EPA-5-IN-STEUBEN-STEUBEN LAKES-LA-30


             "FINAL ENVIRONMENTAL  IMPACT STATEMENT

ALTERNATIVE WASTEWATER TREATMENT SYSTEMS FOR RURAL LAKE PROJECTS

    CASE STUDY No. 4:  STEU8EN LAKES REGIONAL WASTE DISTRICT

                     STEUBEN COUNTY, INDIANA
                         Prepared by the

         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                   REGION V, CHICAGO, ILLINOIS
                               AND
                      WAPORA, INCORPORATED

                        WASHINGTON, D.C.
   us Environmental  Protection Agency,
   Chicago,  Illinois
                   60604
                                           Approved by:
hn McGuire
gtonal Administrator
                                           December 1980

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                              PREPARERS








     This Final Environmental Impact Statement was prepared by




WAPORA,  Inc.,  under the guidance  of Ted  Rockwell and Kathleen  Schaub,




EPA  Region  V   Project  Officers.    Mr.   Edward  Wandelt  was  WAPORA1s




Project  Manager  for the Final  EIS.  Invaluable  assistance  was  provided




by Gerald 0.  Peters, Dr.  Ulrich Gibson,  and Henry Bartholomot.








     Much  of  the  material  in  the Draft  EIS  was provided by  numerous




subcontractors; they are listed in that document.

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                               EXECUTIVE SUMMARY

Background

     The  1979 Draft  Environmental  Impact  Statement  (DEIS)  on  Alternative
Wastewater  Treatment  for  Rural  Lake  Projects,  Steuben  County,   Indiana,
addressed issues raised during the review of the 1976 Facilities Plan.   Issues
included:  the  high cost  of  centralized collection and  treatment  (1980 con-
struction cost of  $20.8  million),  uncertain water quality improvements to the
Steuben  Lakes,  economic  effects on  area  residents,  and  the potential  for
induced growth with its associated secondary impacts.

     The Facilities Plan,  prepared by Mick, Rowland and  Associates,  proposed
the construction of a  regional wastewater collection system and a centralized
treatment facility.  On-site wastewater treatment systems, which are currently
in  use  in  the Study  Area,  would  be  abandoned.  Gravity  sewers,  utilizing
grinder  pumps  and  low pressure  sewers in some low-lying  areas,  would convey
wastewater to a 140-acre treatment site, which has  not  yet been selected, in
the northwestern part  of the  Study Area.  The  wastewater would be treated in
aerated  lagoons, chlorinated,  and  subsequently applied to  the  land  via spray
irrigation.    The  secondary  effluent   would  be utilized  for  controlled farm
operations with either row crops and/or forage crops.    An underdrain system
would be installed at the site to collect the renovated water for discharge to
Crooked  Creek.   The  effluent  would  meet  the  following  National  Pollution
Discharge Elimination  Systems (NPDES) permit  limitations:   BOD-10  rag/1, sus-
pended  solids-10  mg/1,  pH-6.0  to  9.0,  and  fecal  coliform-200 per  100 ml.

     In order to assess the appropriateness and the environmental consequences
of the proposed plan,  EPA conducted a variety of tests.   These tests included
an  aerial  photographic  survey of surface  malfunctions;  two  septic  leachate
surveys  of the  eight  potentially affected lakes  (Jimmerson Lake,  Lake James,
Lake Charles,  Snow Lake,  Big Otter Lake,  Little Otter  Lake,  Lime  Lake, and
Crooked  Lake);  a  groundwater  survey;  and  detailed  soil, groundwater,  and
aquatic  plant  analyses  of selected wastewater  treatment  systems  in shoreline
areas.    However,  data from the  second  septic  leachate   survey  and  the site-
specific analyses,  were not available in time to be used in the preparation of
the 1979 DEIS.

     All the  above studies found  that  only  a few  on-site treatment systems
were having  any  impact  on  water quality  even  though  many systems  did not
comply with  the Steuben  County  sanitary code.   Water quality modeling indi-
cated that none of the EIS or Facilities Plan alternatives would have a signi-
ficant effect on lake water quality or trophic status.

     A wide range  of  alternatives  were developed and evaluated during the EIS
process.  These ranged  from highly centralized (the Facilities Plan Alterna-
tive and some  variants)  to  largely  decentralized (Limited  Action  and No-
Action).  Total present-worth costs  of alternatives ranged from $23.2 million
for  the  Facilities  Plan Alternative  and $8.3 million  for the  DEIS  Limited
Action Alternative,  to $6.4  million  for the Final  EIS  (FEIS)  Limited Action
Alternative,  which would serve the shorelines with on-site maintenance and up-
grading.  The alternatives  differed   greatly  in  their  potential  impacts on
local costs,  future population, and future land use.

