that of any
other person, corporation or public body to enter into a contract. The
DPW can maximize cooperation from homeowners and landowners by setting
up and advertising standard operating procedures so that individuals
know what to expect. For routine operations such as septic tank pump-
ing, inspecting the drainfield area or drawing well water samples, a
guarantee that adequate notification will be provided would reduce anxi-
eties about infringement on privacy. For emergency operations, suitable
procedures could be established.
Despite the community and private benefits of having community supervi-
sion of on-site systems, some property owners may not want to partici-
pate in the "system."
51
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First, these owners can be excluded from receiving the services of the
DPW. When and if their on-site facilities fail, repair or replacement
would be at their own initiative and expense. As is currently the prac-
tice for low-lying lots around Crystal Lake, the health department may
automatically require installation of a holding tank. One problem with
this response is that, without periodic inspection and monitoring, fu-
ture failures may go undetected for long periods. Complaints from
neighbors or self-reporting would be the only means of detection.
Another response might be to require all buildings within the DPWs ser-
vice area to participate and grant easements. If the DPW were to oper-
ate a gravity sewer system, there would be no question about legal au-
thority to require hooking up. However, gravity sewer systems do riot
require permanent easements. This difference is the basis for question-
ing the legal authority of public bodies to provide small flows manage-
ment (See previous Comment and Response). This legal issue would have
to be resolved if the DPW opts for mandatory participation.
The acquisition of property rights, either by ownership or easement, to
land for off-site treatment facilities is legally comparable to acquir-
ing property for gravity sewers. Taking of property from owners who may
not benefit from the new facilities should be carefully weighed against
the need for the facilities and the possibility of using alternatives
that might burden the benefitted owners instead. Because of property
rights issues and cost, off-site treatment, such as by cluster systems,
is not a panacea for every difficult on-site problem but should be
viewed as a technology available for use where on-site measures prove to
be unfeasible or prohibitively expensive.
The mechanics of acquiring voluntary on-site easements have been ex-
plored by local citizens and EPA. A sample easement form has been
prepared by and is included here as Appendix G. Completion of easements
on a segment-by-segment basis, starting with the segments appearing to
have the most serious problems, has been suggested as a way to expedite
the Construction Grants process for Crystal Lake. The cost estimate in
Appendix B for the site specific analysis includes time in the initial
sanitary survey for introduction of the easement forms
and discussion of easement requirements.
In other states, existing public health and regulatory powers have
allowed counties to pass laws giving sanitarians or small waste flows
districts access to all on-site systems and authority to require repair
and upgrading. To a considerable extent these powers are already exer-
cised by local sanitarians in Michigan. EPA Headquarters has indicated
that such a law would be the kind of binding commitment tantamount to
public ownership, and that if this were done, no easements at all might
be required. Development of a way to do this might be an important re-
sult of DPW cooperation with the health department. Preliminary dis-
cussion with Michigan DNR and the Attorny General's staff suggests that
existing police and public health powers are sufficient to allow passage
of such a county law. An Attorney General's opinion is being requested.
C. Administration and management of the Limited Action Alternative means
25 more government intrusion in people's personal lives. [DPW]
52
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R. The issue of privacy was not addressed in the Draft EIS but is certain
25 to be of interest to homeowners and tenants. A discussion of privacy
is presented here to stimulate consideration of means to maximize pri-
vacy while still meeting the environmental goals of the Limited Action
Alternative. The Benzie County Department of Public Works in making
this comment has demonstrated its sensitivity to this issue.
The amount of money they must pay for wastewater treatment, in whatever
form, could be considered one measure of intrusion into peoples lives.
On this basis the Limited Action Alternative is less of an intrusion
than any alternative except No Action.
For the resident whose on-site system is causing no problems and meets
current design standards, short term intrusions will include a one or
two hour interview and site inspection during the site specific evalua-
tion and possibly a return visit for well water sampling. Continuing
intrusions would include periodic (one to three years) site inspections
by a surveyor, routine septic tank pumping every two to five years and,
for lake shore dwellings, possible groundwater and surface water moni-
toring activities along their beach. Some of these residents may be re-
quested to allow well sampling at the same time as the site inspection.
As with other intrusions discussed below, notifying the resident in some
way such as by newspaper notices, citizen's group activities, or mail
can minimize the effect of these intrusions.
For certain of the systems needing repair, replacement, or upgrading,
continuing intrusions would also be greater than with properly designed
and operating systems. On-site pumping units need inspection and main-
tenance perhaps once or twice per year. If water flows must be metered
for hydraulically limited systems, meter readers would enter the pre-
mises perhaps once per quarter. However, the effect would in these few
cases be no worse than construction of the house sewer and gravity sewer
required for a centralized sewerage system. In general, continuing
intrusions will be related to the complexity of the facilities necessary
to deal with site limitations; the more complex the facilities, the more
maintenance would be required.
Intrusions will be greatest for residences required to install holding
tanks. Visits by the pump truck can be embarassing as well as disturb-
ing. This (as well as nuisances and costs) can be minimized by con-
structing holding tanks with hopper bottoms and riser pipes with quick-
lock fittings and by installing flow reduction devices in the house, as
described on pages 100 and 101 of the Draft EIS.
Economic Impacts
C. The Department of Public Works will recover the local costs of the pro-
26 ject from those directly benefitting. A general tax on the entire
County is inappropriate, even though a significant part of the County
economy depends on maintaining the quality of Crystal Lake. [DPW]
R. This comment was made by the Department of Public Works. It is noted.
26
53
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C. Equitable user charges will be difficult to determine and apply. [DPW]
27
R. Establishing a user charge system should be an element in the complex
27 process of designing the "agency." EPA is preparing detailed discus-
sions of agency design and user charge systems as part of a Generic
EIS for Wastewater Management in Rural Lake Areas. The drafts of these
reports are scheduled to be completed by December 1980.
One single system could be developed based upon one assumption (that no
one pays for any service or improvement not actually reviewed) and one
local decision (should local share of capital costs be paid immediately,
or authorized over an extended period, or left to the individual home-
owner to choose?). This would result in the following rate categories:
a. No construction needed - operation and maintenance (O&M) only
(inspection & pumping).
b. On-site w. construction - O&M plus local share of capital costs, if
authorized.
c. Clusters: Different O&M, plus local share of capital costs, if
authorized.
Future needs might move a resident from one of these categories to
another.
C. The $50 annual user charge is grossly underestimated. [Jones]
28
R. Two shortcomings in the cost figures for the Limited Action Alternative
28 have been recognized and addressed above. These two are the cost of the
site specific analysis, and annual operation and maintenance. Conserva-
tively high estimates of these costs raise the 1980 individual dwell-
ings' average annual local cost to $95. This figures assumes amortiza-
tion of the local share of capital costs.
C. These user charges do not take into account service to be provided to
29 vacant lot owners for wastewater management in the future. [Jones]
R. It is not clear whether this comment, made by the same commentor as
29 above, refers to the Draft EIS estimate or his own of $250 per year.
The present worth of all EIS alternatives include the construction and
operation and maintenance costs for any future systems needed to serve
the design population. The local costs were calculated only for the
initial year of operation. Per household O&M costs are expected to
decline somewhat over the next 20 years because of new residents sharing
in the fixed O&M costs. The local costs estimates include a 20% reserve
fund. This would be insufficient to fund the construction of wastewater
systems for new buildings but could be used to repair existing systems
in the future as needed.
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C. The Limited Action Alternative has shifted the cost burden from immedi-
30 ate capital cost (for sewers), which are grant eligible, to operation,
maintenance, monitoring, and replacement costs which are perpetual and
are not grant eligible. [Jones]
R. This is true. The Limited Action Alternative also removes a subsidy for
30 future development that would be funded by the nation, the State and
local citizens. This subsidy can be reinstated by local government by
charging $250 per year user charges as suggested by this commentor.
This will provide about $215,000 per year for DPW to build "free" on-
site and off-site systems for new residents. This amount be would more
than adequate to build systems for increased population projected.
It is highly unlikely, however, that the DPW would do such a thing. It
is more likely that DPW will provide design and construction supervision
services out of its O&M budget and leave construction costs to the
builder as has been the practice in rural areas for 200 years.
Because there is expected to be no subsidy for future development,
existing residents will have a smaller future burden than new residents.
In addition to whatever portion of their mortgage payments is for pur-
chases of their existing systems, existing residents will pay an average
of $95 per year, including $81 O&M and $14 debt retirement and capital
reserve. Since they will continue to pay the same mortgage with or
without sewers, only the $95 charge is attributed to the Limited Action
Alternative.
On the average the future resident will have capital cost of $1,300 more
than if sewers were available ($2,300 for the average on-site system
minus $1,000 that would be paid for a new house sewer). With a 12%,
30-year mortgage, his annual cost would be $161 plus $81 for O&M, or
$242 total. This is still at least $30 per year cheaper than with a
fully grant eligible sewer system.
C. The Draft EIS uses county-wide data to discuss employment and income
31 data of the Proposed Service Area population. [Jones]
R. Problems with the applicability of available socioeconomic data to both
31 the EIS Study Area and the Proposed Service Area are clearly stated on
page 84 of the Draft EIS. The almost complete lack of employment and
income data for the seasonal population is stated on page 88.
The only accurate way to acquire this type of data is by a special
census. This obviously was not conducted for this EIS. In addition,
the Office of Management and Budget (OMB) in Circular A-40 requires
prior approval of any information-gathering by Federal agencies contact-
ing more than 9 people. OMB approval time is currently more than 18
months. EPA will be considering the advisability of funding special
surveys for other rural wastewater projects.
55
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Recreation
C. Consideration should be given to any recreation benefits which might
32 be derived from the project. [Jervis]
R. When the Facility Plan was published in 1976, applicants for construc-
32 tion grants were not required to identify potential recreational oppor-
tunity deriving from Federally funded wastewater facilities. Recrea-
tional opportunities are not an issue of this EIS.
The Clean Water Act of 1977 and regulations implementating the Act
require consideration of open space and recreational opportunities of
Federally funded wastewater facilities. Future grants for both the
Frankfort-Elberta project and the Crystal Lake project will include the
requirement to do so. Particular opportunities to be addressed include
use of the abandoned Frankfort treatment plant structures in conjunction
with the adjacent Mineral Springs Park, perhaps as a nature education
facility. Both active and passive uses of cluster system sites should
also be addressed.
C. Mineral Springs Park and Marina, Benzonia Kiwanis Park and Betsie River
33 Access are three Federally funded park facilities in the Study Area.
Any modifications of these parklands will require review of the action
in accordance with the Land and Water Conservation Fund Act. [Jervis]
R. Comment noted. This will also be incorporated as a grant condition.
33 There is, however, no indication that any such modification is likely.
Archaeology
C. An archaeological survey of any sites that may be disturbed by the
34 recommended alternative should be included in the Final EIS. [Jervis]
R. Only a few specific portions of the Limited Action Alternative have even
34 the potential for archaeological impacts. There are several reasons for
this:
1) The Frankfort and Eberta sewer systems has already been constructed.
2) Almost all of the present Crystal Lake shoreline was submerged
before 1873.
3) On-site system locations have already been disturbed.
The areas of possible concern are those away from the lake, notably the
sites of the cluster system filter fields. When the preliminary loca-
tion of these filter fields has been decided an archaelogical survey
will be performed. Should any sites of interest be found, the fields
or other contributions will be relocated. All contributions will avoid
the four identified archaelogical sites described on page 96 of the
Draft EIS.
56
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The EIS Process
C. The National Environmental Policy Act has been misapplied by EPA and has
35 become a facilities planning task performed at the Federal level rather
than an evaluation of the selected alternative contained in the original
Facility Plan. This is a serious encroachment on the rights and
duties of the local and state government agencies, responsible under the
Clean Water Act and EPA regulations for facilities planning. [Bletcher,
Hinschon]
R. Nothing in NEPA limits the government to evaluation of a selected alter-
35 native in an EIS. Section 102. C. iii specifically includes "alter-
natives to the proposed action" as a part of every EIS. The most recent
EPA and CEQ guidelines for preparation of EISs pointedly emphasize the
importance of evaluating alternatives. Alternatives to be considered
are not limited to those administrative alternatives (i.e. grant or
no grant) available to the Federal agency preparing an EIS. Any measure
which insure that the purposes of NEPA are recognized in Federal deci-
sionmaking can and should be considered in an EIS. USEPA would be of
little use if it did not consider all alternatives that might work well.
As to encroachment on state and local agencies, both the State of
Michigan and Benzie County requested that this EIS be prepared. Indeed,
the State has strongly encouraged a Facility Plan level of alternative
development.
C. The public participation program for this EIS has not been in accordance
36 with EPA'S own standards. [Bletcher]
R. The public participation program has substantially exceeded the stand-
36 ards in effect while the EIS was being prepared. Public participation
has included three public meetings, including a hearing attended by over
20% of all area residents; attendance at more than eight open meetings
of applicant agencies with question-and-answer sessions; radio and news-
paper interviews, circulation of 600 copies of the draft EIS; and an EIS
newsletter running from January 1978 to September 1979. In 1979 USEPA
issued guidelines for an expanded public participation program for EIS's
completed several months after Crystal Lake. Many elements of these
guidelines were already incorporated in the Crystal Lake project. It
is, however, not possible or desirable, to retrace work already alone in
order to retroactively apply a few portions of the new guidelines.
C. The Draft EIS fails to meet minimal EPA and CEQ requirements.
37 [Bletcher]
R. As was the case with public participation, new EPA and CEQ guidelines
37 went into effect after the completion of the Draft EIS. Again, many
elements of these (concise issue-oriented format, reduced number of
pages) were incorporated in the Draft as a matter of common sense.
Others like the inclusion of an index have not been.
C. The EIS is inconsistent in evaluating the alternatives using one set of
38 standards for decentralized alternatives and another for centralized
alternatives. [Hinschon]
57
-------
R. The only intentional biases in the comparison have to do with fund-
38 ing and eligibility. In the Clean Water Act of 1977, the US Congress
encouraged the implementation of alternative wastewater management
technologies. One of the encouragements is an increase in the Federal
share from 75 to 85%. This was incorporated in the local cost
comparison of the alternatives.
The eligibility of sewers in the centralized alternatives (EIS Alterna-
tives 1 and 2 and Facility Plan Proposed Action) was determined on a
preliminary basis to be 40% of estimated capital cost while 100% of the
decentralized facilities were considered to be eligible. This also
biases the local costs in favor of the decentralized facilities. The
sewer eligibility determination was made in accordance with present EPA
policy on the funding of collector sewers and with input from the State
of Michigan.
It is worthwhile to note that, for Crystal Lake residents, the 1980
average annual household costs at 75% funding and 100% eligibility
would be $273 for a sewer and $109 for the recommended Limited Action
Alternative.
C. The Draft EIS contains three different population projections for the
39 area under different proposals. The State's understanding of population
projections under the 201 program is that the number of people to be
living in an area in 20 years is estimated and then alternative ways
of addressing their needs are developed. [Hinschon, Force]
R. For the cost-effectiveness of the alternatives in the Draft EIS, one
39 population projection was used. This was stated at least twice - on
Pages 99 and 121.
The Draft also recognized that the type of sewer service provided may
constrain growth below the projected level or stimulate it above.
Therefore, Section IV.C, Population and Land Use Impacts, estimates
the impacts on population of centralized and decentralized facilities.
C. The EIS leads one to understand that more people will automatically
40 locate in the Proposed Service Area when sewers or central collection
facilities are provided. This seems to ignore all other factors in-
volved in projecting population including employment, the energy situa-
tion, etc. [Hinschon]
R. Some large urban areas of this country offer data sufficient to develop
40 an econometric model of population growth. This is not so for rural
areas. This does not mean that the factors which will affect rural
population growth are not complex. It means that they cannot be com-
plexly analyzed and projected with data available.
The Draft EIS based its quantification of population impacts of waste-
water facilities upon the amount of developable land and the density
possible with and without centralized sewers.
58
-------
C. The EIS does not address the possibility of the No Action Alternative
41 for the Crystal Lake area. [Hinschon]
R. An expanded consideration of No Action Alternative costs and impacts is
included in Chapter III. Additional needs documentation included the
aquatic productivity studies on five sample sites, the groundwater flow
survey, and fluorescent scanning of Cold Creek.
59
-------
Comment Letters
61
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
NORTH CENTRAL REGION
175 WEST JACKSON BOULEVARD
CHICAGO, ILLINOIS 00604
August 24, 1979
Mr. John McGuire, Regional Administrator
U.S. Environmental Protection Agency
230 S. Dearborn Street
Chicago, Illinois 60604
Dear Mr. McGuire:
We have reviewed the draft Environmental Impact Statement (DEIS) for
Alternative Waste Systems for Rural Lake Projects, Crystal Lake Area
Sewage Disposal Authority, Benzie County, Michigan, for compliance with
the provisions of the Fish and Wildlife Coordination Act (48 Stat. 401,
as amended; 16 U.S.C. 661 et seq.) and the intent of the National Environ-
mental Policy Act of 1969. The document is well prepared; however,
there are certain areas which need clarification.
We support the recommended alternative (Limited Action) involving upgrading
of on-lot systems where feasible and the collection and upgrading of
treatment at Frankfort and Elberta.
It is not clear from the discussion of the suitability of the soils (p-6)
for onsite waste-disposal systems (e.g., p. 34) whether actual water-
level measurements have been made or whether conclusions are based on
soil profiles alone. Inclusion of a few representative measurements
might improve the assessment.
Michigan Planning Region 10, including Benzie County, exhibits a low (R-32)
level of need for local facilities as shown in Table 14, page 41, of
the 1979 Michigan Recreation Plan (unpublished draft). However, the
plan does specify on page 95 that:
Local governments should consider providing recreation opportunities
on wastewater treatment plant sites, sewage interceptor rights
of way and other related properties and facilities. The Department
of Natural Resources funding program for construction of water
management facilities presents opportunities to develop recreation
uses at little or no additional cost. The department will continue
to encourage this through grants administration and facility design
review.
-------
- 2 -
This is in harmony with Section 201(f) of the Clean Water Act which
encourages "waste treatment management which combines 'open space' and
recreational considerations with such management."