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     The DEIS  recommended  the  Limited Action Alternative, which would  result
in generally  comparable water quality impacts  at  a much lower cost  than  any
other alternative.   The Limited Action Alternative  would include decentralized
systems for all parts of the Proposed Service Area  and would include a program
to replace  and  rehabilitate on-lot  systems,  where  necessary, in order  to
alleviate existing water quality  and public health problems.   The  utilization
of on-site facilities throughout the Study Area would constrain future popula-
tion  growth  to below  the  level  that  was anticipated  with the provision  of
centralized wastewater  treatment.   Under the Limited Action  Alternative,  the
in-summer population growth would  be limited  to  22%  in  excess  of  the  1975
level  (from  1975  population of  22,440 to  2000 population of  27,346).   This
level  of  population growth  would  necessitate converting of 600 acres  of  un-
developed land  to  residential  land use.   The  resultant  development  patterns
would be more  scattered and at a lower density than the potential density to
be accommodated by a centralized treatment alternative.

Comments

     After the  November 1979  publication of the  DEIS, a  Public  Hearing  was
held on 28 January 1980 in Angola, Indiana.  Numerous people attended and many
comments were received, many of them in writing (see Appendix A).   In general,
the comments concerned:

     •  Clarifying of  the  administrative  elements  of  the  alternative recom-
        mended in the Draft EIS

     •  Ascertaining the suitability of area soils  for upgraded on-site treat-
        ment and their ability to provide long-term treatment

     •  Learning the costs  and Federal funding eligibility for the Draft  EIS
        Limited Action Alternative.

Responses

     After the comment period closed, EPA scrutinized the results of the field
studies conducted during the summer of 1979.  These studies included a ground-
water  hydrology survey,  a  second septic  leachate  survey,  and detailed soils,
groundwater, and aquatic plant analyses  of  six  on-site sewage treatment sys-
tems  in shoreline areas.   The results of prior work  were  confirmed and the
body of knowledge about the effects of on-site systems was increased.

     EPA  also  clarified  Federal,  State,  and  local  administrative questions
about  the  formation of a  Small  Waste Flows District.  The new features of a
district to manage on-site treatment systems  include:

     •  A  Regional  standard  for  project  needs   documentation  requirements
        (see Appendix B)

     •  Methods to  reduce  the  cost and  complexity  of  detailed site work and
        to expedite the processing  of innovative and alternative grant
        applications
                                      ^v

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     •  A variety of  approaches  to simplify easement and access requirements.
        (This  process,  which  is  still ongoing,  could eliminate the  expense
        and complexity of easement acquisition [see Appendix C].)

     Finally,  EPA described  the  No-Action Alternative in  greater detail than
provided in the DEIS and re-examined the Limited Action Alternative.   Costs of
the Limited  Action  Alternative were revised to reflect the more detailed work
plans for the  site-by-site  engineering and environmental analysis,  as well as
for  long-term  operation  and  maintenance.   These costs  were estimated  on a
conservative basis.    The  cost  review of the Limited  Action Alternatives also
revealed some  calculation errors  that showed the present  worth to  be higher
than it should have  been.  In total, these changes reduce the present worth of
the Limited  Action  Alternative from $8,268,700 to  $6,443,200.   This decrease
does  not  change  the ranking  of  alternatives.   The present  worth of  the
No-Action Alternative was estimated to be $3,363,100.

The Final EIS

     This FEIS is  considerably   shorter  than the  DEIS.   Elements  that were
discussed at length in  the  DEIS   are summarized here,  with emphasis  placed on
responses  to  comments  and  explanations of  management procedures and costs.
This approach  is  consistent  with the Council  on  Environmental  Quality's 1978
National Environmental Policy Act (NEPA) compliance regulations.

Recommendations

     The various administrative changes, field surveys and responses  to public
comments have  not  changed basic  assumptions  or  information  published in the
DEIS.  Changes and  new  information have not  substantially altered the nature
or  ranking  of  alternatives.    Therefore,  the  recommended  action  remains
basically as it was  in the DEIS:

     •  To design and implement the Limited Action Alternative

     •  To  perform  site-specific  environmental  and  engineering analyses of
        existing on-site systems   in the Proposed Service Area

     •  To repair and replace on-site systems, as required.