Region 10 is an important destination area for recreationists from southern
populous regions. This is verified by the report, "Recreation by Michigan
Residents - Planning Region 10," a supporting document of the 1979 Michigan
Recreation Plan. This report shows a substantial net "import" of recreation
participations into Region 10. For this reason, and in harmony with
the Clean Water Act and the recommendation cited above, we urge the
project sponsor to give consideration to any recreation benefits which
might be derived from the project.
(P-32)
The study area includes three parks that have received Land and Water
Conservation Fund (LWCF) assistance - Mineral Springs Park and Marina
(Projects 26 - 00126, 741, 893, and 1017) administered by the City of
Frankfort, Benzonia Kiwanis Park (Projects 26 - 00816 and 1023F4) administered
by the Village of Benzonia, and Betsie River Access (Project 26 - 00285
administered by the Michigan Departmment of Natural Resources (MDNR).
Should land be required from any of these parks, a Section 6(f) conflict
would result. Section 6(f) of the Land and Water Conservation Fund
Act states:
No property acquired or developed with assistance under this section
shall, without the approval of the Secretary, be converted to other
than public outdoor recreation uses. The Secretary shall approve
such conversion only if he finds it to be in accord with the then
existing comprehensive statewide outdoor recreation plan and only
upon such conditions as he deems necessary to assure the substitution
of other recreation properties of at least equal fair market value
and of reasonably equivalent usefulness and location.
Any modification of the parklands which may create a Section 6(f) conflict
should be coordinated through the State Liaison Office (SLO) who is
responsible for administration of the Land and Water Conservation Fund
in the State of Michigan prior to initiation of the project. The SLO
in Michigan is Mr. O.J. Scherschligt, Deputy Director, Department of
Natural Resources, Box 30028, Lansing, Michigan 48909.
The document cites Cold Creek (page 60, table II-6) as contributing
38.8% of the phosphorus load to Crystal Lake. Figure 11-12, page 59,
shows that the bulk of the phosphorus enters the lake between mid-February
and the end of April. This coincides with the peak spring runoff and
may be associated with Beulah's storm sewers discharging to Cold Creek.
Earlier in the DEIS (page 42) contained within the section entitled
Clean Water Act, it is pointed out that municipalities must provide
treatment commensurate with "best available technology" by 1983 and
that in appraising their waste management options, localities must address
(R-l)
-------
- 3 -
the control of all major sources of stream pollution (including combined
sewer overflows, agricultural, street and other surface runoff).In
addition, the proposed EPA Consolidated Permit Regulations, Sec. 122.79
and Sec. 122.82(e), may require that the storm sewers of Beulah be subject
to the NPDES permit program, in which case it would seem that the storm
water would need treatment, including phosphorus removal.
We recommend that the issue of larger than ambient loads of phosphorus
from Cold Creek be addressed in the Final Environmental Impact Statement
from the point of view of whether this load should be included in the
facilities plan for Crystal Lake.
On page 96 it is stated that the Michigan State History Division would (R-34)
require a survey prior to construction to verify the existence of any
archeological sites that may be impacted by the selected alternative.
Results of the survey should be made a part of the final environmental
impact statement.
The definition of aquifer on page 195 should include a qualification
concerning the degree of availability of ground water. For example,
the definition should specify that an aquifer will yield useful or economically
sigificant quantities of gound water.
Sincerely yours,
David L. Jervis
Regional Environmental Officer
-------
STATE OF MICHIGAN
M i rfiiftlfr
WILLIAM G. MILLIKEN, Governor
DEPARTMENT OF MANAGEMENT AND BUDGET
P.O. BOX 30026, LANSING, MICHIGAN 48909
GERALD H. MILLER, Director
September 6, 1979
Mr. Eugene Wojcik, Chief
EIS Section
Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Dear Gene:
As promised, I am forwarding to you the enclosed report of the
Michigan Interdepartmental Environmental Review Committee
(INTERCOM) on the Draft Environmental Impact Statement entitled,
"Alternative Waste Treatment Systems for Rural Lake Projects,
Case Study Number 1." INTERCOM, composed of representatives
from all nineteen state departments, adopted the report on
September 6, 1979. The report will receive final consideration
by the Michigan Environmental Review Board on September 24,
1979.
The Environmental Review Board previously reviewed the Draft
Environmental Impact Statement on the proposed Huron Valley
Wastewater Control System. I would appreciate receiving three
copies of the final EIS on that project at your earliest
convenience. Thank you.
Sincerely,
Tepry LyYonker
Presiding Chairman
Interdepartmental Environmental
Review Committee
enc.
THE
GREAT
STATE
*
-------
REPORT TO INTERCOM
Ad Hoc Committee Review of the Draft Environmental Impact
Statement (EIS 216/F/8) For the Crystal Lake Facility
Planning Area, Benzie County, Michigan, Prepared by Region V
Office of the US Environmental Protection Agency
The draft EIS discusses several waste water management options for the Crystal Lake
Planning Area in Benzie county and recommends adoption of the "Limited Action
Alternative" which was found to be most cost-effective. Selection of this
alternative would eliminate from further consideration a facility plan developed by
the Crystal Lake Sewage Disposal Authority under the provisions of section 201 of
the Federal Water Pollution Control Amendments of 1972.
Concern about the high cost of implementing the "201" plan, amounting to $8,654
per residence in the planning area, caused EPA to undertake its own study which
resulted in the identification of several alternatives and preparation of this EIS.
Synopsis
a. Project Area
The area covered by the EIS includes Lake, Benzonia and Crystal Lake townships,
the city of Frankfort and the villages of Benzonia, Elberta and Beulah. Both the
city of Frankfort and the village of Elberta operate primary sewage treatment plants
which discharge in Betsie Lake. Both facilities have insufficient hydraulic
capacity to meet effluent limitations required by the NPDES permits issued by the
Department of Natural Resources.
The village of Beulah's treatment works consist of a series of oxidation 'ponds
originally designed to dispose of the effluent via two seepage ponds. Problems of
hydraulic overloading in recent years necessitated periodic discharges of treated
effluent to Betsie river. The NPDES permit provides for such discharges on a
semi-annual basis but they apparently take place more frequently as the community
has failed to install the necessary improvements stipulated in the permit. The
remaining portions of the planning area lack central collection and treatment
systems and are served by individual on-site disposal facilities.
A sanitary survey conducted in connection with the preparation of the EIS indicated
that over 50 percent of the on-site disposal systems around Crystal lake were in
violation of the sanitary code while a substantial number were found to be leaching
effluent into the lake. Except for the vegetation along the shore line which was
correlated with the influx of sewage effluent, the water of Crystal lake is otherwise
considered to be of high quality.
Of considerable concern is the deterioration of the water quality of Betsie lake
where excessive nutrient loading have created serious eutrophic conditions. The
major cause of this problem are the non-point pollution sources in the Betsie
river watershed tributary to the lake and the effluent discharges from the primary
treatment plants serving Frankfort and Elberta.
The majority (approx 60 percent) of the population in the Crystal Lake planning
area consists of season resident most of whom are located in the unsewered area
surrounding Crystal lake. In contrast, the small urban centers have mostly permanent
populations.
-------
Report to INTERCOM
Page Two
b. Proposed Waste Water Management Plan
The Limited Action Alternative selected by the EPA as the preferred system for the
Crystal Lake Planning Area would replace the primary treatment plants of Frankfort
and Elberta with a single secondary facility discharging into Betsie lake. The
plan also provides for rehabilitation of the collection sewer systems of the two
communities. The village of Beulah would retain its treatment plant while in the
remainder of the area existing on-site systems would be repaired and upgraded.
The feasibility of cluster systems or other off-site systems for the northeast
and southeast shores of Crystal lake would be considered. The plan further
proposes the creation of a small waste flow district in the unsewered portion of
the planning area for managing the on-site waste water systems.
Comments
The committee identified a number of inconsistencies and problems with the limited
action alternative recommended by EPA.
1. Under the Clean Water Act of 1977, individual on-site and cluster systems are
considered "alternative technologies"., Repair, renovation and replacement of such
facilities are therefore eligible for 85 percent federal cost share, provided they *
are privately-owned, serving year-round residences or are publicly-owned, year-
round or seasonally used. Seasonally-used, privately-owned systems do not qualify.
Since the population in the unsewered portions of the planning area consists
mainly of seasonal residents it would seem that the federal financial assistance
program would not likely contribute much to correcting the problems associated with
individual on-site systems.
2. Applications for federal grants to finance the rehabilitation or construction
of on-site systems must be filed by a public body or governmental entity. EPA
regulations (40CFR35) also require the applicant to be responsible for the proper
operation and maintenance of the system. The applicant must further certify that
there is assurance of unlimited access to each individual on-site system at all
reasonable times for inspection, monitoring, maintenance and operation.
Michigan has no statutes authorizing units of local government to manage waste
water facilities other than those connected to conventional collection systems.
Therefore, it appears that the proposed waste management plan for the unsewered
part of the project area is non-implementable unless Act 320 of 1929 is applicable
as suggested in the EIS.
3. The EPA recommended plan seems to favor the use of cluster systems in selected
areas around Crystal Lake where small lot sizes or soil limitations preclude the
installation of individual on-site disposal facilities.
Site conditions are more critical in the design of cluster systems than of sewers.
However, it seems that little site-specific information is available to determine
(R-21
(R-24
-------
Report to INTERCOM
Page Three
whether cluster systems are technically and socially acceptable in the locations
considered for this purpose.
A. In view of the limited impact of the existing on-site system on the water
quality of Crystal Lake, it would seem that upgrading of septic tank facilities (R-21)
with implementation of a government-enforced maintenance program would remedy
the present problem of aquatic plant growth along the shore without the need
of creating a special management agency.
5. No problems were found with the elements of the plan dealing with centralized
waste water management recommendations.
Respectfully submitted,
Emmanuel T. Van Nierop
Michigan Department of Agriculture
Jan H. Raad
Michigan Department of Transportation
8/30/1979
Adopted by INTERCOM on September 6, 1979
Terry L. Yonker, Presiding Chairman
INTERCOM
-------
STATE OF MICHIGAN
NATURAL RESOURCES COMMISSION ^>j$ STEVENS T MASON BUILD
JACOB A HOEFER BOX 30028
CARL T JOHNSON WILLIAM G MILLIKEN, Governor LANSING MI 48909
DEPARTMENT OF NATURAL RESOURCES
HARRY H WHITELEY HOWARD A TANNER, Director
JOAN L WOLFE
CHARLES G YOUNGLOVE AugUSt 29, 1979
Mr. Todd A. Gayer
Assistant Division Director
for Construction Grants
U.S. EPA - Region V
230 S. Dearborn Ave.
Chicago, IL 60604
RE: Crystal Lake Environmental Impact
Statement, Project No. 0262844-01
Dear Mr. Gayer:
We have completed our review of the draft Environmental Impact Statement
for the Crystal Lake Area Sewage Disposal Authority, Benzie County,
Michigan, and have the following concerns.
The Environmental Impact Statement fails to come to a final conclusion
as it does not contain all data necessary to support the alternative
recommended therein. The EIS claims that local on-site systems are
cost-effective, yet, it does not provide information indicating the
number of systems needed, but refers to the fact that extensive on-site
analysis will be done in the Step 2 stage. These extensive on-site
studies must be done in Step 1 as they are an important factor in developing
the cost-effective analysis. Until such time that the exact number
of facilities needing replacement or upgrading are known, a true cost-
effective analysis can not be completed.
We also wish to point out that the various alternatives considered in
the EIS are inconsistent with Appendix A. Appendix A requires that
all feasible alternatives and waste management systems shall be initially
identified. These alternatives should include systems discharging to
receiving waters, land application systems, on-site and other noncentralized
systems including revenue generating applications and systems employing
the reuse of wastewater and recycling pollutants. In identifying alternatives,
it is required that the applicant consider the possibility of no action
and staged development of the system. The EIS does not address the
possibility of the no action alternative for the Crystal Lake area.
(R-
It is our opinion that the National Environmental Policy Act is being
misapplied by EPA and has become a facilities planning task performed
at the federal level rather than an evaluation of the selected alternative
contained in the original facilities plan.
(Rr-
VHCTTLG%M
1*
THE
GREAT
LAKE
STATE
-------
The EIS is furthermore inconsistent in its evaluation of various systems
and the need for such systems. The agency is reviewing the project (R-38)
with decentralized measures under a different set of standards than
if a centralized system were proposed.
The report contains three different population projections for the area
under different proposals. Our understanding of population projections ( R-4Q)
under the 201 program is to estimate how many people will be living
in an area in 20 years and then develop alternative ways of addressing
their needs. The EIS leads one to understand that more people will
automatically locate in the service area when sewers or a central collection
facilities are provided. This seems to ignore all other factors involved
in projecting population including employment, the energy situation,
etc. We would appreciate clarification on this item. (R-41)
The State of Michigan agrees with the segmenting of the Frankfort-Elberta
areas and has already taken the initiative to prioritize the projects
based upon information contained in the draft EIS. Upon receipt of
the final EIS and/or revised facilities plan by the authority, the State
of Michigan will revise the priority list based on the information contained
therein.
It is our recommendation that the additional on-site technical evaluations
be conducted prior to finalization of the environmental impact statement
at least for the Crystal Lake area so that a true cost-effective solution
can be evaluated. It is possible that these studies will show that
portions of the lake are not suitable for renovation or upgrading
to local codes due to topography, lot size, elevation, and other factors,
and that even a more localized breakdown or less extensive service area
may be appropriate, i.e. renovate and/or serve only the northeast portion
of the lake. Until these issues are addressed, we feel that a cost-
effective analysis for the Crystal Lake area has not been properly prepared
and cannot be evaluated.
We appreciate being given the opportunity to provide our comments on
the Environmental Impact Statement. If you have any questions with
respect to our comments, do not hesitate to call.
Very truly yours,
WATER QUALITY DIVISION
Richard T. Hinshon, Chief
Grants Administration Section
RTH/TK:ma
cc: Eugene Wojcik
Elaine Greening
Crystal Lake Area Sewage Authority
Ralph Heiden
Merle Crow
-------
United States
Department of
Agriculture
Soil
Conservation
Service
1405 South Harrison Road, Room 101
East Lansing, Michigan
48823
August 17, 1979
Mr. Gene Wojcik, Chief
EIS Section
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
We have reviewed the draft Environmental Impact Statement, Alternative
Waste Treatment Systems for Rural Lake Projects, Case Study No. 1, Crystal
Lake Area Sewage Disposal Authority in Benzie County, Michigan. We have
the following comments:
On page V under Environment-Soils, the second paragraph indicates the.
Soil Conservation Service accepts or rejects a site for on-site sewage
systems. The Soil Conservation Service provides soils identification
and soils limitations. The decision to accept or reject is left up to
others. This paragraph also states that the Soil Conservation Service
considers excessive permeability to be a limitation to on-site
systems. We do consider excessive permeability to be a limitation
where the affluent might find its way into water supply systems
(wells) or to open waters, such as Crystal Lake.
The third paragraph on page 31 indicates the Soil Conservation Service
is currently in the process of performing a soil survey for Benzie
County; this is not the case. In the fourth paragraph, the last
sentence should be corrected to read "The Soil Conservation Service
emphasizes that the existing soils data are not specific enough for
on-site septic tank evaluations".
The last paragraph on page 34; we feel that the purpose and the
intensity of the two soils evaluations are significantly different and
that they should not be compared. Again, the Soil Conervation Service
provides basic soils information and interpretations. The SCS does not
issue any permits.
On page 36, we question the advisability of including Table 2-1 in
this draft environmental impact statement. The data in this table are
not compatible. In general, we feel this section on soils and soils
limitations in the draft environmental impact statement is not clear,
not consistent and should be rewritten.
(R-3)
(R-5)
-------
-2-
We appreciate the opportunity to review and comment on this draft EIS and
would appreciate the chance to review the final environmental impact
statement.
Arthur H. Cratty
State Conservationist
AHC:rwg:rs 5252A
5252A
-------
STATE OF MICHIGAN
MlrHlfita
THE
GREAT
LAKE
STATE
WILLIAM G. MILLIKEN, Governor
DEPARTMENT OF MANAGEMENT AND BUDGET
P.O BOX 30026, LANSING, MICHIGAN 48909
GERALD H MILLER, Director
October 24, 19W f^
Mr. Eugene Wojcik, Chief O
EIS Section ",- c
US-EPA, Region V
230 S. Dearborn St.
Chicago, Illinois 60604
Dear Mr. Wojcik:
Enclosed is a copy of the Michigan Environmental Review Board's
comments on the draft EIS entitled "Alternative Waste Treatment
Systems for Rural Lake Projects, Case Study Number One." This (R-20)
report was adopted with the added proviso that the planning for
the waste water treatment system for the Village of Beulah be
coordinated with the study for the Crystal Lake Area.
A copy of this report will be forwarded to the Governor, MDNR and
Michigan A-95 Clearinghouse.
Sincerely,
Boyd Kinzley, Executive Secretary
Michigan Environmental Review Board
Enc.
BK:mf
cc: Dr. Howard Tanner
Mr. Hank Doerr
Dr. William Cooper
Mr. William Rustem
-------
MERE Review of the Federal Environmental
Impact Statement on Alternative Waste
Treatment Systems for Rural Lake Projects:
Case Study Number 1, Crystal Lake Area,
Benzie County, Michigan
by
Bill Cooper
Dick Passero
The draft environmental impact statement brings to public attention
several issues that have been previously discussed by M.E.R.B. The Federal
Environmental Protection Agency initiated the impact statement preparation
following a 201 facilities plan which recommended an extensive sewering system.
This alternative would produce the desired level of water quality protection,
but at considerable costs in monies and secondary developments. M.E.R.B.
engaged in a similar discussion when we reviewed the "Huron River Super Sewer"
plan. Since E.P.A. had to initiate the analysis of decentralized alternatives,
it appears that the D.N.R. should have developed an interest in alternatives
besides intensive hardware solutions. This attitude must be challenged for
rural areas like Crystal Lake.
The E.I.S. also discusses the conflict between the Soil Conservation
Service and the Department of Public Health concerning the premeability
criterion in determining soil suitability for land application of waste water
(pg. 34). This issue has arisen several times in the past and deserves
resolution. M.E.R.B. recommends that the S.C.S. and the D.P.H. make a joint
presentation at our November meeting on the issues of disagreement.