     Should  the Steuben  Lakes  Regional Waste District (SLRWD) wish to proceed
with the Limited  Action Alternative.  EPA  recommends  that careful  considera-
tion be  given to the sections of  the  FEIS on Management and Implementation,
(Chapter II, Sections B-2 and  B-3), which  presents  the  nature and advantages
of many of  the available choices.  In addition, the SLRWD should initiate the
management  structure  that  will   operate  in the  future  so that citizens and
local officials  can  take part in  the  site-by-site  design treatment choices.
This will allow all concerned  individuals  to  become  familiar with the proce-
dures necessary  to  maintain and  improve  water  quality in the Steuben Lakes
area.
                                     v

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     The no-action alternative was evaluated but rejected as a viable solution
to the problems of the Steuben Lakes area for the following reasons:

     •  It fails  to detect and  remedy existing and future malfunctions  in a
        timely manner,

     •  It places  substantial financial burdens on those  individual property
        owners  who  would  have to  install  holding  tanks  or costly  on-site
        systems at their own expense,

     •  It offers no  provision of developing a database on the design, usage,
        and  impacts  of on-site  systems;  such as database would be  useful in
        making future permit decisions.

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                                   CONTENTS
Preparers 	
Executive Summary 	
Figures 	     ^
Tables 	      x

I.    PURPOSE OF AND NEED FOR ACTION 	      1

     A.  The Applicant's Facilities Plan and Environmental Impact
         Statement Issues 	      1

         1.   Cost-Effectiveness 	      1
         2.   Sizing 	      1
         3.   Primary Impacts 	      1
         4.   Secondary Impacts 	      1
         5.   Socioeconomic Impacts 	      3

     B.  The Need for Improved Wastewater Management 	      3

         1.   Studies Included in The Draft EIS 	      4
         2.   Additional Studies 	      6

II.  ALTERNATIVES	     11

     A.  The Facilities Plan Proposed Action 	     H

     B.  The EIS Recommendation - Limited Action 	     H

         1.   Treatment Methods Selection 	     13
         2.   Community Management 	     16
         3.   Implementation 	     19

     C.  The No-Action Alternative	     20

     D.  Other Alternatives 	     21

         1.   Facilities Plan Alternatives 	     21
         2.   EIS Alternatives not Already Considered in Facilities
             Plan	     22

III. AFFECTED ENVIRONMENT AND IMPACTS OF NO ACTION 	     25

     A.  Soils	     25

     B.  Surface Water Resources 	     25

     C.  Groundwater Resources 	     26

     D.  Population and Land Use 	     27

     E.  Environmentally Sensitive Areas 	     27

     F.  Economics 	     30

                                     vii

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                             CONTENTS (Continued)


                                                                      Page

IV.  ENVIRONMENTAL CONSEQUENCES OF THE ACTION ALTERNATIVES 	      33

     A.  Surface Water Resources 	      33

     B.  Groundwater 	      35

     C.  Population and Land Use 	      35

     D.  Economic Impacts 	      36

V.   PUBLIC AND AGENCY COMMENTS 	      37

     A.  Water Quality 	      37

     B.  Soils 	      39

     C.  Field Data Collection 	      39

     D.  Alternatives 	      40

     E.  Implementation/Management 	      43

     F.  Impacts 	      44

     G.  The EIS Process	      45

APPENDICES:

     Appendix A.  Letters and Written Comments

     Appendix B.  EPA Region V Guidance--Site-Specific Needs Determination
                  and Alternative Planning for Unsewered Areas

     Appendix C.  EPA Memo on Access and Control for On-Site System
                  Upgrading

     Appendix D.  Septic Leachate and Groundwater Flow Survey—
                  Steuben Lakes, Indiana August 1979

     Appendix E.  Revised Limited Action Present Worth and User
                  Charges—Steuben Lakes Project Area

     Appendix F.  No Action Alternative Present Worth—Steuben Lakes
                  Project Area

     Appendix G.  Limited Action Site Analysis

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                                    FIGURES

                                                                      Page

Figure 1.  Steuben Lakes:  Proposed Service Area ...................     2

Figure 2.  Plume Locations on Steuben Lakes - August 1979 ..........     7

Figure 3.  Direction and Rate of Groundwater Flow at Selected
           Stations around the Steuben Lakes Shoreline,
           August 1979 .............................................     g
Figure 4.  Steuben Lakes:  Facilities Plan Proposed Action
Figure 5.  Trophic Conditions of Marsh Lake, Snow Lake, Big Otter
           Lake, Lake James, Lake Gage, Crooked Lake, Jimmerson
           Lake, and Lime Lake (1973-1974) ................. t ........   34

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                                    TABLES

Table 1.
Table 2.
Table 3.
Table 4.

Existing and Projected Dwelling Units within the
Proposed Service Area (1975 and 2000) 	
Estimated Population of the Steuben Proposed Service
Area (1975) and Projected Population (2000) 	
Options and Costs for Installing On~Site Systems . . .
Comparison of Phosphorus Loading under Alternatives
Page
28
29
31

Table 5.
with the Average Present Conditions (projected for the
Year 2000) 	     33

Percentage of Population that would Experience Financial
Burden and Displacement Pressure 	     36
                                     x

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                                   CHAPTER I

                        PURPOSE OF AND NEED FOR ACTION

A.   THE APPLICANT'S FACILITIES PLAN AND ENVIRONMENTAL IMPACT STATEMENT ISSUES

     In  August  1976, Mick,  Rowland and  Associates  completed the  Facilities
Plan for the  Steuben Lakes area.  They evaluated  alternative  wastewater col-
lection and treatment strategies for residences around numerous  lakes  in the
Study Area.  Their Facilities Plan proposed the construction of new wastewater
collection and  land  treatment  facilities.  The proposal was submitted  to the
US  Environmental   Protection Agency  (EPA)  Region  V by  the  Steuben  Lakes
Regional Waste  District (SLRWD),  the  grant applicant, for  funding under the
EPA Construction Grants  Program.  Figure 1 shows the service area addressed in
this EIS.

     Following  are the  major issues that are examined in the EIS.  These five
issues are closely related to  the proposal to build sewers around the various
Steuben Lakes.

1.   Cost-Effectiveness

     The  total  capital  cost ($3,800 excluding  connection costs)  and  annual
user charges  ($450)  for the project proposed  in  the Facilities  Plan are very
high.  Those costs are especially high considering the fact that a majority of
the  population  is seasonal  and that many  of the permanent residents  in the
area are  of retirement  age.   The Facilities Plan did not adequately address
whether or not the local share of the cost burden was acceptable.

2.   Sizing

     The use  of per  capita flows of 100  gpcd for both permanent and seasonal
residents  was  not  justified in the Facilities  Plan.  As  a  result  of this
suggestion residents might be required to pay for substantially larger systems
than they need.

3.   Primary Impacts

     Steep slopes  exist in  many parts of  the Proposed Service Area,  parti-
cularly  in the  east.   Construction of sewers and treatment plants may cause
substantial erosion  of  these   slopes,  with  the  consequent deterioration of
water  quality.   The Facilities  Plan also failed to  discuss the impacts that
construction would have  on nearby tamarack bogs, which are  the habitats of two
orchids  on the  Federal list  of  threatened  species  (Plantanthera  flava and
Plantanthera leucophaea).

4.   Secondary Impacts

     Often, availability of  a  regional  sewer  system  such  as  that proposed in
the  Facilities  Plan induces significant  growth in  a  community.   Such growth
could lead to the contamination of surface and groundwaters, pressures for the
development of wetlands, and increased demand for infrastructural services.  A
trend  towards  the development  of wetlands  is  already visible  on Snow Lake,
Lake James, Jimmerson Lake, and Crooked Lake.   It is, therefore, important
that  regional  and  subregional  systems  be  compared for  their  potential  to
create secondary impacts that are associated with induced growth.
                                    1

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5.   Socioeconomic Impacts

     Estimated capital costs of the Facilities Plan Proposed Action are at the
very high  level of  $3,800  per residence.   Because it is also  likely that  a
substantial portion  of  the costs  may  not be  eligible  for Federal  funding,
local costs may be very high.   High local costs may lead to both a shift from
seasonal to permanent residence,  and  the displacement  of low, moderate,  or
fixed-income families.

     Subsequent  project  studies to research  the  above  difficulties uncovered
the  following  additional concerns  all  of which  would require  resolution  or
mitigative measures:

     •  The large, non-point source phosphorus plume originating in Marsh Lake
        and extending  through  the two  Otter Lakes, Snow  Lake,  and Lake James

     •  The ongoing  destruction  of wetlands  within the  Study Area  and its
        relationship  to  secondary  impacts  (Linked with  this  is the  role  of
        cut-and-fill  techniques  in  creating  shoreline   channels  that  tend
        to become sinks for septic tank effluent leachate.)

     •  The location of numerous  non-point  sources, notably  dozens  of unof-
        ficial  dumps or landfill areas

     •  The management  requirements  for  operation of an  On-Site Wastewater
        Management District (OSWMD).