The E.I.S. describes the groundwater hydrology and water quality
characteristics on pages 47-52. The E.I.S. also identifies the extensive
use of groundwater for municipal drinking supplies (Table II-3). On page
D-4 of the Appendix, the statement "however, NPDES regulations no longer
apply because the treatment system is groundwater discharge. There are no
effluent limits associated with this type of discharge;" raises a number of
obvious questions. M.E.R.B. recommends that the D.N.R. present an explanation
of the existing procedures for monitoring "groundwater discharges" and
itemizes how many of these operations exist in the state.
The E.I.S. states (pg. 106) that the "D.N.R. requires the equivalent
of secondary treatment prior to land disposal." The E.P.A. has issued a
memorandum that states "A universal minimum of secondary treatment for
direct surface discharge... will not be accepted because 'it is inconsistent
with the basic concepts of land treatment." M.E.R.B. recommends that the
D.N.R. present a discussion of the merits or conflicts that they perceive
with this E.P.A. position.
10/22/79
-------
STATEMENT CY BENZIC COUNT' DEPARTMENT OF PUBLIC
WORKS FOR PUBLIC HEARING OH EIS August 6, 1979
It is the desire of the DPW to implement the majority preferences
of the public in connection with the Crystal Lake Area Sewage Disposal
Project. It is not the intent of Ihe DPW 'to arbitrarily impose minority
views on those who must bear the local shar.e of the cost of the project.
One of the DPW basic principles is that the local cost of the
project will be paid only by those directly benefiting. A general tax
on the entire County is inappropriate, even though a significant part of
the County economy depends on maintaining the quality of Crystal Lake.
It is clear, based on data in the EIS, that no other alternative
other than the Limited Action Alternative, except possibly Alternative 6,
can be justified. Alternate 6 might be justified if additional data
^
supporting it can he developed during Step II work. The choice is between
the lessor of two evils: one evil is deterioration in the quality of
Crystal Lake; the other evil is the difficulty of administering and
managing the limited action alternative, which means more government
intrusion in people's personal lives. Nevertheless, the DPW recommends
the limited action alternative.
The DPW would like to mention some of the problems of the Limited
Action Alternative, to show that the problems are recognized, and as an*
indication that no effort is being made to gloss over these problems.
* / J ..'..,'
1. Cost may be underestimated.
2. ^Easements must be obtained giving DPW access to septic
tanks and drain fields for inspection and maintenance. Some people may
w ' ' '
not voluntarily do this, particularly ivhere cluster system drain fields
JA ;
are concerned.
(R-25)
(P.-il)
(R-12)
(R-24)
3.. Legalities have not been tested in Michigan courts, but
- , f «-'"'
have been tested and established in Colorado and California.
4. The Limited Action Alternative is not as long range,
permanent solution as sewers would be, and may turn out to be penny wise
and pound foolish in the next 50 years.- On the other hand, sewers would
75
(R-21)
-------
ten/ to Increase the population density around Crystal Lake much faster
o
than the Limited Action Alternative, and would be prohibitively expensive
c ' - '
'compared to the limited action alternative. . -. .
5. Jurisdictional conflicts with the Tri-County Health Dept
are possible. '
6. Equitable user charges will be difficult to determine and
t . . , ..--.'
apply.
Notwithstanding the foregoing problems and provided that 'the
Limited Action Alternative is the majority consensus, the DPW will do .
its best to implement the Limited Action Alternative.
, Prolonged discussion advocating other alternatives will be
wasteful of time and counter-productive, because EPA will not approve
other alternatives unless new data can be.developed disproving existing,
c^ [ -
dat^.
cc: Eberly,Willard
-------
(R-D
I am Larry Manville, President of the Village of Beulah. It seems
you people have done everything in your power to get us to join the
sewer authority. At the first meeting I attended, you had our sewer-
maps, and were just planning on taking them over. I was accused at
that time of being against the sewer, gentlemen that is far from the
truth. The people of Beulah are not against your sewer, but we are
against giving ours up or paying for yours. We participated in phase
one,and only phase one of your project, and have no intentions of
participating any further.
It also seems Beulah is the main culprit on the polluting of
Crystal Lake because of Cold Creek. Gentlemen let me inform you
only a small part of Cold Creek is in Beulah, most of Cold Creek
and the drainage ditch is outside of the Village. We have farming,
golf courses, and homes along the creek and the drainage ditch. We
feel, if it has not been done, tests should be made all along these
streams to determan where, if any, the pollution is coming from.
This, then we can say with authority is where the sourse lies. Our
sewer lines cross the creek twice, in both places it is above the
water, this we have inspected and found in good shape. Last year
we televised the sewer in the alley in back of main street where it
crosses the creek and grouted and air tested all joints.
The taxpayers of Beulah have built and paid for their sewer and
we voted five mills when we built our Lagoons, this bond issue we
hope to pay off in 1981. 1981 is the first year we can pay in advance
This is one big reason we don't feel we should join but most of the
reports include Beulah. Second you people are talking of $15 a
month sewer charge, and this is not a final or definate charge. The
average charge for water and sewer for three months for a family of
four is about $20. To have you come in and redo our rates is unthinkable.
We are now operating in the black as the State requires and that is
all we hope for.
Gentlemen we of Beulah have done the only constructive work
that has been done. We are not against your sewer or the preserva-
tion of the lake, we are only against paying for it, the confiscation
of our sewer, and the reference to Beulah being the one polluting
the Lake.
Thank you,
(R-20)
' (sCrVSlS-fS t*"" A >
js/j£jte*£**'
-------
ENGINEERS /PLANNERS /ARCHITECTS /SURVEYORS /GEOLOGISTS /CHEMISTS -611 CASCADE WEST PKWY . S E , GRAND RAPIDS, Ml 49506 PH (616)942-!
WILLIAMS fer WORKS
TO WILLIAMS 1861-1941 F D WORKS 1880-1931 W B WILLIAMS 1895-1974
August 9, 1979
83742 31
Mr. Gene Wojcik, Chief
EIS Section
Environmental Engineering Branch
USEPA Region V
230 South Dearborn Street
Chicago, Illinois 60604
Re: Crystal Lake Wastewater Project
Dear Mr. Wojcik:
Enclosed are our comments and questions pertaining to the Environmental
Impact Study for the above referenced project.
They are contained in a letter to the Benzie County Department of Public Works
dated August 1, 1979.
Sincerely,
WILLIAMS & WORKS, INC
Richard C. Jones, P
Regional Consultant
RCJ/cln
Enclosures
-------
ENGINEERS/PLANNERS/ARCHITECTS/SURVEYORS / GEOLOGISTS / CHEMISTS -611 CASCADE WEST PKWY , S E , GRAND RAPIDS, Ml 49506 PH (616)942-9*
WILLIAMS e>WORKS
TO WILLIAMS 1861-1941 F D WORKS 1880-1931 W B WILLIAMS 1895-1974
August 1, 1979
Mr. Donald Graves, Secretary
Benzie County Department of Public Works
Benzie County Government Center
Beulah, Michigan 49617
Reference: Crystal Lake Wastewater Collection & Treatment Project
Dear Mr. Graves:
At your Board's request, we have reviewed the draft documents of the
Environmental Impact Study for the Crystal Lake Area Wastewater Project.
Our comments and questions with regards to the review are contained in
this letter. Some of the questions that we have raised were answered by
Al Krause during your July 20, 1979 DPW meeting. The remaining questions
which have yet to be answered are listed in this letter.
In general, our comments pertain to suitability of soils for on-site
systems, application of information generated documenting degree of correc-
tive action needed, authority for implementation of the management system,
and income of families in the county versus income of people in the service
area.
We find that the capital cost of recommended improvements; cluster
systems and upgrading on-site systems, for the immediate service area may
be off by as much as 100$. To date in Michigan, the only cluster system
of comparable size approved and funded by EPA cost in excess of $400,000.
This means that the cost of the five proposed cluster systems would exceed
costs indicated in the EIS and leave nothing for upgrading the remaining
600 on-site systems that do not meet sanitary code.
We find the $50 per year annual user charge fee grossly underesti-
mated. Because of the figures used for other alternatives, we must assume
that the $50 per year also includes debt retirement of the local share
capital cost of the limited action alternative. Operation and maintenance
plus replacement cost for the proposed five cluster systems and approxi-
mately 975 remaining on-site systems, would be nearly $300,000 per year.
If this cost were spread over all of the developed property, it would be
approximately $250 annually per user.
(R-12)
(R-28)
(K-13)
(R-29)
(R-30)
-------
Mr. Donald Graves - 2 - August 1, 1979
These costs do not take into account service to be provided to vacant
lot owners for wastewater management in the future. That cost would be shared
by the existing service area or be the total responsibility of the owner of the
vacant property. In locations where the soil is unsuitable for on-site systems,
costs for an acceptable system could be extremely high.
In essence what the limited action alternative has done from a cost
standpoint, is shifted the cost burden from immediate capital cost which
is grant eligible; to operation, maintenance, monitoring and replacement costs
which are perpetual and are not grant eligible.
The "1977 Clean Water Act Amendments" provide for more flexibility regarding
types of systems that can be used by rural areas for wastewater management. There
is more grant assistance available where innovative or alternative processes can
be utilized.
There is the possibility that the foregoing can now make available wastewater
management at a more reasonable cost to users of the system. However, one must be
careful not to oversell the concepts. It is a situation of trade-offs. Individual
on-site systems cannot provide the reliability of a sewer system. On the other
hand, based upon the cost figures generated in the EIS as well as information on
water quality, one would be led to conclude that a conventional sewer system can-
not be justified to serve all of Crystal Lake. We take exception to some of the data
gathered and some of the costs presented in the EIS.
In more detail, we have listed below our comments and questions.
COMMENTS
Item No. 1
Throughout the report there is discussion with regards to suitability of soils
for on-site systems. There is considerable discrepancy between information generated
from Tri-county Health Department records and Soil Conservation Service soils inves-
tigations. This leads one to conclude that there are obvious gray areas with regards
to whether lots with existing on-site systems and vacant lots have suitable soils
for on-site systems. Although the on-site systems that do exist may be functioning
adequately at this time, they may in the very near future, not function properly.
On vacant lots, where the on-site systems would not be able to be utilized, because
of soil conditions or water table, a waste disposal system could be a very expen-
sive improvement, especially if the septic tank effluent had to be pumped to a
cluster system some distance away, or there might have to be continued pumping of
a holding tank.
(R-14)
-------
Mr. Donald Graves
- 3 -
August 1, 1979
Item No. 2
An infra-red aerial photography survey was conducted during the summer
of 1978. Few surface malfunctions of on-site sewage disposal systems were
found. The report indicates that foilage may have hidden from view some
failing systems. A sanitary survey was conducted by the University of
Michigan during September and October of 1978. The results indicated that
over half of the lake shore on-site systems were violating the sanitary
code. At this time of the year, few of the seasonal residents would have
been occupying their dwellings. This type of a survey should have been
conducted during the summer months, or on a holiday week-end. From this we
conclude that more than half of the on-site systems violate the sanitary
code.
Item No. 3
With regards to implementation, it is stated that the concept of
public management for septic systems has not been legally tested in Michigan
present sanitary codes, however, have been interpreted as authorizing such
management by local governments. We can only assume that this was an inter-
pretation by the Environmental Protection Agency and yet has to be tested
in the courts.
Item No. 4
On page 32 of the Appendix, Item No. 5, indicates that location and
characteristics of the emergent plumes suggest direction of water flow is
entering the lake in the eastern sections and discharging in the western
sections towards Lake Michigan. The low occurrence of plumes along the
western shore is related to the predominate outward flow of the region.
This may result in keeping nutrients out of Crystal Lake; however, we
question what is it doing to ground water that is supplying private wells
for residents on the western side of Crystal Lake.
Item No. 5
The abstract for Section F-l, indicates that on-site improvements
would be necessary. It further indicates, that more than 60% of the homes
do not meet current public health regulations, therefore, if there are
1,085 homes on the lakeshore, and 60% have systems that do not meet current
health requirements, there are 651 homes that are going to need upgrading.
In the limited action alternative there is a capital cost of $1,600,000,
(realistic or not) for on-lot systems to be replaced. This is a cost of
approximately $2,500 per lot. We know that the cost for a cluster system
on a per home or lot basis is far in excess of that figure.
R-7)
(H-9)
(R-10)
Appendix
A
(R-21)
(R-2)
(R-ll)
(R-12)
-------
Mr. Graves -4- August 1, 1979
Item No. 6
On page No. 156 of the report, it states under the Section, "Long-term
Impacts", that 5' of soils are ample to remove bacteria, except in very course
grain highly permeable material. This may be a debatable item as far as the
State Department of Natural Resources Wastewater Division and local health
authorities are concerned, but we are not convinced. We suggest that current
literature be researched.
Item No. 7
On page 87, the report talks about the characteristics of the popula- (R-31)
tion, employment and income. It appears as though there may be a discrep-
ancy between the study area and the service area. The report preparers are
trying to use data for all of Benzie County, as a basis, when in fact, they
should be using the service area, which is quite different.
QUESTIONS
Item No. 1
On page 22, under the section entitled, "Estimation of Costs for Alter-
natives", it indicates that there is a breakdown of costs listed in the
Arthur Beard Report. It would be helpful to have the updated version of
breakdown of costs prepared by Arthur Beard & Associates for the cluster
systems, and for costs associated with renovation of existing on-site sys-
tems, also information with regards to quantity involved and cost associated
for each. Al Krause indicated that he will be sending us this information;
however, as of the date that this letter was prepared, we have not received
it.
Item No. 2
Throughout the report, there is very little information generated within
the Village of Benzonia with regards to documentation of on-site system
failures. Somehow it was concluded that gravity sewers would not be needed
for the Village of Benzonia. Al Krause indicated that within the Village of
Benzonia, the site specific study will actually determine what amount of
upgrading of on-site systems^ or types of systems will be justified. This
should be a part of this report.
Item No. 3
On page 168, it states that after selection of a recommended alterna-
tive, discussed in Chapter V, that alternative will serve as a baseline for
determining the cost effectiveness and thus eligibility. Collection and
treatment costs of other alternatives would not be eligible to the extent
that they exceed costs for comparable facilities in the recommended alter-
native. It is our concern that the DPW have access to more detailed base
information for the recommended limited action alternative to be able to
-------
Mr. Graves
-5-
August 1, 1979
(R-ll)
(R-12)
(R-12)
make a comparison for eligibility in the future.
Al Krause indicated that with documentation, systems other than up- (p~17)
grading of existing on-site systems can be justified and therefore, be
grant eligible. Therefore, only after thorough investigation in the Step
2 phase, or possibly Step 3 phase, can the final eligibility be determined.
Item No. 4
In looking at the cost figures for the limited action alternative in
Section J-2, there is no indication of how many cluster systems are planned
and how many on-site systems are to be upgraded with regards to septic tank,
tile field replacement.or renovation by the hydrogen peroxide method. There
has been no allowance made for growth in the limited action alternative for
on-lot systems in the lakeshore area, although in the other alternatives,
there is allowance for growth. More specific information is needed to be
able to make a detailed analysis.
Item No. 5
Only 25% contingency is allowed for the limited action alternative for
legal, administrative, engineering, etc. It is felt that this percentage
is not high enough considering the cumbersome administrative aspects that
will have to be dealt with in the area of land acquisition. In addition,
a very time consuming site specific study will be required, and the possi-
bility of higher than normal construction contingencies is required because
of uncertainties going into the construction phase. Exact condition of
marginal operating on-site systems will only be known after they have been
uncovered during the Step 3 phase.
Item No. 6
What is the boundary of the site specific study area. Al Krause
indicated that it would be the same as the immediate service area as proposed
in the facility plan. This is also the area that would have to be monitored
in the future with regards to affective functioning of systems. It would
have to be determined whose responsibility it would be for any replacement
or upgrading of the systems in that area in the future. It was indicated
by Al Krause that the Department of Public Works must have easements or
options on the properties that are included in the study area before the
DPW can receive their Step 2 grant offer.
Item No. 7
We question whether the EPA Study actually identified malfunctioning
systems with their aerial survey. From the information that had been sent
to Don Graves in November of 1978, it is obvious that it does not go into
much detail.
(R-24)
(R-7)
appendix
A
-------
Mr. Graves -6- August 1, 1979
Item No. 8
We question the cost per customer served for the limited action alter- (R-H)
native as presented. Al Krause confirmed that on the average it is $2,000.
This is based on cost information presented in the EIS.
Item No. 9
In the study, there was discussion with regards to pumping wastewater
from the northeast corner of Crystal Lake to Beulah. We question if there
are dollars allowed for improvement of the Beulah treatment facility. Al
Krause indicated that there were no dollars allowed for the improvements to
the Beulah treatment facility in the limited action alternative.
Item No. 10
Where is the septic tank sludge in the limited action alternative dis- (R-15)
posed? If it goes to the new Frankfort-Alberta Treatment Facility, are costs
allowed for that in estimating the new treatment plant cost? Al Krause
indicated that they have incorporated those costs into the construction of
the new treatment plant at Frankfort-Alberta. What would be the additional
operating cost?
Item No. 11
On page 130, there is a detail breakdown of the existing systems indi-
cating percentage of the on-site systems that have to have septic tanks or
drain fields replaced, plus those to be treated with hydrogen peroxide.
This is information included in alternative No. 3. Is this information used
for the other alternatives? Al Krause indicated that it is. Show us what
it is for the recommended alternate.
Sincerely yours,
WILLIAMS & WORKS, INC,
Richard C. Jones, P
Regional Consultant
RCJ/LEA
cc: Samuel Eberly
Dayton Willard
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McNamee, Porler and Seelet]
2223 PACKARD ROAD AN N ARBOR, M I C H 48104- AREA CODE 313 769-9220
fi I MtM*MEE W 5 HERBERT J C SELLE*
August 3, 1979
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60609
Attn: Mr. Alfred Krause
Re: Review Comments on the Crystal
Lake Area Sewage Disposal Authority
Benzie County, Michigan
EIS Prepared by Region V EPA
Gentlemen:
McNamee, Porter and Seeley was the Wastewater Treatment
Engineering Consultant for the City of Frankfort and Elberta
during the preparation of the Step 1 Facilities Plan. We
are also the Consulting Engineers for numerous other communities
that are faced with similar problems as were discussed in this
EIS. Therefore, our comments fall into two categories. The
first category consists of comments relating to the City of
Frankfort and Elberta portion of the Environmental Impact
statement while the second includes general comments.