B.   THE NEED FOR IMPROVED WASTEWATER MANAGEMENT

     The Facilities  Plan identified the following problems associated with the
existing on-site systems in the Steuben Lakes area:

     •  Most  of the  septic  systems are  quite  old and  were constructed when
        there  were  few  rules governing  their  installation.   In the past,
        there  was  very  little inspection of the  construction of  septic sys-
        tems.    In some summer  cottages, out-houses  are still in use.

     •  The Facilities  Plan indicated  that most of the nitrates and phosphate
        from septic  tank effluents  near lakes will  eventually reach the lakes.

     •  Some  of the septic systems  in  low-lying areas  near  the  lakes are
        located below  the  highest  groundwater  table.   The  Facilities  Plan
        stated  that   in  periods of high precipitation,  septic  tank  effluent
        reaches  the  lake quickly.

     •  Some  lake lots  are quite narrow  (i.e.,  40-foot  frontage)  and con-
        tain a  well  and  septic  system.  Many  of the wells are shallow.  Proper
        separation of the water supply and the wastewater disposal  system can-
        not be  maintained on such  small lots.

     •  Dye tests  of septic tank  effluents  have  been conducted by the County
        Health  Department and  some of the  lake  associations.  Several  areas
        of pollution have been detected by  these  tests.   Furthermore, it was
        stated  in the Facilities  Plan that  much  of  the pollution caused by
        septic  systems is  of  a slow nature  and  is not readily detectable by
        dye tests.

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     Several tests were conducted  during  the preparation of the Draft  EIS  to
evaluate  in greater  detail  the  water quality  and public  health  problems
related to  use  of on-site systems  around  the Steuben Lakes.   Several  of the
studies were  reported in the Draft EIS.   These studies and their major  con-
clusions are:

1.  Studies Included in the Draft EIS

     a.  Eutrophication modeling--0n-site  sewage  disposal systems  contribute
an estimated 3% of  the  phosphorus load to Snow Lake, 5% of the load to  Lake
James, 21%  of the  load  to Jimmerson Lake,  7% of the load to Crooked Lake, and
10% of the load to Lake Gage.   They do not play a  role in the  phosphorus loads
to Marsh Lake,  Little Otter Lake, Lime Lake,  and Big Otter Lake.  According  to
Dillon's lake eutrophication  model, Crooked  Lake, Jimmerson Lake,  Lake Gage,
and Lime Lake are  mesotrophic,  and Lake James, Big Otter Lake,  Snow Lake, and
Marsh Lake  are eutrophic.   Little Otter Lake is classified as hypereutrophic.
Removing the contribution that phosphorus from septic tanks makes to the lakes
would lead to negligible changes in the lakes trophic status.

     b.   Aerial photographic  survey—EPA's  Environmental  Photographic  Inter
pretation  Center  (EPIC)  conducted an  aerial photographic  survey to determine
the location of surface  malfunctions  within the Study  Area.  During the sur-
vey,  only  four surface  malfunctions were detected within the  Proposed Service
Area; the malfunctions were later confirmed by on-site investigation.

      c.  Septic leachate study—An investigation of septic leachate discharges
around the Steuben Lakes took place in December 1978. The study was to deter-
mine  whether groundwater  plumes from  nearby septic  tanks  were  emerging along
the lakeshore.

     An  instrument called  the  "Septic  Snooper"  was  used to   detect  septic
leachate plumes.   This  instrument  is equipped with analyzers  to  detect both
organics and inorganics  from  domestic wastewater.  The  device was towed along
the lakes;  holes  were drilled in  ice-covered  areas  in  order  to obtain a pro-
file  of septic leachate plumes discharging to surface waters.

      A total of 69 plumes were found, irregularly scattered around the shore-
lines  of the  lakes.   This is a comparatively small number of plumes for 3,494
lakeshore  residences  in  the Proposed  Service Area  to produce.   Almost all of
the plumes were  found  on three lakes:  Lake James,  24 plumes  (35%); Crooked
Lake  (first and  second  basins),  20  plumes   (29%);  and Lake  Gage,  15  plumes
(22%).  Erupting plumes numbered 42, which was  equivalent to 61% of the total.
There were  23 passive plumes  (33%), and four stream  source plumes  (6%) .

      The frequency  of the plumes was directly  related to the soil classifica-
tion.  The majority of the plumes, 41  of  69, were  associated with moderately
rapid and  rapidly  permeable soils, or  occurred in cut-and-fill canal  regions
with  uncertain soil types.