I. Frankfort and Elberta portion of the EIS.
1. The EIS recommends a 0.32 mgd wastewater treatment
plant (WWTP) for Frankfort at a cost of $2,181,000
based on 1978 costs (see Appendix J-2). The
Facilities Plan included a 0.32 mgd WWTP for
Frankfort as part of Alternative 4 at a project
cost of $2,746,000 (see page 6-24). Based on
an ENR index of 2776 for 1978 and 2414 for the time
of the original estimate, the cost estimated in
the Facilities Plan would be updated to $3,158,000
as a 1978 cost. Therefore it appears that the cost
estimates used in the EIS are low. We recommend
that EPA prepare a revised cost estimate based on
1979 bids for similar work in Michigan.
(R-ll)
(R-16)
-------
McNamec.Porler and Seeleq
U.S. Environmental Protection Agency
August 3, 1979
Page Two
4.
The Frankfort NPDES permit requires advanced
secondary treatment and phosphorus removal.
However, the EIS does not indicate whether
the documentation required by PRM 79-7 has been
satisfied.
Page 117 of the EIS states that septage would be
treated at the RBC plant. If this RBC plant is
meant to be the one proposed for Frankfort, the
EIS should clearly state that. Neither the
Facilities Plan nor the EIS included cost for
septage treatment. The quality of septage is not
stated in the EIS. There is no cost effective
analysis in the EIS to determine if it would be cost
effective to treat the septage at the Frankfort-
Elberta WWTP or by some other method such as land
disposal. Elsewhere in the state, we evaluated
septage disposal at an RBC treatment plant and
determined a cost of $56.80 per 1000 gallons of
septage for treatment at the treatment plant.
That figure did not include the pumping and hauling
cost. In that project, land application of septage
was shown to be more cost effective.
EPA has indicated an interest in segmenting the
Frankfort-Elberta portion of the proposed project
from the Cyrstal Lake project. We concur with
this and recommend timely implementation of the
segmenting.
II. General Comments
1. The EIS lacked sufficient detail on the onsite and
cluster alternatives in order to enable an evaluation
of whether the systems would function properly. It
was also not possible to determine whether all costs
associated with such systems were included. Based
on our calculations for similar projects in a nearby
area, the costs for the onsite and cluster systems
is low.
(R-18)
Appendix
A
(R-15)
(R-1D
(R-12)
(R-14)
Appendix
B
-------
McNamee,Porter and Seeleq
U.S. Environmental Protection Agency
August 3, 1979
Page Three
2. The level of detail provided in the EIS concerning the
basis of design for the alternatives is much less
than the Michigan Department of Natural Resources
requires in Facilities Plans currently being prepared
in Michigan.
3. The EIS does not include a responsiveness summary
of the public meetings.
4. The term "Standard Population" should be more clearly
explained as well as the method by which it was
determined.
Very truly yours,
McNAMEE, PORTER AND SEELEY
BY
(R-4(
f Richard W. Force
RWF: gh
cc: Mr. Dan Post, City of Frankfort
Crystal Lake Authority
-------
HARMON CULHANE, PETERSEN, & BLETCHER
17 August 1979
Gene Wojcik, Chief
EIS Section
Environmental Engineering Branch
Water Division
Region V
United States Environmental Protection Agency
230 South Dearborn Street
Chicago Illinois 60604
RE: Draft EIS; Crystal Lake Area Sewage Disposal Authority, Benzie
County Michigan; Alternative Waste Treatment Systems for Rural
Lake Projects; Case Study Number !L. 2§_ June 1979.
Dear Mr. Woj cik,
We have decided not to submit our review memorandum on the Crystal
Lake Study at this time. It seems unreasonable to take you to task
for the length of the Crystal Lake EIS in a document that I judge
to be eight times the length it needs to be itself.
It is our position that the limited action alternative proposed by
EPA for this study area is the correct alternative. It will work,
and, we believe, meet the water quality goals that it claims. And,
at a greatly reduced cost to the public.
We do not, however, believe this to be an adequate water quality
improvement plan for the study area defined as the Crystal Lake
Watershed and Lower Betsie River Valley, within the meaning and
intent of PL 92-500 and PL 95-217. It does not address water qual-
ity matters other than sewage disposal, and it does not propose
facility or institutional arranaements to address those matters, as
is the clear intent of the Federal legislation.
We find the division of this project into two parts, a municipal
wastewater treatment project and a rural lake project, by the
Michigan Department of Natural Resources for priority list purposes
to be totally unacceptable. Such action by MDNR compromises the
water quality effort in the study area by dividing the pressing
Frankfort-Elberta treatment works problem from the no less important
Crystal Lake water quality problem, allowing the less obvious and
more difficult of solution problem to attempt to forge ahead on its
own, without the driving force of the readily apparent present
danger to water quality in Betsie Lake and Lake Michigan posed by
the Frankfort plant. We find, in addition, that MDNR took this
action without notice or hearing as required by State and Federal
Law.
Participation by the public in this decisionmaking process has not
been in accordance with EPA's own standards for Citizen information,
education, and participation. The efforts of Mr. Al Krause, the
EPA Project Officer, to bail out this particular turkey are to be
highly commended, mitigated only by the fact that he has been re-
sponsible for this EIS effort from its inception, and a lesser ef-
fort earlier on might have achieved a better result. EPA needs to
address these matters in the Final EIS for the benefit of the Step
II process, which we hope will include excellent citizen information
education, and participation elements.
(R-l)
(R-19)
(R-36)
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TEB to Wojcik: Crystal Lake EIS: 17 August 1979: page 2
We believe that EPA has, in the Crystal Lake study, prepared an
alternative facilities plan, and not an environmental impact
statement. That a good result, and an economy for the Benzie
County DPW, have come from this irregular practice ought not to
detract from this serious encroachment on the rights and duties
of the local and State government agencies, responsible under
the Federal statute" and EPA regulations for Water Quality Facility
Planning.
The Final EIS should include a description of the techniques used
in the studyThe Septic Snooper, and Aerial Infrared Photography
that rises above mere journalism, and shows that the writer had
some knowledge of the scientific method. The link should be forged
between hypothesis, data, theory, and proof in a credible and
reproducible way, and that substituted for, among other things,
the endless reproduction of Seotic Snooper chart paper in the
Draft EIS.
The Draft EIS's financial and institutional analysis section, which
is factually in error on several points, and incomplete and poorly
done in its entirty should be deleted from the Final EIS and re-
placed with the excellent and accurate institutions and financing
study prepared for the Michigan 208 Planning effort by Miller, Can-
field, Paddock, & Stone of Detroit Michigan, a firm of expert and
qualified Michigan municipal bonding counsel. We are not aware
that Miller, Canfield has updated this study to include the effect
of the Headlee Amendment to the Michigan Constitution in 1978, but
that should be included in the final EIS as well.
Taken as a Facilities Plan, the Draft EIS is incomplete, vague,
and generally weak on economic, land use, and environmental matters
of great concern in this project area. Taken as an environmental
impact statement, it fails to meet minimal EPA and CEO requirements
for a valid EIS--on some of the same matters, and others of tech-
nical interest such as length and apparatus. It is hard to suggest
a way out of this dilemma, and I am glad that that is EPA's task
and not mine.
The McNammee bathymetric map of Crystal Lake, prepared in 1943,
shows that some 20% of Crystal Lake is eligible for eutrophic action,
These areas are those with other major water quality problems other
than shallow water--densely developed shoreline, Cold Creek inflows,
and so forth. Shortsightedness and inaction can easily destroy this
priceless water and related land resource. Proceeding with the
limited action alternative on both the municipal and lake fronts
is the most important next step for EPA, the MDNR, and the Benzie
County DPW. Fixing the Facilities Plan and The EIS will not help
water quality in Benj&ie County one bit.
(R-7)
Thomas E. Bletcher
Senior Partner
815 South First Street
Ann Arbor Michigan 48103
(313) 663-8005
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Johnson & Anderson, Inc.
Consulting Engineers
Design and Engineering Division
2300 Dixie Highway PO Box 1166
Pontiac, Michigan 48056
Telephone 313-334-9901
J&A Group
July 19, 1979
Mr. Gene Wojcik, Chief
Environmental Impact Statement Section
Environmental Engineering Branch
U.S. EPA Region V
230 S. Dearborn St.
Chicago, Illinois 60604
Dear Mr. Wojcik:
In response to studying the Draft E.I.S. for the Crystal Lake Sewage
Disposal Authority, Benzie County, Michigan, I would like to offer the
following comments:
1) The analysis of decentralized alternatives (involving
substantial on-site upgrading) and their management approaches
is excellent and should be mandatory in the development of a
Facilities Plan; rather than allowing the usual cursory
examination of such worthy alternatives.
2) The analysis of flow reduction and water conservation
techniques in alternate sewer designs was very impressive in
terms of hindering the likely adverse impacts on the lake from
future watershed development. Again, an honest (rather than a
cursory) examination of these techniques should be required of
the applicant in the Facilities Planning stage instead of the
E.I.S. stage.
3) For analysis of sewering in the vicinity of a lake, a
practical nutrient budget (including on-site soil evaluations ;
dye/smoke testing; groundwater, surface and well water
sampling; and the use of the ultraviolet fluorescent "septic
snooper", to detect the septic system effluent actually
entering the lake) should be a must in order to protect such
an important and valuable ecosystem.
4) Guidelines should be specified by EPA on both theoretical and
practical nutrient budget development for use in Facilities
Plans as well as Act 314 Lake Restoration projects. The
biggest discrepancy lies in the theoretical input of nutrients
(R-8)
Member: Johnson & Anderson
Engineering Services Group, Inc.
Total Scope'
I
-------
Johnson & Anderson, Inc.
Consulting Engineers
Design and Engineering Division
Mr. Gene Wojcik, Chief
July 19, 1979
Page Two
to the lake from shoreline septic tank systems. For example,
the EPA National Eutrophication Survey recommended a value of
0.25 Ib/capita/year of total phosphorus as that which would
leach from soil disposal systems within 300 feet of a
lakeshore (p. 60 of Crystal Lake D.E.I.S.). However, MDNR
recommends that only a 200 foot shoreline envelope be used to
count septic systems; and furthermore, recommends that the
total phosphorus leaching to the lake be calculated by
multiplying 1.8 Ib/capita/year (Vollenweider, 1968) times a
percentage figure based on the soil's phosphorus adsorbing
capacity. For soils around lakes in Oakland County this %
figure is often 45%, thereby resulting in a phosphorus load of
0.81 Ib/capita/year; or more than 3 times the load suggested
by the National Eutrophication Survey. Hence, the potential
for sewering around a lake is three times as great with the
MDNR recommendations as with the EPA recommendations! For
proper environmental protection, clarification on this point
is needed.
Sincerely,
JOHNSON & ANDERSON, INC.
Michael A. Czuprenski
Environmental Engineer/Planner
MAC:Is
-------
UNIVERSITY OF WISCONSIN-MADISON
DEPARTMENT OF SOIL SCIENCE 1525 Observatory Drive
Madison, Wisconsin 53706
608-262-2633
August 17, 1979
Gene Wojcik, Chief
SIS Section
Environmental Engineering Branch
USEPA, Region V
230 Dearborn St.
Chicago, Illinois 606C4
Dear Mr. Wojcik:
The EPA is to be commended for its fine job in pre-
paring a comprehensive and thorough draft EIS for the Crystal
Lake area proposed facility plan in Benzie County, Michigan.
The EIS was quite effective in pointing out the possibly
undesirable, secondary impacts of a sewer installation in
the area. In recommending the limited action alternative, the
EPA seems to be complying with Tanis1 conclusion that "an
alternative which addresses specific problem areas may be
more appropriate" than complete sewering of the shoreline
( Tanis, 1978 ). I wholeheartedly agree with this viewpoint.
However, there is one point which has me slightly confused.
Consider these statements made in three recent publi-
cations dealing with Crystal Lake water quality: (R-l)
"It is apparent that significant contributions
of nutrients are made by Cold Creek discharges
to Crystal Lake. Also it is apparent that the
phosphates are being contributed by several
business establishments and houses along the
north branch." (Gannon, 1970)
"Cold Creek watershed is an area of high
influence on water quality....The greatest con-
tributions of phosphorus to Cold Creek originate
from the village of Beulah and its vicinity....
-------
Consideration should be given to alternative
collection and routing of Beulah stormwater."
(Tanis, 1978)
"Impact analysis has indicated that.non-point
source runoff contributes a large percentage of
the total Crystal Lake nutrient load....The two
major nonpoint sources have been identified
as the lower Cold Creek watershed and the lake
bluffs....Alternatives to the current practice
of routing Beulah's stormwater to Cold Creek
should be investigated." (EPA, 1979)
It seems quite evident that Cold Creek contributes sig-
nificant quantities of phosphorus to Crystal Lake. Indeed,
by EPA's own estimate, jQ.Qfo of the total phosphorus load to
Crystal Lake originates in the Cold Creek watershed, while a
maximum of 6.7$ is contributed by septic tank seepage fields
(EPA, 1979). Data presented by Tanis (1978) shows that about
68fo of the phosphorus loading from Cold Creek occurs during
the months of March and April. Taken together these figures
would seem to indicate that a substantial portion of the total
amount of phosphorus entering Crystal Lake (26%") is brought
in by runoff from the lower Cold Creek watershed during
periods of both high rainfall and snowmelt. This amount of
incoming phosphorus exceeds by bQOfo the amount of phosphorus
contributed by septic tanks. EPA is recommending that 7.^ million
dollars be spent, in part, to eliminate septic tank inputs.
What about Cold Creek?
Admittedly, it would be impossible to effectively
eliminate all phosphorus inputs from Cold Creek. Any such sug-
gestion would be unrealistic. However, Tanis (1978) showed
extremely high phosphorus concentrations in Beulah stormwater
runoff samples and the EPA itself has recognized the importance
-------
of Beulah stormwater. Here, then, is the point of confusion.
EPA seems to be interested in preserving the water quality
of Crystal Lake. It suggests that it's recommendation of
specific action on the water quality problem "is justified
to maintain (Crystal Lake's) unique scenic and recreational
value" (EPA, 1979). Why, then,do none of the alternatives con-
sidered in the EIS address the possibility of rerouting
Beulah stormwater? It seems that any solution which attempts
to alleviate one problem while ignoring a much greater one is
no solution at all.
As a graduate student in both soil chemistry and civil
engineering, and as a summer resident of the Crystal Lake area
I have both professional and personal interest in maintaining
the water quality of this most beautiful lake. I ask that in
the preparation of the final EIS the possibility of rerouting
Beulah stormwater be given more consideration than just passing
comment. If the EPA feels that 6.7$ or less of the total
phosphorus load warrants an expenditure of 7*^ million dollars,
than it seems to me that what could be a substantially larger
percentage ought not to go unattended. Even if no final action
to eliminate Beulah1 s contribution is recommended, it's con-
sideration as an alternative in the EIS would at least call
attention to a problem that is not well recognized by Crystal
Lake area residents.
Thank you very much for allowing me to express my opinion
of the draft EIS.
Sincerely you]
A. James Pastene
Research Assistant
-------
Literature Cited
EPA. 1979. Draft Environmental Impact Statement.
Alternative waste treatment systems for rural
lake projects. Case study number one, Crystal
Lake Area Sewage Disposal Authority, Benzie
County, Michigan. June, 1979.
Gannon, J. J. 1970. Crystal Lake water quality
investigation. Contract No. 33304-1-F. School
of Public Health, University of Michigan, Ann Arbor,
Michigan.
Tanis, F. J. 1978. Final summary report on Crystal
Lake water quality study for the Crystal Lake
Property Owners Association. Ann Arbor, Michigan.
-------
August 20, 1979
ENVIRONMENTAL PKOFECTION AGENCY
RECEIVED
Mr. Alfred Krause, Project Manager
Environmental Engineering Branch
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, IL 60609
AUG241979
ENVIRONMENTAL ENGINEERING BRANCH
TECHNOLOGY SECTION -'
Re:
Draft Environmental Impact Statement - Alternative Treatment Systems
for Rural Lake Projects, Case Study No. 1., Crystal Lake Area Sewage
Disposal Authority, Benzie County, Michigan
Dear Mr. Krause:
Since I was unable to attend the public hearing on the draft EIS on
August 6, 1979 I would like to make the following general and specific
comments.
General Comments
The great amount of data gathered during the case study support the
conclusion that the Facility Plan Proposed Action is neither economically
or environmentally justified. While the alternatives including the
recommended limited action alternative are less expensive none are anticipated
to have a positive effect on the water quality of the main body of Crystal
Lake. The positive effects on shoreline Cladophora growths are questionable.
The EIS in this regard fails to recommend or address explicitly lake
management actions which are considered necessary to maintain or improve
the long term water quality.
While the adverse effects of non-point sources (NPS) on lake water
quality are discussed within the EIS they are considered secondary to the
principal focus of the EIS which is to evaluate the impacts of the Facility
Plan Proposed Action. Since NPS pollution is central to the water quality
problem I suggest a complete discussion of NPS with recommendations be
included in the EIS summary and recommendation sections.
Specific Comments
Refs. Kerfoot, W. 1978. Investigation of septic leachate discharge into
Crystal Lake, Michigan.
Tanis, F. 1978, Crystal Lake Water Quality Study (CLWQS).
-------
Page Two
1. The EIS value for annual contribution of total phosphorus from
precipitation as quoted from the CLWQS (Tanis, 1973) is for a
specific year and is estimated to be 22% less than the long term
average base upon the annual precipitation.
2. The hydraulic retention time of 63.1 years as reported in the EIS is
misquoted from the CLWQS where the retention time was estimated to be
30.2 years.
3. The annual total phosphorus loading from Cold Creek is reported in
the EIS (page 60) to be 679 kg/yr. This estimate is reported to
have been made based upon data reported in the CLWQS report. I
suspect this value was obtained by integrating under the loading-time
curve and is approximately twice the sum of monthly averages as
reported by the CLWQS. The integration technique would yield erroneous
values of monthly loading during March and April of 1977 when very
high levels of total phosphorus were observed in Cold Creek.
4. The EIS suggests on page 74 that a large discrepancy exists between
the number of cottage sites found with Cladophora growth during the
CLWQS survey (5%) and that indicated by the sanitary survey (34%).
The former figure represents percentage of the 1090 cottages around
the lake which showed significant growths. The sanitary survey's
figure is given with respect to the 511 cottage which are located
within 300 feet of the shoreline. Only 10% (approximately 5% of 1090)
of these were found to have heavy growths. Thus, I believe the
studies to be in much closer agreement than indicated in the EIS.
5. The "septic snooper" device used by Kerfoot (1978) to observe septic
tank leachate plumes provides complementary data to those collected
in the Cladophora surveys. However, the use of these data to calculate
annual nutrient loading from individual tanks (or shoreline sections)
as indicated in the above report (page 30) are in doubt for the
following reasons.
a. Total phosphorus concentrations measured in these plumes was often
within the expected variation of whole lake concentrations.
b. The measurements were made in November after many of the seasonal
residents had left the area.
c. The movement of phosphorus in soils associated with leachfields is
highly variable in time and depends heavily upon local rainfall/
runoff conditions.
d. Littoral bottom materials are put in motion during frequent windy
weather. These materials move along the shoreline allowing some
of the plume phosphorus to mix with lake waters.
For these reasons I would expect Kerfoot's values to be much lower than
actual loadings.
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Page Three
In general, I believe that EPA Region V EIS staff and WAPORA Inc. have
done a good job in preparing the draft EIS.
Fred J. Tanis
2370 Delaware Drive
Ann Arbor, MI 48103
-------
W. J. BAUER CONSULTING ENGINEERS
20 NORTH WACKER DRIVE
CHICAGO, ILLINOIS 606O6
312 -
JUL 1 9 7979
Mr. A. Krause
Region V, US EPA
Water Division
230 S. Dearborn
Chicago, IL 60604
Subject: Crystal Lake, Frankfort, Michigan
Dear Mr. Krause:
I thank you for sending to me a copy of the EIS and a copy of its appendix
concerning the subject area.
I have been on vacation at Crystal Lake, continuing a custom in our family
that began in 1955, and have not as yet read these volumes in detail. However,
I have skimmed through them and read the summaries, so I am able to comment
as follows in this letter.
1. I applaud the decision to continue the use of septic tanks for the
cottages around Crystal Lake. I agree with the report that the instal-
lation of sewers would not only be exhorbitantly costly, but would
actually cause a deterioration of the environmental quality around
Crystal Lake. Not only would nutrients now trapped in the soils be
conveyed to and discharged into Betsie Lake and thence into Lake
Michigan, but the presence of sewers would produce an intensification
of pressures for a much increased population around the shoreline of
Crystal Lake. I like it the way it is, with as much natural terrain
remaining undisturbed as possible. The majority of lake residents
and summer users also feel the same way.
2. I am still alarmed by the high costs of treating sewage for the little
town of Frankfort. I realize that the costs have been much reduced
as compared to the former proposals by the consulting engineer for the
Facilities Plan, but I think there is still room for substantial cost
cutting. The flows are so tiny; one wonders why such expensive
facilities are required. I must admit that I have not examined any cost
estimates in detail; I don't recall there even being any detailed cost
estimates in the materials furnished to me; but the $7 million for such
flows just appears too much.
3. I saw no discussion of any remedial measures for either Crystal Lake or
Betsie Lake such as would result from a bottom cleaning operation. One
can envisage equipment similar to that used for cleaning swimming pools,
-------
Mr. A. Krause -2- July 18, 1979
but of course with substantial design changes to account for the
presence of unconsolidated materials on the bottom and the much larger
size required; such equipment might be used to reduce the present
accumulations of undesirable materials, and to export nutrients now on
the bottoms of these lakes - particularly on the bottom of Betsie Lake -
to the nearby agricultural areas which could benefit from them. This
approach could probably remove nutrients from the lake for substantially
less per pound than the cost of reducing the input of them via the
proposed Frankfort sewage treatment system.
4. Again, I suggest an open competition for the handling of the Frankfort
sewage. Why could not the specifications read es follows:
a. The cities of Frankfort and Elberta, Michigan invite the submittal of
proposals to design, construct and operate a facility for handling an
average of X million gallons per day of sewage, with peak flows of
Y million gallons per day, to be treated to the required state standards
which include limits on B.O.D., S.S., and nutrients. The proposal
will be accompanied by a fixed price for construction; a fixed price
for operation, with escalation clause to allow for future increases in
costs of energy and labor, and a suitable performance bond covering
the entire scope of the work.
b. The detailed specifications of the methods to be used in evaluating
performance are given in the attached specifications.
c. The work is partially funded by grants from the federal and state
governments, and the applicable regulations regarding the qualifica-
tions of persons to be employed by the successful bidder in the
execution of this work must be obeyed.
If the contractor did not provide plans and specifications suitable for the accom-
modation of the sewage, then one need not award a contract to him. On the
other hand, if you would advertise in the manner described above, I would organize
a bid, which would include providing of the land to be irrigated with the waste-
water, as well as the land for the storage and treatment lagoon.
5. You could even arrange to have the job bid both ways at the same time.
Let conventional plans for the bio-disc plan be drawn up. Then advertise
for proposals for the construction of that plan and also for proposals for
the design, construction and operation of a plant to be proposed by the
bidder. Then one could take a choice at the time of the consideration of
bids. You would throw out the proposals that your technical committee
would evaluate as being incapable of meeting the required performance
and then choose among those that would remain.
-------
Mr. A. Krause -3- July 18, 1979
In summary, I was pleased to see that progress has been made, that
the profligate and dangerous plan proposed by the consultants has been
shown to be undesirable and that your agency has the courage to take
an opposing view. I shall try to attend the August 6th meeting at
Frankfort High School, which is on a Monday evening. I normally
would be at Crystal Lake on a Monday evening.
Very truly yours,
-tr
William J. Bauer
WJB/jp
-------
August 25, 1979
ENVIRONMENTAL PROTECTION AGENCY,
RECEIVED
SEP 041979
ENVIRONMENTAL ENGINEERING BRANCH
TECHNOLOGY. SECTION
Mr. Alfred Krause, Project Monitor
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, IL 60609
Subject: Draft of Environmental Impact
Statement - Crystal Lake Area
Benzie County, Michigan
Dear Mr. Krause:
As spokesmen for the three lake associations comprised of property
owners in the Crystal Lake area, we would like to submit the following
commentary concerning the Draft E.I.S. for our area.
We generally agree with the conclusions of the Draft E.I.S., and
support the Limited Action Alternative. In addition, we are impressed
with the preparation ;aiid thoroughness of the document.
However, we are concerned that the Draft E.L.S. does not address a
major source of nutrient input to Crystal Lake, namely Cold Creek.
Also, we were startled to learn that the project was in effect
already segmented and different priorities assigned. This aspect leaves
us fearful that our specific interests may be stalled again!
Again, an additional concern is the liklifcood that the National Park
Service will install a roadway on the bluff areas between Beulah Village
and Warren Road. The resultant erosion potential for impact on the lake
would seem to be of serious concern in the Study Area.
Consideration of these concerns in the final draft should result in
additional protection of the water quality of Crystal Lake - our major
concern.
Respectfully,
Ralph O7 Hand
C.L.P.O. President (350 members)
.sociation Pres.
(150 members)
Thomas W. Williams
South Shore Association - Pres. (228 Members)
-------
t . ., -. i.*. - - V t , iJ
Regional Planning
u.,,,,,U inLlii-LK^uuK^oH
Development ' Ctmtmission
. -I
<; to
PHONE (6161 946-5922 ^"TRAVERJE^ITY ' ~.
2334 AERO-PARK CT *" "'
9 November 1979 %; ~£ ,->
Mr . Alfred Krause £r ^ ' \
U.S. EPA 1_
230 S. Dearborn '^ cc
Chicago, ILL 60604 ''-
Dear Mr . Krause :
The Northwest Michigan Regional Planning and Development Commission at its
19 October 1979 meeting concurred in the recommendations in the Crystal Lake
Environmental Impact Statement. The Commission believes that you have pro-
vided important information for dealing not only with Crystal Lake's water
quality problems, but also with similar existing or potential problems
elsewhere in our Region.
Although the report is generally satisfactory we would like to reinforce
comments made by the Crystal Lake Property Owners Association regarding
Cold Creek. Cold Creek is a major nutrient source, and we feel that the
EIS should therefore investigate that problem in greater detail. The
survey of effluent discharges to Cold Creek to detect leakage from Beulah
sewers is an important study and definitely should be conducted. In the
event that the Beulah sewers are found not to be causing the high phospho-
rus loading, then the Environmental Impact Statement should outline other
studies that EPA will perform to identify the problem. The addition of
this material to the Environmental Impact Statement is very important.
The Commission applauds the Environmental Protection Agency for its
efforts to date, and urges it to follow through with implementation of
the Environmental Impact Statement recommendations.
Robert C. Morris AIP
Executive Director
/gs
cc: Bruce Moore, Michigan Dept. of Nat. Res.
Bruce Orttenburger, Benzie County Planning Director
Bill Crawford, Benzie County Health Department
Ralph Hand, Crystal Lake Property Owners Association
-------
ENVIRONMENTAL PROTECTION AGENCY,
RECEIVED
iiu " n $PFa Forest,
JUL «>U WaSikfort, Michigan ^9635,
July 26, 1 9 7 9.
ENVIRONMENTAL ENGINEERING BRANCH
Mr. Alfred Krause, Project MonJECtiMplOGY SECTION
230 South Dearborn St.,
Chicago, Illinois.
Subject! Draft Environmental Impact Statement, Crystal Lake
Facility Planning Area, Crystal Lake, Michigan.
Dear Mr. Krause,
I recommend that EIS Alternative 4 (page viii) be implement-
ed. (As stated "Same as EIS Alternative 3, except that land applica-
tion of waste water would be substituted for RBC treatment).
My reason for this recommendation is that water quality of Betsie
Lake should be the best possible without adding some effluent re-
sulting from RBC treatment. Betsie Lake water is prime recreational
water s^ the quality should be the best possible.
On another subject, in Volume II Appendices, page Appendix G-2
there appears a list of endangered plans; also referred to Vol. I,
part II, D-4, page 83. Indicated as perhaps not being involved, the
enclosed news item from the Traverse City Record-Eagle may be of
interest.
-------
Great
Lakes
Basin
Commission
Lee Bolts, Chairman
3475 Plymouth Road
Post Office Box 999
Ann Arbor, Michigan 48106
313/668-2300 FTS: 378:2300
July 17, 1979
Mr. Gene Wojcik, Chief
EIS Section
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
RE:
Draft EIS, Alternative Waste Treatment
Systems for Rural Lake Projects, Case
Study Number 1 Crystal Lake Area Sewage
Disposal Authority, Benzie County, Michigan
Dear
Thank you/for the opportunity to review the draft environmental impact
statement for the Crystal Lake Sewage Disposal Authority Sec. 201 project. My
staff has reviewed the EIS and found it to be well written.
I was particularly impressed with the initiative taken to develop an
innovative and cost-effective solution to the water quality problems described
in the report. The analysis clearly demonstrates the potential for substantial
cost savings while still meeting local and national water quality needs. Also
important, as the report points out, are the possible development impacts if
extended sewage collection and treatment is provided.
Our analysis of regional water quality management plans throughout the
Great Lakes basin, prepared as a part of our Great Lakes Basin Plan, has shown
consistent support for the small waste flow district approach in sparsely settled
areas. I hope that the analysis done for this report serves as a model for
similar projects throughout the country. In particular, I recommend that the
report be made available to "208" agencies, if this has not already been accom-
plished.
Yours/truly,
irman
cc: John McGuire
Madonna McGrath
William Marks
State of Illinois
State of Indiana
State of Michigan
State of Minnesota
State of New York
State of Ohio
Commonwealth of Pennsylvania
State of Wisconsin
Great Lakes Commission
Department of Agriculture
Department of the Army
Department of Commerce
Department of Energy
Department of Housing
and Urban Development
Department of the Interior
Department of Justice
Department of State
Department of Transportation
Environmental Protection Agency
-------
DRAFT ENVIRONMENTAL IMPACT STATEMENT
ALTERNATIVE WASTE TREATMENT SYSTEMS FOR RURAL LAKE PROJECTS
Case Study Number 1
Crystal Lake Area
Sewage Disposal Authority
Benzie County, Michigan
Statement by
Dr. Stacy L. Daniels
999 Crystal Drive
Public Hearing
Frankfort, Michigan
August 6, 1979
-------
I am Dr. Stacy L. Daniels, a resident of Crystal Lake at 999 Crystal Drive,
and a native of Frankfort and Benzie County. I have been particularly
interested in following the development of the draft Environmental Impact
Statament for the Crystal Lake Area. As a practicing environmental engineer,
I am familiar with the EPA study procedures. I have been involved personally
in the development of technology for the removal of phosphorus from wastewater
by chemical means. I also participated in the 1978 Water Quality Study for the
Crystal Lake Property Owners Association.
I generally agree with the conclusions reached in the draft EIS. It is
heartening to see a study in which the conclusions are supported by scientific
fact. I support the Limited Action Alternative. I do not believe that any of
the alternatives would improve the water quality of the main body of Crystal
lake. I do not believe that extensive sewering is warrented, I encourage
the EPA to continue monitoring of both ground and surface waters, and analysis
of existing on-site treatment systems. I believe this approach will be
supported by the property owners to preserve the present character of the
cotmunity.
I would like to address two specific points: (1) the impact of a ban on
phosphorus-containing household detergents, and (2) the application of
innovative technology for on-lot systems.
I disagree with the conclusion in the draft EIS regarding the reduction of
phosphorus (Chapter Ill.l.b, pp 101-3). I do not support the action of the
Michigan DMR which banned the statewide use and sale of domestic laundry
detergents containing more than 0.5% phosphorus. I contend that there will
-------
be no significant reduction of the capital or operating costs of phosphorus
removal by the sewered communities of Frankfort/Elberta. The iirpact of the
ban on the unsewered conrnunity of Crystal Lake will be insignificant and
at best will amount to a reduction of the total phosphorus load to Crystal
Lake of about 2% (6.7% total phosphorus load from septic tanks x 0.35 reduction)
(Table II-6, p 60, and Chapter IV.A.l.a-b, pp 145-54). The option of a
ban on phosphorus is not viable (p 98) and should be deleted. I agree,
however, that the phosphorus ban will not achieve the effluent discharge limit
of 1 mg/L set for Betsie Lake. This will require chemical treatment (coagulant
and flocculant) at the new Frankfort/Elberta plant. I encourage the revision
of the draft EIS to reflect these views.
With regard to the continued use of on-lot systems, I support a program of
replacement and rehabilitation of malfunctioning systems to comply with local
health codes (Chapter III.C.2.f, pp 127-30). The management of small waste
flow districts is correctly addressed in the draft EIS (Chapter III.D.2,
pp 140-4). The cost sharing eligibility for small waste flow systems
using innovative or alternative technologies is further encouraged (Appendix J-3)
by a 15% present worth preference over conventional technologies. The EPA is
presently addressing the questions of elgibility for those 'systems which do not
have existing problems, those owned publically or privately, and those operated
seasonally or permanently. I believe that development of innovative technology,
such as waterless toilets (p 107) should be encouraged as an option for all
on-site systems regardless of ownership or period of use.
In conclusion, I believe that the EPA Region V personnel and their contractors
and subcontractors should be commended for a very credible job in preparing
what should be a model EIS for Alternative Treatment Systems for Rural Lake Projects
-------
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington. D.C. 80230
(202) 377XKM 4335
August 15, 1979
Mr. Charles H. Sutfin
Director, Water Division
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Sutfin:
This is in reference to your draft environmental impact
statement entitled, "Crystal Lake Facility Planning Area,
Crystal Lake, Michigan." We have the following comments
to offer.
Appendix B, National Ambient Air Quality Standards. This
Appendix should be updated to include the revised primary
and secondary standards for ozone (formerly photochemical
oxidants, 44 Fed. Reg. pages 8202 thru 8237, dated February 8,
1979), and for lead (43 Fed. Reg. 46246, October 5, 1978).
Enclosed are comments prepared by the National Oceanic and
Atmospheric Administration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you. We
would appreciate receiving eight (8) copies of the final
environmental impact statement.
Sincerely,
C<
idney R. Gtaller
Deputy Assistant ^Srfcretary
for Environmental Affairs
Enclosure
Memo from:
Mr. Eugene J. Aubert
Director, GLERL, RF24
Environmental Research
Laboratories
-------
U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
ENVIRONMENTAL RESEARCH LABORATORIES
Great Lakes Environmental Research Laboratory
2300 Washtenaw Avenue
Ann Arbor, MI 48104
August 3, 1979
TO:
FROM:
SUBJECT:
Richard L. Lehman, Acting Director
Office ofNEcology and Conservation, EC
Eugene
Director /GLERL, RF24
DEIS 7907.07 - Alternative Waste Treatment Systems for
Rural Lake Projects; Case Study Number 1 - Crystal Lake
Area - Sewage Disposal Authority; Benzie County, Michigan
The subject DEIS prepared jointly by U.S. EPA and WAPORA, Inc. on
Crystal Lake area sewage disposal has been reviewed and comments
herewith submitted.
Crystal Lake area near eastern shoreline of Lake Michigan is a well-
established recreational center based upon diversified scenic and
sports amenities. To maintain these unique values a plan was pre-
pared for an extensive wastewater collection and treatment. Costs
of the plan, Facility Plan, would be extremely high, $8,654 per
existing dwelling. For this reason an examination was conducted of
less extensive plans. The least cost plan, Limited Action, was
selected as the Recommended Plan. It would provide construction of
new sewers and a rotating biological contactor treatment plant to
serve Frankfort and Elberta and cluster systems or other off-site
treatment for the northeast and southeast Crystal Lake shorelines.
Cost estimate of the Limited Action Plan assumes that cluster systems
will be required for these shorelines (page 125).
The assumption is contrary to findings of the on-site surveys
conducted in 1978 by Biological Station, University of Michigan, and
by K-V Associates Inc. Biological Station found that northeast section
is the problem area and individual septic system improvements or
cluster systems would not be possible in the immediate area due to
high seasonal groundwater, but would require pumping to suitable soils
away from the lake. It concluded that sewering and land application
appear to be the most effective, lower cost, alternative (Appendix F-l,
page 15). Surveys by K-V Associates indicated that an abrupt
cessation of wastewater plumes into Crystal Lake occurred when sewered
area of Beulah was encountered on the east shore (Appendix C, page 13).