      A  large,  stream source  plume, principally  of bog-like  organic composi-
tion,  (as  distinct from wastewater effluent),  was found entering  Little Otter
Lake  via  the connecting stream  from Marsh  Lake.  This plume  became pro-
gressively less concentrated  as  it  flowed  through  Little Otter Lake,  Big Otter

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Lake, and  the lower  half  of Snow  Lake;  it finally dissipated  in  the middle
basin of Lake  James.   Associated with this plume was  a  noticeably high level
of total phosphorus,  ranging from 0.096 mg/1 at the  entrance  to Little Otter
Lake to 0.011  at  the discharge from Lake James  to  Jimmerson Lake.   Old sedi-
ment  deposits in Marsh  Lake,  the  result of  effluent  discharges from  the
Fremont sewage  treatment plant  (east  of Marsh  Lake),  were indicated as  the
likely  source  of  the  high  phosphorus concentrations.  Although  the plant no
longer  discharges phosphorus  to Marsh  Lake, the  acidic  leachate from  the
extensive bogs  around Marsh  Lake is thought  to release phosphorus from  its
carbonate binding in  the Marsh  Lake  sediments.  This  and the  other stream
source plumes were  identified as the major sources  of phosphorus to the lakes
surveyed.

     The bacteriological survey  of  the  lakes revealed very few locations with
fecal contamination  (shown  by the  presence of  fecal  coliforms).   The recom-
mended limit of 200 fecal coliform organisms/100 ml  was only exceeded at three
locations:   the storm drain outlet  on the western  shore  of Lake Charles,  the
stream  entering Big Otter  Lake  in  the  northeast,  and  a point  on the north
shore of the  third  basin of Crooked Lake.  Four other elevated concentrations
(5 100 organisms/  100 ml) were found in canals on the eastern shore of  Crooked
Lake and on the stream linking Crooked Lake and Lake Gage.

     d.    Well water sampling—This  study  was  undertaken  by  the  Tri-State
University  Engineering  and  Research  Center  (TSUERC).   It  was designed  to
obtain supplementary information about the existing  groundwater quality in the
Study Area  and an indication of  the effects  that current wastewater disposal
practices have  on groundwater quality.   A total of  101  residential drinking
water wells were  sampled for bacteriological and chemical analyses.  Sampling
was distributed throughout the 13 subareas of the Study Area, in proportion to
the number  of  residences in each subarea.  Each sample was analyzed for total
coliforms,   fecal   coliforms,  fecal  streptococci,   phosphates,  nitrates  as
nitrogen,  chlorides, and specific conductance.

     Based  on  the results  of the study, the quality of groundwater (bacterio-
logical and chemical) in the Study Area is of a high standard.   The effects of
more  than  50 years  of septic tank/soil  absorption systems on water  quality
seem to be insignificant.

     Less than 10%  of the 101 samples were confirmed positive for total coli-
forms.  Less  than 2%  of the samples  were positive for  both  total and fecal
coliforms.   The bacteriological  quality of the  groundwater  is  very high;  the
groundwater appears to be uncontaminated by human wastes.

     In all cases,  nitrate  levels are well below the  USEPA's  Interim Primary
Drinking Water  Standards permissible  10  mg/1 as nitrogen.  The values range
from  0.03 to 2.60 mg/1.  Only 5  samples ( 5% of the total) were above 2 mg/1,
and 8 samples  were  between  1 and 2 mg/1.   These low levels and the absence of
significant increases  in nitrate concentrations over  background levels indi-
cate that the  soils  throughout the Study Area have  been efficiently treating
septic tank wastes.

     Chloride levels  are  generally  well below 100 mg/1,  with the exception of
two wells on  Crooked Lake (138 and 650 mg/1), one well on Jimmerson Lake (194
mg/1),  and  one well  on Lake Gage  (136 mg/1).   In all four cases, the asso-

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elated levels of nitrates  (which,  like chlorides, are also  soluble  in water)
are very low.  These  low nitrate levels indicate that the  main source of the
elevated chlorides  is  unlikely to be human wastes.

     There is no drinking  water standard for phosphates,  but phosphate levels
are generally low throughout the area;  only 16 samples exceed 0.02 mg/1.  Most
of  the  elevated  phosphate  levels  (maximum measured  0.15  mg/1)  are  found in
off-lake rural areas  east  and south of Crooked Lake,  and  north of Lime Lake,
which suggests agricultural fertilizer is the source.