AUGOq 1979
-------
- 2-
In view of findings of the on-site surveys, it is suggested that
the recommended Limited Action plan be modified to include central
sewer system for the northeast section. It appears that the second
lowest cost plan, Alternative 6, with proposed gravity sewer collection
would eliminate extensive algal growth along the northeast shoreline
and provide many other benefits. This Alternative could serve as a
basis for a Recommended Plan.
-------
REV. GILBERT APPELHOF, JR.
608^4- Crystal Drive
Beulah, Mich. 4961?
August 6, 1979
U.S. Environmental Protection Agency
Region V, Chicago
Attention: Charles F. Sutfin
Direct6r, Water Division
Dear Sir:
We are year-around residents of Benzonia
Township, living on the north shore of Crystal
Lake. We own two houses, one on the lake shore,
one on the bluff, located between Nichols Road
and Warren Road.
We have special interest in the "cluster
system" proposed by your organization, and hope
it will extend to include our area. If so, we
pledge our fullest cooperation in bringing this
about.
We appreciate your comprehensive studies
which have been recorded in your "Environmental
Impact Statement," published recently. You have
done a commendable job, and a most difficult one!
Very sincerely,
v r
^^uU^-
-------
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION 5
182O9 DIXIE HIGHWAY
HOMEWOOD ILLINOIS 6O43O
July 31, 1979
AGEi'vuy
:>
AUG021979
Mr. Alfred Krause , ,,,-.,,,, , .
Project Monitor tuViKuNivJt.jTAL ENGINEERING BRANCH
U.S. Environmental Protection Agency TECHNOLOGY SECTION
230 South Dearborn Street
Chicago, Illinois 60609
Dear Mr. Krause:
The draft environmental statement for the Crystal Lake Area Sewage
Disposal Authority, Benzie County, Michigan has been reviewed. We
find the proposed improvement will have no adverse effect on the
Federal-aid routes in the area.
No reference to the consistency of the proposed improvement to
Michigan's Coastal Zone Management Plan could be found in the state-
ment. This should be discussed in the final statement.
Sincerely yours,
Donald E. Trull
Regional Administrator
By:
o£/W. G. Emrich, Director
* Office of Environment and Design
-------
Appendices
-------
Appendix A
Aerial Septic System Survey of Crystal Lake
-------
AERIAL SEPTIC SYSTEM SURVEY OF CRYSTAL LAKE
Introduction
An aerial photographic survey was conducted by EPA's Environmental Photographic
Interpretation Center (EPIC) to locate failing septic systems throughout the Study
Area. There are three basic types of failures that can occur with septic tank or
cesspool systems: 1) the wastewater contained in the system backs up into the home,
2) the wastewater "short-circuits" to underlying groundwater before it is adequately
filtered and purified, and 3) the wastewater makes its way to the surface in the
form of a surface "break-out". It is this last type of failure that is detectable
using aerial photographic techniques.
Based upon work undertaken to date, it has been demonstrated that the primary
surface manifestations associated with this type of failure are: 1) conspicuously
lush vegetation, 2) dead vegetation (specifically grass), 3) standing wastewater
or seepage, and 4) dark soil where excess organic matter has accumulated. All of
the above are a result of the upward movement of partially treated or untreated
wastewater to the soil surface, and usually appear directly above or adjacent to
one or more components of the septic system. Often, two or more of these manifes-
tations will occur simultaneously at a homesite experiencing a septic system
failure.
Methodology and Results
The two types of aerial film used in the survey of the Crystal Lake study area
include normal color (KODAK 2448) and color infrared (KODAK 2443) acquired in the
summer of 1978 at a scale of 1:8000, or 1 inch = 667 feet. In the photo interpre-
tation procedure, this aerial film was viewed simultaneously in a "multispectral"
approach to identify those manifestations associated with malfunctioning septic
systems (i.e., lush vegetation, dead vegetation, standing wastewater or seepage,
and very dark soil), and distinguish them from unrelated surface phenomena. These
"signatures" were used in conjunction with a knowledge of what type of system might
be used with homes of various ages and styles, and knowing where they should be
situated in relation to the house, to devise a "photo interpretation key" for de-
tecting and locating failing septic systems. After the photo analysis was completed
for the area, an extensive field inspection was undertaken by personnel from EPIC
and WAPORA to verify actual failures and discriminate them from "false" signatures.
Using the photo interpretation key, 100 potentially failing septic systems
were identified and located on the aerial photography. Upon field inspection, 29
systems were evaluated as being "overt" or "marginal" failures. Those systems
designated as overt failures were having problems with wastewater coming to the
surface during the time of the ground inspection. Those systems designated as mar-
ginal were not necessarily failing at the time of the inspection, but did exhibit
signs of having failed in the past, or having the potential for malfunctioning
during periods of excessive use or moderate to heavy rainfall. In the majority of
cases, the "false" signatures were areas of ponded rainwater, drainage from roof
gutters, low-lying shrubs, and other areas of excess soil moisture and lush vege-
tation not related to failing septic systems.
-------
Conclusions
One of the significant findings of the aerial survey, and subsequent field
inspection, was that despite the excess number of "suspect" sites initially located,
most of the chronic surface failures in the study area were believed to have been
identified and located. What is important here is not the percentage of probable
failures actually confirmed, but whether most of the significant failures have been
located. For example, if there are 25 actual failures in an area with 2,500 homes,
it is more important to find all 25 failures within a group of 90 "suspect" sites
than to find only 16 out of 20. The "detection" percentage is higher in the latter
instance, but in the first instance all of the failures have been found, and in
both instances the number of homesites requiring field inspection have been
greatly reduced, and objective information on the number and location of surface
failures within a specified area has been obtained.
Because of the difficulties experienced in detecting failures in sandy soils
and under vegetation canopies, it is possible that some surface break-outs may not
have been detected. As mentioned previously, however, this possibility was not
supported by findings of the field inspection. Thus, it is believed that a thorough
and accurate septic system failure survey was accomplished in the Crystal Lake
study area.
-------
Appendix B
Cost Information
No Action Alternative - Crystal Lake Area Project
Limited Action Alternative - Crystal Lake Area Project
Limited Action Alternative - Frankfort and Elberta Project
Work Description and Cost Estimate - Site Specific Analysis
Operation and Maintenance Cost Estimate - Limited Action
Alternative - Crystal Lake
Note: All costs in $1000.
-------
No Action Alternative - Unsewered Areas of Crystal Lake Study Area
Assumptions:
1385 dwellings unsewered in 1980
Increase 1980 - 2000 (years) = 809 (standard systems)
2% per year failure rate for existing dwellings with half
going to holding tank without flow reduction and half going
to dosed mounds.
Septic tank pumping on average of 1 per 10 years.
$45/pump of 1000 gal.
Sanitarian salary = $18,000/year. 12 hour per new permit.
16 hours per failure
Annual costs - constant
Install 14 holding tanks at $1714 each =
Install 14 mounds at $4115 each =
20 new permits x 12 hr./permit x $8.65/hour =
28 failures x 16 hr./failure x $8.65/hour
40 new ST/SAS x $1365
140 septic tank pump x $45 =
Annual costs - increasing
Holding tank pump = $400/year for seasonal
residents, 4 months/year x 2 pumps/month
of 3000 gal. each x $50/pump. 14 new
tanks/year x 400 =
Dosing systems for mounds $50/year each x 14=
$23,996
57,610
2,076
3,875
54,600
6,300
5,600
700
No Action Alternative - Crystal Lake Area
Present Worth Analysis
Annual Costs - Constant
Annual Costs - Increasing
Capital
1457.0
Constant
0 & M
131.0
Increasing
0 & M
495.5
Salvage
Value
-259.8
Total
1328.2
495.5
1823.7
-------
Limited Action Alternative - Crystal Lake Area Project
Summary Cost Data
Unit (year of construction)
Capital
Cost
Constant
0 & M
Cost
Increasing
0 & M
Salvage
Value
Site Specific Analysis (1980)
6 cluster systems (1980)
Land for cluster systems (1980)
On-site system upgrading (1980)
Contingency and Legal (1980)
Future on-site systems (40.5
new systems/year)
Management, Operation and
Maintenance (continuous)
501.7
418.1
60.0
867.0
90.0
93.8/year
113.5
2.3
Limited Action Alternative - Crystal Lake Area Project
Present Worth Analysis
Present Worth of
36.7
108.4
111.1
1,002.7
1980 Construction and Analysis
Management, Operation and
Maintenance
Future On-site Systems
Capital
1936.8
Constant Increasing Salvage
0 & M 0 & M Value
1003.4
- 67.8
1214.2 + 184.8
-265.2
Total
1869.0
1399.0
738.2
4006.2
Total Capital Costs
Eligible Capital Costs
Local Share of Capital (10%)
Annual 0 & M
Debt Service/year
20% Capital Reserve
Local Cost Analysis (1980)
$1,936,800
1,936,800
193,680
113,500
15,413
3,083
per Household
$ 82
11
2
$ 95
-------
Limited Action Alternative - Frankfort and Elberta Project
Summary Cost Data
Capital
Unit (year of construction) Cost
.33 mgd rotating biological 1744.8
disc treatment plant (1980)
Interceptor sewers to new treatment 104.4
plant (1980)
Frankfort and Elberta sewer 263.9
rehabilitation (1980)
Frankfort storm sewer separation (1980) 204.6
1980 Engineering and contingencies 579.4
Future sewers for Frankfort and 860.8
Elberta (1990)
1990 Engineering and contingencies 215.2
Constant
0 & M
Cost
64.0/yr.
1.4/yr.
2.1/yr.
Increasing
0 & M
.68
Salvage
Value
676.0
57.8
530.8
Limited Action Alternative - Frankfort and Elberta Project
Present Worth Analysis
1980 Construction
1990 Construction
Capital
Present Worth of
Constant Increasing
0 & M 0 & M Salvage
Total
Present Worth
2897.1 + 703.9
553.4 + 7.6
53.5 -194.1
-140.4
3460.4
420.6
3881.0
Total Capital Costs
Eligible Capital Costs
Local share of capital
Annual 0 & M
Debt service/year
20% Capital reserve
(20%)
Local Cost Analysis (1980)
$2,897,130
2,897,130*
597,426
65,400
46,111
9,222
per Household
$ 54
38
8
$100
* Some costs associated with the project will be ineligible as discussed in the
Facilities Plan. For the purposes of this analysis, the amount was assumed to
be negligible.
-------
Work Description and Cost Estimate
Site Specific Analysis
Crystal Lake, Michigan
Assumptions: # dwellings = 1384 total, 500 lakeside
Surface Malfunction = 3% based on U. Mich, sanitary survey
Repeat Backups = 6% based on U. Mich, sanitary survey
Non-Conformance = 53% total
= 23% less than 50' to well
= 63% small septic tanks or no record
=57% small drainfield or no record
Step
1. Sanitary Survey - Each survey house to include: completion of questionnaire,
inspect site, inspect well, explain access requirements,
provide access papers, educate, coordinate with survey team
on decision for succeeding steps.
-5/person/day = 1384 homes, 277 days
-Personnel: Sanitarian 25
Sr. Engineer 25
Soil Scientist 14
Jr. Engineer 25
Surveyors 174
W. Q. Scient. 14
2. Well Sampling - For homes with private wells less than 50 feet from sewage
facilities or down-gradient, collect sample for analysis
of fecal coliform bacteria, nitrates and bacteria.
-10/person/day 40% based on 23% less than 50' from
and an increment for down-gradient =
55 days
-Personnel: Surveyors 47 days
W. Q. Scient. 8
3. Septic Tank Inspection - For septic tanks a) for which no records or memory
of size, construction exist, b) for systems which have
reported backups c) for systems which have surfaced in past
d) for tanks reported to be small. Locate, uncover, pump,
and inspect for construction, leaks, deterioration, condition
and type of sanitary tees and baffles. Rod influent line
noting roots, other obstructions or collapse. Rod effluent
line noting same plus distance to headers, distribution box,
bends, obstructions.
-70% of 1384, 6/day/person plus $450/day for 3 man crew
and rodding equipment and pump truck plus $20/tank waste
disposal fee
-Personnel: Jr. Engineer 161 days
4. Soil Sampling - For lots with a) past or present malfunctions not explained
by survey results or septic tank inspection, b) substandard
soil disposal units, c) no record for soil disposal unit.
Determine soil texture, color, depth to seasonal high ground-
water level, water table of time of sampling in suspected
area of soil disposal unit and in alternate sites on and
-------
near lot. Probe suspected area of soil disposal unit for
depth, size, type.
-60% of 1384, 4/day/2 persons. 415 days
- Personnel: Soil Sclent. 215
Surveyor 200
5. Header and Drainfield
Excavation: For systems having recurrent backups or past surface mal-
functions not explained in prior steps, hand excavate
effluent line from point of obstruction, headers, etc.
to uncover distribution system. Hand excavate test pits
to verify size, depth and type of subsurface disposal
unit. Evaluate soil crusting, decomposition or silting
in of- aggregate, poor distribution, soil hydraulics as
reasons for failure.
-10% of 1384, 3/day/supervisor, 1/day/2 persons. 322 days
- Personnel: Sanitarian 46 days
Laborers 276
6. Well Water Meter
Installation: For on-site systems with limited hydraulic capacity as
determined by sanitary survey, soil sampling or excavation,
install water meter (after outside faucet) and read at
least monthly during survey .
-(1384 x .2) x 6 inspections - 24/person/day = 70 days
plus $175 for meter and meter installation
- Personnel: Surveyor 70 days
7. Shallow Groundwater
Sampling: Shoreline scan with fluorescent meter to detect emergent
plumes. Follow-up at sites with plumes with shoreline
transect and 5 samples per plume for bacterial and
nutrient analysis.
-Scan: 10 days x 2 persons = 20 days
Transects: 100 plumes T 2 plumes/day x 2 persons/day
=100 days
Plus $20/sample for analysis at Frankfort STP
- Personnel: W. Q. Sclent. 60 days
Sanitarian 30
Surveyor 30
8. Supervision/Documentation/Clerical
Support: Assume 272 work days total. Sanitarian at 100%, including
Tasks 1, 5, and 7. Sr. Egnineer at 25% plus 20 days for
report. Secretary at 100%.
-------
LABOR SUMMARY
Sanitarian
Sr. Engineer
Jr. Engineer
Soil Scient.
W.Q. Scient.
Surveyors
Laborers
Secretary
277
TOTAL
25 46
25
25 161
14 215
14 8
174 47 200
276
30
60
70 30
171
63
272
272
88
186
229
82
521
276
272
55 161 415
322
70
120
461
1,926
DPW COSTS
Salaries
Rent
Sanitarian at $25,000/yr. for 272 days
Surveyors at $ll,000/yr. for 521 days
Laborers at $12,000/yr. for 276 days
Secretary at $12,000/yr. for 272 days
20% Fringe
Office at $300/month x 13 months
SUBTOTAL
$ 26,154
22,042
12,738
12,554
$ 73,488
14,698
$ 88,166
3,900
Service
Contracts
Well sample analysis by Frankfort STP $10 x 554
Equipment
& Sampling
Transect sample analysis by Frandfort STP
$20 x 5 x 100 plumes
Septic tank inspect. ($450 x 161) & ($20 x
Water meter installation ($175 x 277)
Fluorescent meter
Groundwater flow meter
Field sampling equipment
Paper supplies
Cameras & film for documentation/records
4 vans at $350 & $120 gas & oil/month x 13
969)
5,540
10,000
91,830
48,475
14,000
4,000
2,000
2,000
3,000
24,440
Summary
CONSULTANT COSTS
Direct Labor
Salaries
Rent
Contracts
Equipment and supplies
Sr. Engineer at $35,000/yr, 88 days
Jr. Engineer at $20,000/yr, 186 days
Soil Scient. at $25,000/yr, 229days
W.Q. Scient. at $25,000/yr, 82 days
88,166
3,900
155,845
49.440
297,351
11,846
14,308
22,019
7,885
$56,058
-------
Other Direct
Costs Report reproduction $ 150
Communication 1,000
Graphics, report prep. 1,500
2,650
Travel House rental for office, sleeping (13mos.) 6,500
Other per diem $20/day x 790 14,000
75 RT - 700 miles x .20/mile 7,000
27,500
Consultant
Costs Labor x 3.0 56,058 x 3 168,174
ODC x 1.2 2,650 x 1.2 3,180
Travel x 1.2 27,500 x 1.2 33.000
204,354
TOTAL
DPW 297,351
Consultant 204.354
501,705
Equivalent to $363 per house total, $36.50 per house local share after Federal and
state grants.
-------
Operation and Maintenance Cost Estimate
Limited Action Alternative
Crystal Lake, Michigan
Assumptions: 1) Properly trained sanitarian will provide administration, engineering,
operations and planning services. Salary $25,000/year. Time not
spent on routine duties will be used for special monitoring studies
and evaluation of innovative systems, management techniques and
public education.
2) User charge and secretarial services provided by half-time
secretary at $6,00/year.
3) Soil scientist available on retainer for 20 days/year at $325/day.
4) Well sampling and site inspection provided by part time surveyors,
2/year at $3,000 @ for 12 weeks in summer.
5) 20% fringe benefits for sanitarian, secretary and maintenance
personnel.
6) Septic tanks serving permanent residences will be pumped every
3 years, seasonal every 5 years. Assume 50% permanent.
7) Septic tank pumping by 2 men making $7.50/hour each, 2 hours/
1000 gallon septic tank. $20/hour for truck. $15/1000 gallons
for septage treatment.
8) 0 & M for dosing systems and mounds = $50/year each. For electricity,
pump removal for seasonal residents, and emergency maintenance by
contract.
9) 0 & M for cluster systems = $100/year each. Includes electricity,
monthly inspection by sanitarian, periodic and emergency maintenance
by contract.
10) H202 treatment at 2%/year, $400/treatment.
11) Each private well sampled every 5 years.
12) Water sample analysis provided by Frankfort-Elberta for $10 for
nitrate and fecal colifonn (well water) and $20 for nutrient series.
Nutrient series limited to 200 samples per year for compliance
testing of near-shore systems. Lake and stream sampling not
included.
Salaries - constant
Sanitarian/Administrator $25,000
1/2 time secretary, $12,000 * 2 6,000
1400 hours for 2 mfn to pump 350 tanks
per year at 2 hours each per tank; $7.50/hr. 10,500
2 part-time surveyors at $3,000/year 6,000
$47,500
FRINGE X 1.2
$57,000/year
-------
Salaries - increasing
Additional 200 tanks pumped each year by 2,000 or 10 more
per year x 4 hrs. X $7.50/hr. $ 300/yr.
Retainer - constant
Soil scientist at $325/day for 20 dyas/yr. $ 6,500/yr.
0 & M - constant
6 cluster systems at $100/yr. each $ 600/yr.
H202 treatment for existing systems at 27, x 1384
& $400 11,000
Existing well sampling 1384 x .2/yr. x $10 2,800
Cluster system well sampling 6 cluster x 3 well/
cluster x 2 samples/yr. x $10/sample 360
Septic tank truck at $20/hr. x 700 hrs./yr. 14,000
200 water sample analysis/yr. for compliance testing
x $20 4,000
Septage treatment for 350 tanks x $15/tank 5,250
0 & M - future system
40 new homes/yr. 45% with pumps at $50/yr. 900/yr.
40 new homes/yr. 25% septic tank pump at $15 for
treatment and $40 for truck 750/yr.
20% well samples at $10 80/yr.
2% H202 at $400 320/yr.
Rental - constant
Office at $300/month x 12 3,600
Office supplies, telephone, etc. 2,000
Van purchase, maintenance, gas & oil 6,000
Small boat and motor rental 4 wks/yr x $100/wk. 400
Summary
Constant;
Salaries
Retainer
0 & M
Rental
for 1384 homes = $82/house
$57,000/yr.
6,500
38,010
12.000
$113,510/yr.
Increasing:
Salaries
0 & M
in 20 yrs = $47,000 more per year
111,760 base
$158,760
for 2194 homes = $72.36/house
300/year
2,050
$ 2,350
-------
Appendix C
Fourteen Things You Can Do to
Keep Crystal (or Betsie) Clear
-------
UNITED STATES REGION V
ENVIRONMENTA 'ROTECTION AGENCY CONST TTION GRANTS PROGRAM
NO. 6 DATE OF ISSUE September 12, 1978
» E./.S. NEWSLETTER
Fourteen Things*You Can Do To Keep Crystal (or Betsie) Clear
Malfunctioning septic tanks, although they can sometimes be an important
source of the nutrients that cause lake decay, are not the only source of
such pollutants. All of the sewage treatment alternatives in the 1976
Facilities Plan and in the current EIS will affect only localized nutrient
"hot spots", and not the long-term condition of the whole lake.
The Environmental Impact Statement will develop recommendations to deal
with the localized problems, but long term improvement of water quality
for the whole lake will require individual action by Crystal Lake area
residents.
Individual action can help control "non-point sources" of phosphorus and
nitrogen, such as lawn, farm, and orchard fertilization. Any substantial
rainfall causes fertilizers, pesticides, and weedkiller to run off the
land into the lakes. Taking the lakes as a whole, these "Non-point sources"
are the major sources of nitrogen and phosphorus entering the two lakes.
Here, with the help of Gale F. Arent (one of Michigan's County extension
directors) are fourteen things you can do in your own home to keep Crystal
and Betsie Lakes clear:
1. Maintain a zone of natural vegetation between your lake and lawn.
If you wish to plant a buffer strip, some trees worth considering are tamarack,
red cedar, black willow, red oak, white oak, sugar maple, black ash and
balsam poplar. A buffer strip can help stabilize the shoreline and prevent
runoff. Deeply rooted plants can- take up nutrients from the soil, instead
of allowing than to seep into the lake water.
2. If you are planting a lawn, plant fescue rather than blue grass.
The annual nitrogen requirement of fescue is about 2 Ibs. per 1000 square
feet, while bluegrass needs 4 to 7 Ibs. per 1000 square feet.
3. Use the smallest possible amount (this may be none at all) of
nitrogen fertilizer to maintain a good grass cover. Fertilize with
nitrogen in the spring using a small amount of a soluble form of nitrogen.
The principle is to have the grass use the nitrogen so it will remain
vigorous and minimize the amount of undissolved fertilizer on the lawn
surface capable of washing into the lake. .If the lawn is not growing
well, apply a small amount of nitrogen in early summer.
4. Do not use fertilizer containing phosphorus or potash unless a
soil test indicates the need for these nutrients and the lawn is not
growing well. In most case no phosphorus is needed on lawns.
-------
-2-
5. Water sparingly, especially on sandy soils, to reduce the
possibility of leaching nitrogen and other nutrients as the water moves
through the soil toward the lake.
6. Avoid fertilizer-weedkiller mixtures. Use weedkillers only if
weeds become a serious problem. If weeds are treated, apply the weed-
killer in the fall. This will minimize runoff and reduce the chance of
injury to trees and shrubs.
7. On lightly fertilized lawns thatch will probably not need to be
raked. It will decompose and provide part of the nutrients needed by
the lawn.
8. Fake leaves in the fall. This will keep them from "shading" the
lawn and from falling into the water where they will add to the nutrient
load.
9. Do not cut the lawn too close. Cutting height should be 2" to
2 1/2" so an adequate green area remains on the turf.
10. Don't park your car on the lawn.
11. Don't burn leaves in the gutter. Collect any leave that fall
and use them for compost or mulch.
12. Dog droppings are high in phosphorus, so don't "toalk" your dog
along the curb. If there is no large area where dog droppings won't
be a nuisance, collect the droppings and bury them, compost them, or
flush them down the toilet. Your neighbors and the lake will appreciate
it.
13. Do not clean driveways and sidewalks by hosing the dirt into the
street, but sweep it onto your lawn, or collect the dirt for disposal
elsewhere.
14. Keep your gutters clean and, if possible, dispose of the water
on your property so it can soak into the ground.
-------
Appendix D
Soil Conservation Service
Soils Data
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
10850 Traverse Highway, Suite 1105, Traverse City, Michigan
December 1, 1978
Mr. Dennis J. Sebian, PE
WAPORA, Inc.
6900 Wisconsin Avenue N.W.
Washington, D.C. 20015
Dear Mr. Sebian,
The enclosed table and soil interpretations are the results of the soils
study made in the Crystal Lake area of Benzie County you requested for
the ElS you are preparing on proposed waste water facilities.
The table lists the items you requested with the exception of phosphorus
absorption capacity which is an interpretation we do not make. The
investigations were made on the lots you designated on the location map
as closely as possible. The predominant soil series and slope ranges are
indicated in the outlying areas. Soil interpretation pages for each soil
series indicated are enclosed.
The water level of Crystal Lake evidently was lowered some 100 years ago as
indicated by the elevation marker near the north shore of the lake. Many
of the lots investigated are in the lowered lake level zone and a natural
soil profile has not had time to develop. Natural drainage conditions
and depth to seasonal high water table were difficult to determine in
many instances.
A majority of the lots investigated had summer seasonally occupied dwellings
on them. The permeability is rapid in most of the soil material. The
septic tank absorption fields may operate during the dry season but the
water table being at a relatively shallow depth in much of the area by the
lake may be contaminated by leachate from the septic systems.
Parts of some of the outlying areas are in intensive use like subdivided
platts, orchards, and golf courses or are dissected by waterways which
would make them unavailable or their use restricted for effluent disposal.
If clarification of any of this material is needed, please let me know.
Sincerely,
/s .,£&/C«
-------
Crystal Lake Area of Benzie County, Michigan
Depth to seasonal
Permeability high ground water Slope
Location (inches/hr.) level (%}
SEG.1 (north 1)
(north 2)
SEG.1 (south 1 )
(south 2)
SEG.2(west 1 )
(west 2)
SEG.2(east 1 )
(east 2)
SEG.3(west 1)
(west 2)
SEG-3( center 1)
(center 2)
SEG.2(east 1 )
(east 2)
SEG.l|(east 1 )
(east 2)
SEG. lowest 1)
(west 2)
> 20
6-20
6-20
6-20
6-20
6-20
6-20
6-20
6-20
2-20
6-20
2-20
6-20
6-20
6-20
6-20
6-20
.2-. 6
6 inches
6 inches
15 inches
15 inches
1 8 inches
30 inches
15 inches
15 inches
^ 60 inches
x"60 inches
^"60 inches
x"60 inches
1 8 inches
21; inches
2k inches
15 inches
15 inches
6 inches
0-1
0-1
1-3
1-3
o-k
o-k
0-2
0-2
18-30
18-30
0-2
12-30
0-2
0-2
0-3
0-3
0-2
0-2
Limitation
and/or
hazard for
absorption
field Observation Notes
wetness
wetness
wetness
wetness
wetness
wetness
wetness
wetness
(1)
(1)
(1)
(1)
wetness
wetness
wetness
wetness
wetness
wetness
water table at 21; "
water table at I|.6"
water table at 36"
3" fill material
water table sb 36"
water table at 1|2"
house built on dug
out and leveled area
hilly area above blufi
water table at 36"
water table at lj.2"
(north side of road)
water table at 60"
( south side of road)
water table at 2?"
(south side of road)
water table at 1;8"
(north side of road)
water table at 30"
-------
Crystal Lake Area (Cont'd)
Page 2
Depth to seasonal
Permeability high ground water Slope
Location (inches/hr.) level (%}
SEG. 5( west 1 )
(west 2)
SEG. 5 (center 1 )
(center 2)
SEG.5(east 1)
(east 2)
SEG. 6( west 1)
6-20
6-20
6-20
6-20
2-20
.6-20
6-20
6 inches
6 inches
> 60 inches
15 inches
6 inches
36 inches
1 2 inches
0-2
0-2
2-6
0-2
0-2
0-3
0-2
Limitation
and/or
hazard for
absorption
field Observation Notes
wetness
wetness
(1)
wetness
wetness-
flooding
0)
wetness
water table at 18"
(2 ft. of sandy fill
on much of the lot)
water table at 15"
north side of road
south side of road
55" alluvium
6" clay loam overwas!
12" fill material
(west 2)
6-20/.2-6
SEG.6(east 1) 6-20
water table at 29"
15 inches 0-2 wetness 6" fill material
water table at 36"
clay loam at lj.2"
6 inches 0-2 wetness 6" fill material
water table at 36"
(east 2) 6-20/.2-.6 15 inches
0-2 wetness water table at 1;0"
sandy loam at IjV'
SEG.7/8( west 1) 2-20
(west 2) 6-20/.2-.6 10 inches
SEG.7/8(center 1) 2-20
(center 2) 2-20
SEG.7/8(east 1) 6-20
18 inches 6-18 wetness sandy to loamy fill,
springs, water table
at 23"
0-2 wetness 10" of fill material
clay loam at 2?"
drains nearby
21; inches 1; wetness- waterway and col-
flooding luvium water table at
36"
^60 inches 12-18 (1) houses on cut and
fill on hill
,>60 inches 6-12 (1) house on cut and fill
-------
Crystal Lake Area (Cont'd)
Page 3
Permeability
Location (inches/hr.)
SEG
SEG
SEG
SSG
SEG
SEG
SEG
SEG
(east 2)
. 9/1 0( north 1
(north 2)
. 9/1 0( south 1
(south 2)
.9/1 0( center
(center 2)
.11 (west 1)
. 11(west-
center 1 )
(west -
center 2)
.11 (east-
center 1 )
(east -
center 2)
.11 (east 1)
(east 2)
.12(west 1)
6-20
) 6-20
6-20
) 6-20
2-20
1)6-20
.2-20
6-20
>20
6-20
.6-6
6-20/.2-.6
2-20
6-20
.2-. 6
.2-6
Depth to seasonal
high ground water Slope
level (%}
^60 inches
?60 inches
x" 60 inches
^"60 inches
> 60 inches
? 60 inches
/"60 inches
15 inches
>60 inches
>60 inches
1|0 inches
30 inches
6 inches
1 8 inches
>60
>60
2-6
1-li
1-2
3
1-U
10
1-U
0-2
1-3
10
8-12
1-6
0-2
0-3
6-18
10-30
limitation
and/or
hazard for
absorption
field
(D
(1)
(0
0)
(D
0)
(1)
wetness
(1)
0)
wetness
wetness-
percs
slowly
wetness
wetness
percs
slowly
percs
slowly ( 1 )
Observation Notes
in back of bluff
to Lake Michigan
on side of hill
on top of hill
water table 1*8"
old beach, ridge
moderately well
drained
moderately well
drained
aquafer at U8"
perched water
table at 21;"
water table at ij.8"
above Nester bluff
(west 2) 2-20
6 inches
1-3 wetness water table at 36"
-------
Crystal Lake Area (Cont'd)
Page k
Location
Permeability
(inches/hr.)
Depth to seasonal
high ground water Slope
level (%)
Limitation
and/or
hazard for
absorption
field Observation Notes
SEG.12( center 1 )
(center 2)
SEG.12(east 1)
(east 2)
SEG.13(west 1)
(west 2)
SEG«13( center 1 )
(center 2)
SEG.13(east 1)
(east 2)
SEG«lU(west 1)
(west 2)
SEG.1it( center 1 )
(center 2)
SEG«1l|(east 1)
(east 2)
SEG.l5(west 1)
(west 2)
SEG.l5(east 1 )
2-20
.2-. 6
6-20
6-20
6-20
6-20
>20
6-20
6-20*
6-20
6-20
6-20
6-20
6-20
6-20
2-20
6-20
6-20
.2-20
12 inches
>60
12 inches
1 8 inche s
18 inches
2h inches
,>60 inches
12 inches
>60 inches
18 inches
>60 inches
18 inches
>60 inches
1 8 inche s
30 inches
2k inches
15 inches
15 inches
6 inches
0-3
18-50
0-3
0-3
0-2
0-2
o-h
0-2
12-18
0-3
6-18
0-3
12-30
0-3
0-3
0-3
0-3
0-3
0-2
wetness
water table at 30"
Slope and springs and gullys
percs slowly
wetness
wetness
wetness
wetness
0)
wetness
slope ( 1 )
wetness
slope (1)
wetness
slope ( 1 )
wetness
wetness
wetness
wetness
wetness
flooding-
water table at 30"
water table at 1|8"
water table at 50"
water table at 50"
water table at kS "
-X-.2-.6 layer at 2k"
in part of the area
water table at i|0"
strata of sandy
loam in bluff face
water table at 30"
strata of sandy loam
in bluff face
water table at 30"
water table at i|.8"
water table at 36"
muck at U8-55"
water table at 30"
water table at 1±8"
floodplain
wetness water table at 30"
(east 2) > 20
>60
10
0)
old beach ridge
-------
Crystal Lake Area (Cont'd)
Page 5
Permeability
Depth to seasonal
high ground water Slope
Limitation
and/or
hazard for
absorption
Location (inches/hr.)
SEG.l6(west 1)
(west 2)
SEG.l6(east 1 )
(east 2)
6-20
6-20
6-20
> 20
level
30 inches
15 inches
18 inches
1 8 inches
(%}
0-3
0-3
0-3
0-3
field
wetness
wetness
wetness
wetness
Observation Notes
water table at 36"
water table at 2k"
water table at 36"
water table at 60"
Village of Benzonia
(ME Cor. 1)
(HE Cor. 2)
(west)
(south)
S₯ Cor. Sec. 35
SE Cor. Sec. 26
.6-20
.6-20
.2-6
6-20
.2-6
.2-20
> 60 inches
>60 inches
>60 inches
^ 60 inches
original
surf ac e
> 60 inches
1-3
1-3
6-12
2-6
0-1
2-6
(1)
(1)
percs
slowly
(1)
wetness
slow perc
and (1)
on edge of steep area
on edge of steep area
water way on lot
k-5 feet of sandy and
loamy fill over muck
complex of Kalkaska,
Leelanau, arid Nester
NE Cor. Sec. 35 6-20
(east)
NE Cor. Sec. 35 6-20
(west)
> 60 inches 6-12 (1) slope
> 60 inches 1-3 (1)
house on terraced
lot with cut and fill
waterway crosses lot
(1) Pollution hazard to shallow water supplies
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Appendix E
Region V Guidance
Site Specific Needs
Determination and Alternative Planning
For Unsewered Areas
-------
REGION V GUIDANCE
SITE SPECIFIC NEEDS
DETERMINATION AND ALTERNATIVE PLANNING
FOR UNSEWERED AREAS
I. Objective
The objective of this guidance is to simplify fulfillment of the
requirements regarding the demonstration of need for sewage treatment
associated with the application of Program Requirements Memorandum (PRM)
78-9, "Funding of Sewage Collection System Projects" and PRM 79-8,
"Small Wastewater Systems." This guidance is written particularly with
respect to the needs of small, rural communities and the consideration
of individual on-site and small alternative technology. It suggests
procedures which may be utilized to reduce the time, effort, and expense
necessary to demonstrate facilities needs. It is also intended to
provide guidance pertaining to the selection of alternatives for a cost-
effectiveness comparison. It is not intended to allow indiscriminate
definition of need based upon "broad brush" use of a single criterion.
The procedure recommended herein may not be the optimum procedure for
all projects. Compliance with this analysis will be priraa facie
evidence for the acceptability of the "needs" portion of a proposed plan
of study. If another method is proposed for obtaining and documenting
the needs Justification, it is recommended that the grant applicant
discuss the proposed approach with reviewing authorities prior to the
submission of the pian of study and the Step 1 grant application.
This guidance is predicated on the premise that planning expenditures
should be commensurate with the cost and risk of implementing feasible
alternatives for a specific planning area. The guidance further
recognizes the complexity of planning alternative technology. It
presents procedures for, and rationally limits, the amount of detailed
site investigation necessary to determine the suitability of alternative
technology for site specific areas within the community, and allows for
A degree of risk inherent to limited data gathering.
II. Goal
The goal of this guidance is to enable the community to categorize the
residences into three groups. The three groups are those residences
experiencing a) obvious sewage treatment problems with clearly defined
solutions b) no problem and c)exposure to potential problems
representing a planning risk that requires resolution by the acquisition
of original data.
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2
III. Criteria for site-specific needs determination.
A. Direct evidence that demonstrates obvious need
due to malfunctioning systems includes:
1. Failure by surface (breakout) ponding of filter field discharges
can be identified through direct observations, mailed
questionnaires, and remote imagery (infrared photography).