2.  Additional Studies

     After the Draft EIS was issued, additional studies were concluded.  These
studies and their major findings follow.

     a.   Septic leachate study—A  second  investigation  of  septic  leachate
discharges around Crooked  Lake,  James  Lake, and  Jimmerson  Lake  took place in
August 1979.  The patterns of erupting plumes from on-lot septic systems were
compared  with the  pattern  that  emerged  in the  winter  survey.  The summer
survey revealed that groundwater plumes occurred irregularly around the shore-
lines of the three surveyed lakes; their locations coincide closely with plume
locations found in the winter survey.  Plumes again seemed directly related to
soils  classified as moderately rapid to rapidly  permeable;  plumes were espe-
cially grouped in stream inlets or stagnant cut-and-fill canal regions common
on  each  of  the  lakes.  The actual number of plumes revealed was low; 25 sites
on  Lake  James,  and  less than ten  each  on Crooked Lake and Jimmerson Lake had
plumes (see Figure 2).

     The  fecal  coliform bacterial  survey of Jimmerson Lake  and Crooked Lake
turned up only three locations that exceeded the State's maximum safe  level of
bacteria  for  full body  contact.   Bacterial  impacts  are  isolated  and do not
appear to be a significant hazard to recreational swimming areas.

     The complete septic leachate study is presented  in Appendix D.

     b.  Near-shore hydrology study—Seventy-six  sites were chosen around Lake
Gage, Big and Little Otter Lakes, Snow Lake, Crooked  Lake, Jimmerson Lake, and
Lake  James.   These sites  were used  to determine  the  rate  and  direction of
shallow  groundwater  flow  at the near-shore  water table surface.   The  flows
were  measured with a meter  that  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 illustrated  in  Figure 3.

     The  groundwater  flow patterns show  some  irregularities that result  from
complex  soil matrices   (which  include marl  and  mucks),  but  they  portray a
general  southwesterly flow,  with  a low  velocity  (estimated  at  less  than 10
feet per day).

     c.     Analysis of near shore aquatic productivity problems—Studies   of
other  mid-western  lakes have suggested a  correlation between the growth  of a
filamentous  green algae,  Cladophora glomerata,  and effluent emergence at the

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shoreline.  Previous  studies,  however,  did  not establish a  cause  and effect
relationship between effluent emergence and growth of this algae.   To evaluate
this  relationship  and to  study  factors controlling  effluent plume movement,
six  on-site  systems close  to  Crooked Lake  were selected for detailed moni-
toring.

     At two of the sites, C. glomerata grew mainly on rock walls in the splash
zone  and,  to a  lesser extent, in  shallow water just  off-shore.   This green
algae  did not grow in readily visible amounts at the  other  four  sites.   The
presence  of  C.  glomerata did not correlate with  the  phosphorus concentration
in  septic  tank leachate  at the  shoreline.   Although the  leachate  at  one
C. glomerata site contained elevated total phosphorus (3 mg/l-P),  another site
with  high phosphorus  had  no C.  glomerata.  The  other  site  with  C. glomerata
had background concentrations of phosphorus.

     Shallow  areas near  two other  sites  had  slight  to moderate  growths  of
Chara Sp. ,  a  branched  green algae,  and  several rooted, aquatic  organisms.

     For all six sites, at depths of 1 meter and more extensive and dense mats
of Chara Se. grew interspersed with the rooted aquatic plants found in shallow
water.

     The  distribution  of plant growth in this productive lake does  not cor-
relate  with the  observed and expected  locations of  plume  emergence  at  the
shoreline.  The  densest  growth is  found  in  deep water.  Sparser  growths  in
shallow waters and in the splash zone may be locally stimulated by septic tank
leachates  but the  relationship  is  not  strong.  Other factors such  as  wave
action,  water  temperature,  boating and swimming  activity, use of  herbicides,
or amount of light, appear to control near-shore plant growth more than septic
tank leachates do.

     Analysis of  groundwater samples collected at each site  showed that phos-
phorus  and nitrogen  compounds  were  reduced  to background  concentrations  at
three  sites  before  effluents  entered Crooked Lake.   This  result was found
despite the age of the dwellings  and location of their soil absorption systems
in  or just  above, the  groundwater.  Two other  sites had  total  phosphorus
concentrations  in  groundwater at  the shoreline  of  3  and 4  mg/l-P and total
inorganic nitrogen concentrations (ammonia, nitrite and nitrate) at the shore-
line  of  19.7 and 22.7 mg/l-N. The  sixth site had background  levels  of phos-
phorus  but a  high total  inorganic  nitrogen  concentration  of 22.8  mg/l-N.

     Taken as a small sample of the lakeshore dwellings in the Study Area,  the
groundwater sampling  supports  the  septic  tank loading assumptions that were
used  to  model the  lakes'  eutrophication potential.  The  sampling  also shows
that  there can  be wide  variations  in  leachate  nutrients,  even  though  the
average nutrient levels are low.