2. Sewage backup in residences can be identified through response
to mailed questionnaires, knowledge of local septage haulers, or
knowledge of local health or zoning officials.
3. Detected sewage effluent or tracer dye in surface water, by
means of site visit or various site effluent detection systems.
A. Flowing effluent pipe detected by remote infrared photography,
site visits, knowledge of local officials, or results of mailed
questionnaires.
5. Contamin it ion of water supply wells (groundwater) can be
demonstrated by sampling and analyses for whiteners, chlorides,
nitrates, fecal colJEorm bacteria, or other indicators, and a
finding of their presence in concentrations which significantly
exceed background Levels in groumlwaters of the area or primary
drinking water quality standards, newonstratton of trends
toward groundwater pollution due to malfunctioning systems could
aid in concluding a problem exists.
B. Indirect evidence that may demonstrate inferred need due to
limitations of treatment systems includes:
1. Seasonal or year-round high water table considering possible
water table mounding by residential use. Seasonal or annual
water table can be determined by taking transit sightings from a
known lake level, if the dwelling in question is adjacent to a
lake or other surface waters. Elsewhere, Soil Conservation
Service maps may indicate depth to groundwater. If these data
are unavailable, soil borings may be employed during an on-site
investigation described below.
2. Water well isolation distances (depending on depth of well and
presence or absence of impermeable soils). Isolation distances
may be addressed in part by lot size. In cases where a
community water system is installed or is concurrently planned,
this criterion will not be considered. Lots, Including
consolidated lots, which are less than 10,000 square feet in
area will be assumed to have insufficient isolation distances.
However, before this criterion may be used as areawide evidence,
a correlation with results of limited representative sampling
which substantiate water well contamination must be made.
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-3-
3. Documented groundwater flow from a filter field toward a water
supply well can often override seemingly adequate separation
distances.
4. Bedrock proximity (within three feet of filter field pipe) can
be assessed by utilizing existing SCS soils maps. If reasonable
suspicion exists that bedrock will be a site limitation and it
cannot be quantified, an on-site investigation may include
representative soil borings as appropriate.
5. Slowly permeable soils with greater than 60 minutes/inch
percolation rate.
6. Rapidly permeable soil with less than 0.1 min/inch percolation
rate. Soil permeability will be assessed by evaluating existing
SCS soils maps and related use limitations data. Should the
data be unavailable, and should other data indicate strong
possibility of permeability-related lot limitations, appropriate
numbers of soils borings may be made during the on on-site
investigation.
7. While holding tanks, in certain cases, can be a cost-effective
alternative, for purposes of site-specific needs determination a
residence equipped with a holding tank for domestic sewage
should be considered as indirect evidence of need for sewage
treatment facilities. Location of holding tanks will be
identified through records of local permitting officials,
septage haulers, and results of mailed questionnaires.
8. On-site treatment systems which do not conform to accepted
practices or current sanitary codes may be documented by owners,
installers, or local permitting officials. Extreme methods of
disposal, such as, cesspools, the proverbial "55 gallon drum"
septic tank and systems which feature direct discharge of septic
tank effluent to surface or ground water will be considered
direct evidence of component failure.
9. On-site systems a) incorporating components, or b) installed on
individual lots or c) of an age, that local data indicate are
characterized by excessive defect and failure rates, or non-
cost-effective maintenance requirements.
IV. Needs Determination For Unsewered Communities
For projects in which the scope of work is difficult to assess during
the Step 1 application, it is recommended that Step 1 be divided into 2
phases to more effectively allow estimation of the planning scope and
associated costs. Phase 1 will consist of a review of existing or
easily obtainable data. Phase II will consist of on-slte investigation
and repv;esentati/e sampling necessary to confirm assumptions based on
indirect evidence identified in Phase I. Alternatives development for
those lots determined to have need may be completed and incorporated
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-4-
into the facilities plan. Both phases should be addressed in the plan
of study and grant application. This is discussed in greater detail
below.
A. Phase I
The review of existing or easily obtainable data may include the
following as appropriate:
1. a mailed questionnaire regarding each resident's knowledge of the
on-site system and its performance
2. review of soils maps
3. review of local permit records
4. lot elevations to estimate depth to water table (lakeshore areas)
5. calculation of lot sizes
6. remote photographic Imagery (e.g., infrared)
₯
7. leachate detection sensing of ground or surface water in the area.
This preliminary data will be used to categorize each lot within the
planning area into one of three groups:
a) obvious-problem
b) no-problem
c) inconclusive
The "obvious-problem" group consists of those lots where at least one
criterion of direct evidence of a need (specified on page 2 of this
guidance) is satisfied or where, by summarizing indirect evidence
validated with limited sampling, there exists a high potential that a
problem does exist. (See Phase II Work, On-Site Investigation, as
outlined below.)
The "no-problem" group consists of those lots where there is evidence
that the present system is adequate and functioning properly, and likely
to continue to do so with proper, cost-effective operation and
maintenance, based upon the review of available information.
The "inconclusive" group consists of the remaining lots where available
information does not substantiate their placement Into either the
"obvious problem" or "no-problem" category.
The next step is to attempt to recategorize the "inconclusive" group
into either group (a) or (b) by making reasonable assumptions based upon
known information and to plan detailed on-slte investigations to obtain
supporting data, This on-site investigation would consist of
representative sampling to confirm the assumptions made based upon the
-------
5
inferred evidence criteria noted in section III. B. The on-site
investigation would also be the source of information on those lots
where information was not previously available.
For example, on-site systems located on lots with apparent continuous
high groundwater and very tight soils could be placed in the "obvious-
problem" category, even though then1 is no direct evidence of failure.
The on-site investigation, however, should validate the assumption by
representative sampling to confirm that Indeed there is high groundwater
and tight soils in this area and obtain further information that this is
causing a problem with on-site systems.
In addition, it may be necessary to gather field data on a minimum
number of lots where the evidence is not available to substantiate the
placement of these lots into either the "no-problem" or "obvious-
problem" group.
Indirect evidence, which is based primarily on construction standards,
generally identifies lots which probably do not have adequate on-site
systems. This probability is verified by a small amount of on-site
investigation as explained in Phase II. Indirect evidence does not
identify lots which have no site limitations but which in fact do not
have an adequate operating system. The use of indirect evidence alone,
may result in the erroneous conclusion that the on-site system is
adequately operating. This situation is especially prevalent in areas
with high percolation rates, where system failure is not evident to the
observer. Thus, a sampling program should consider, to some extent,
lots that exhibit no indirect evidence of need.
B. Mid-Course Review
At the end of Phase I, the results of the Phase I effort should be
presented for review and concurrence before proceeding to Phase II. The
Mid-Cjurse Meeting facilities plan review is an appropriate time for the
presentation and discussion o£ the Phase I results. Phase II will
consist of on-site investigation and sampling, alternative development
for specific need areas and completion of the facilities plan.
The following should be considered at the Mid-Course Meeting:
1. It may become apparent during Phase I that on-site alternative
technology systems will not approach the cost-effective solution for
the substantially defined obvious need area. In this case a
preliminary cost estimate for conventional collection and treatment
should be compared to that for the innovative/alternative treatment
solution. If cost estimates and technical analysis indicate that
the use of alternative technology is not coat-effective, the
analysis may be terminated and a cost-effective collection and
treatment solution developed without proceeding into the on-site
investigation of Phase II. This would also apply in areas where a
substantial obvious need has been Justified, where a high
concentration of dwellings occur in a municipality, and where on-
-------
-6-
site systems would not be a viable solution because of site
limitations. Any such exclusion of on-site treatment should be
clearly quantified and supported by documentation :*n accordance with
PRM 78-9 and PRM 79-8.
2. The number of lots to be investigated during the on-site evaluation
should be reasonably estimated. If the original estimation of on-
site work included in the Step 1 Grant Agreement is found to be in
error at the end of the preliminary evaluation (Phase I), a request
to amend the grant amount, if necessary, may be submitted and a
grant amendment expeditiously processed provided there is
concurrence at the Mid-Course Meeting.
3. The manner of presenting this data in the Facilities Plan is
discretionary, although it should be clearly apparent to anyone
reading the Facilities Plan upon what basis a given residence was
determined to have or not have a need for waetewater treatment.
Should need be demonstrated for a giv'en residence, sufficient
information should be acquired to determine potential treatment
alternatives. (For example, if a repidence is determined to need
treatment facilities on the basis of an Illegal discharge of septic
tank effluent, additional inform.it 1 on will be required to determine
if any limitations to on-site trt-atment exist).
C. Phase II Work
Indirect evidence, requires reasonable verification in order that a lot
be placed into the "obvious need" category. This is accomplished by
identifying combinations of indirect evidence criteria that indicate an
increased risk or potential of a problem, and representative sampling.
Sampling results supporting a significantly increased risk justify
placement of a lot into the "obvious-need" category.
For example, an on-site system located on a lot with marginal soils
(i.e., a percolation rate of about 60 min/in) would be considered a low
risk situation. If, however, this same lot has adjacent lots with
direct evidence of malfunctioning systems and has a short-duration of
seasonal high groundwater, for example, the combining of low risk
factors elevates the net risk to a high risk situation. After
representative sampling of these parameters during the on-site
investigation to confirm these assumptions, placement of all similar
lots into the "obvious-need" category can be made.
Representative Sampling Method
The planning of representative sampling should address the following
considerations on the basis of Phase I results:
1. Delineate areas that exhibit indirect evidence and/or inconclusive
need.
2. Delineate areas, if possible, that exhibit one or more common
-------
limiting physical parameters that may be associated with a type of
indirect evidence of need.
3. Sample to confirm the assumed physical constraint for on-sit.e sewage
treatment or the indirect evidence of need and correlate with actual
occurance of wastewater treatment deficiencies. The number of lots,
or public areas or rights-of-way adjacent to private lots exhibiting
inconclusive or indirect evidence of need that are to be further
analyzed normally should not exceed 30% but should be at least 15%
of the total lots within a discrete area assumed as exhibiting an
inconclusive need or indirect evidence of need. Measurable
constraints to sewage treatment may be: high groundwater and Its
deoth, predicted duration and recurrence interval, groundwater flow
direction and velocity, depth to bedrock, highly permeable or
impermeable soils that do not allow for treatment, and the physical
condition of existing on-site systems. Sampling may be random or
stratified according to the requirements of the analytical design
selected as appropriate to test the strength of an assumption. In
any event, decisions about what is to be sampled, the sampling
design and the size of the sample should meet the test of cost-
effectiveness .
4. Water quality parameters that can be evaluated and utilized as
pollution indicators include, but are not limited to: chlorides,
nitrates, phosphate, fecal coliform, surfactants, whiteners or other
synthetic organica inherent to domestic wastewater.
5. The analysis should be completed and study areas classified as
exhibiting direct evidence of pollution problems, indirect evidence
of pollution problems, the combination of direct and indirect
evidence, and no need. If, after the Phase II analysis is
completed, discrete areas of the Plan of Study Area (POSA) remain
inconclusive as to evidence of need, no need may be construed for
those areas.
V. Planning for treatment alternatives
Based upon data assembled during Phase I and Phase II, residences should
be categorized as follows:
1. Residences having adequate treatment facilities (no-problem).
If a conveyance system determined to be cost-effective to transport
wastewater passes a lot that has no need for sewage treatment, there
will be no limitations on hookups to the sewer. However, a sewer
will not be funded by EPA if the sewer is purposely routed to areas
exhibiting no need.
2. Residences not having adequate treatment facilities
a) Capable of on-site upgrading of septic tank and filter field
(standard system).
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-8-
b) Capable of on-site upgrading with non-standard on-site
treatment.
c) Not capable of on-site upgrading (treatment must be off-site).
Preliminary alternatives to be compared for cost-effectiveness should
Include a combination of selective no-action, on-site upgrading, and
off-site treatment alternatives. For each discrete area, the generally
determined generic alternative should reflect the specific need defined
by the common physical linitation of the discrete area.
Standard system upgrading is defined as expansion of an existing filter
field, construction of a filter field, repair or replacement of
defective components or construction of an entire on-site system in
compliance with approved specifications. This alternative is viable
where lot limitations such as small size, or slow percolation would not
preclude it.
Non-standard on-site system upgrading may include a mounded filter
field, alternating beds, pressure distribution systems, aerobic systems,
sand filters and other alternatives permissible under the State and
local code. These should be considered where lot size and water well
isolation distances are adequate, and where other limitations such as
high groundwater and slow percolation preclude standard systems. Off-
site treatment such as cluster systems should also be considered in such
cases, and possibly graywater/blackwater separation.
Septic tank replacement should be considered only as necessary. For
purposes of cost-effectiveness calculations, the number of septic tanks
requiring replacement should be estimated on the basis of permits issued
and knowledge uf local septic tank pumpers and installers regarding the
type, life, age and condition of existing installations. Information on
the size and condition of the current treatment systems, gathered during
home-to-home interview surveys, sampling and inspections, should also be
used. For those systems for which information pertaining to septic tank
conditions cannot be obtained, cost-effectiveness calculations should
assume 100% replacement.
When a ^ystem is found to be malfunctioning on the basis of direct
evidence, information pertaining to lot limitations must also be
obtained. This information should be sufficient to allow for
alternatives planning, and should include all relevant parameters listed
under Item III. B. of this memorandum,
Limitations on Planning
Estimation of the cost-effectiveness of on-site treatment in general,
and of particular types of on-site treatment, should be based on
information acquired during Phase I and Phase II, including any
representative sampling. Only the limited amount of on-slte
investigation, normally less than 30% of the total lots that exhibit
inconclusive need and/or indirect evidence of need, should be conducted
-------
-9-
in the j'hase II portion of the Step 1 grant.
When generic on-site solutions are generally determined for discrete
areas, it is contemplated that it will normally be cost-effective to
specify construction requirements through the use of generic component
designs; plans; performance, quality and workmanship specifications; and
unit price/estimated quantity procurement.
Field work necessary to select the design of individual drainfields
including on-site soil borings, percolation tests, surveying, work to
specifically identify present septic tank and soil absorption field
location and inspection is generally to be viewed as Step 3 work. For
practical purposes, site-specific design and construction should
normally proceed in tandem on a lot-by-lot and area-by-area basis. The
establishment of a management district's authority must be completed
before a Step 2 or 2+3 award. The development of a management
district's program must be completed before a Step 3 grant award or
before Authorization to proceed with construction procurement is granted
under a Step 2+3 grant.
VI. Public Participation
The following comments arc intended to demonstrate how this guidance
relates to the standard requirements for public participation. It is
not all inclusive.
A. A useful "mailing list" may include all owiiers of residences within
unsewered areas in the planning area and other interested -ind
affected parties.
B. The public meeting required by 40 CFR 35/917-5, provides an
opportunity for property owners to be informed of whether or not
they have been found to need wastewater treatment facilities.
During the meeting they can respond to the consultant's
determination of their need status. A map with each lot designated
as no-need, obvious-problem, or inconclusive, would be helpful for
public understanding. This meeting could be conveniently scheduled
at the end of Phase I.
C. The final public hearing required by 40 CFR 35.917-5(b) should be
scheduled at the end of facilities planning.
-------
Appendix F
Revised Effluent Limitations for
Discharge to Betsie Lake
-------
STATE OF MICHIGAN
UUAI C.FSOlHCtS COMMIjt> \j)
We have received the following information. The revised rccommsHadatidits
resulted from the Advanced Waste Treatment checklist justification made
by the Comprehensive Studies and Biology Sections. The proposed discharge
would be Betsie Lake in Section 27, T26N, R16W. The proposed design
flow would be 0.6 MGD.
Betsie Lake at the above location is protected for coldwater fish, total
body contact recreation, industrial water supply, navigation, and agricultural
uses .
The Biology Section recommends that land treatment alternatives be employed
if at all possible, however, if this is not feasible, the waste should
be discharged through the channel at Lake Michigan instead of to the
lake itself.
For a discharge at or below the 0.6 MGD design flow to Betsie Lake,
the following effluent limitations are recommended:
5-Day Biochemical Oxygen Demand (Total) 30 mg/1 as a 30-day average,
45 mg/1 as a 7-day average.
Tol.'il Sur-penJer! Solids - 30
7-day average.
as a 30-day average, 45 ir.^/1
pH not less than 6.0 nor more than 9.0.
Fecal coliform bacteria 200/100 ml as a 30-day geometric mean, 400/100
ml as a 7-day geometric mean.
Total residual chlorine 0.024 mg/1 as a daily maximum (lake discharge),
0.05 mg/1 as a daily maximum (channel discharge).
MICHIJ&W
IHf
GMfAT
IAKC
»!»U
111026 1/79
-------
Total phosphorus as P 1.0 wg/1 as a 30-day average.
Please feel free to contact myself or Clif Clark of ray staff should
you have any questions regarding this letter.
Very truly yours,
WATER QUALITY DIVISION
Richard Hinshon, Chief
Grants Administration Section
RH/CC:clp
cc: City of Frankfort
Village of Elberta
MeNamee, Porter & Seeley, Inc.
Fred Eyer
Engineering & Technical Services Section
Planning Section
Municipal Design Review Section
H. W. MI. Reg. Plann. and Dev. Comm.
-------
Appendix G
Sample Easement Form
-------
SEWER EASEMENT AND RIGHT OF WAY
(I) (WE)
of
respectively, in consideration of the prospective benefits to.be derived from
a new or upgraded sewer and/or improved water quality in Crystal Lake, do
hereby convey and release to the (to be decided)
an casement and right of way for unlimited access to the present or future on
site sewer system or other systems of sewage disposal, at all reasonable times
for such purposes as inspection, monitoring, construction, maintenance,
operation, rehabilitation, and replacement, over, upon and across lands owned
by (me)(us) end situated in the Township of , County of
Benzie, State of Michigan, and more particularly described as foTTows:
In witness, whereof, I have hereto set my hand this day of
, 19
WITNESSES:
STATE OF )
) ss.
COUNTY OF )
Subscribed and sworn to before me this day of , 19
Notary Public
My commission expires-:
GOVERNMENT PRINTING OFFICE 1980654-262
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1
U.S. Environmental Protection Agency*
Region V, Library
230 South Dearborn Street "
r "*o, Illinois 60604
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