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                              CHAPTER II

                             ALTERNATIVES

A.   THE FACILITIES PLAN PROPOSED ACTION

     The Facilities Plan recommended the construction of a regional collection
and centralized treatment  system.   The collection system would be  a  combina-
tion of pressure  sewers/grinder  pumps and gravity sewers with  lift stations.

     The Facilities  Plan also proposed treatment of 1.9 million  gallons  per
day  (mgd)  of  wastewater by  aerated  lagoons  and  land applications.   Spray
irrigation was selected  with  an  underdrain system to collect the  effluent  for
discharge  to  Crooked Creek.  Figure  4 illustrates the  Proposed  Service Area
and location of the proposed stabilization pond.

     The Draft EIS  found that  septic tank effluent pumps  (STEP) were more
cost-effective than the grinder pumps recommended in the Facilities Plan.  For
this reason, STEP systems were substituted in the Proposed Action  discussed in
this EIS.   In  this  respect,  the  Proposed  Action differs  from  that  in  the
Facilities Plan.

     Costs developed  in  the  Draft EIS for the Facilities Plan Proposed Action
are:

     Construction costs (1980)                    $ 20,839,800
     (including engineering, legal,
     and contingency costs)

     Future construction costs                    $    125,600 per year

     Annual operation and maintenance expense     $    253,050 per year

     1980 Local cost user charge                   $        450 per year

     The  1980  average  annual user  charge  includes  all operation and main-
tenance costs  for the year plus  annual payment  on the  debt  of privately,  as
well as publicly, financed construction costs (interest  rate of 6-5/8%, with a
payback period of  30 years).   The relatively high  local costs  of the Facili-
ties Plan  Proposed Action stem,  in part, from the ineligibility  of  all col-
lector sewers.  Costs  for  these  ineligible sewers must  be met entirely at  the
local level without Federal and State assistance.

     Appendix  K-2  of  the Draft  EIS  outlines  the  major components  of this
Alternative and the detailed costs of these components.

B.   THE EIS RECOMMENDATION - LIMITED ACTION

     As described  in  the Draft  EIS,  the  Limited  Action Alternative would
continue the  use  of on-site  systems  throughout  the Proposed Service Area.
Upgrading  or  replacement of  on-site  systems is  included where  the  existing
systems are  obviously of  inadequate  design, are malfunctioning,  or  could be
expected  to malfunction based  on  comparisons   with  similar  systems.   The
Limited Action Alternative is estimated to result in:
                                    11

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12

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     •  Replacement  of  approximately  50% of  the  existing  septic  tank/soil
        absorption systems (ST/SASs)  in the year 1980
     •  Replacement  of  approximately  10%  of  the  drainfields  in  the  Study
        Area.

     The present worth  of the  Limited Action Alternative has been revised for
the Final EIS  and  is estimated to be  $6,523,700  (as detailed in Appendix E) .
This compares  to  $8,268,700  for the  Limited Action  Alternative  (described in
the Draft EIS) and $23,166,800  for the Facilities Plan Proposed Action.

     The  total present worth   cost  for  the  Limited  Action Alternative  has
decreased by 27% from the  Draft EIS to the Final EIS.  This is a result of the
following major factors:

     •  Detailed estimates of operation and maintenance (0 & M) cost's reduced
        the  annual 0 & M from $45/yr to  $41/yr.   Annual  0  & M  for  future
        construction increases  the total 0 & M costs less than $41/yr.

     •  Detailed  estimates  of  engineering costs  that  were based  on  house-
        by-house  site  analysis increased  the  present capital  cost slightly.

     While  many  of  the elements  of  the Limited Action  Alternative have been
estimated,  described, and costed,  the final details will  not  be known until:
house-by-house  analysis  allows a  selection  of treatment  methods  for  eaca
house,  and  the Applicant and   community  decide on  the  method and  degree of
management  to be  provided.    These  two  considerations  are  described  below.

1.  Treatment Methods Selection

     Identifying  on-site  systems problems  and causes of  the  problems  is tne
first step  in  specifying  technologies for individual residences. Site-specific
analysis  is  necessary  to  accomplish  this.  The analysis should be sequential,
beginning with a  review  of 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 investiga-
tions  may be  warranted in order to  identify  the  cause  and  possible remedies
for  any recognized problems.  Examples of  additional  investigations keyed to
problems are:

Problem                                 Investigations in Sequential Order

Recurrent backup into house or          Install  and  monitor  water meter
evident ground surface malfunction

                                        Uncover, pump out, and inspect septic
                                        tank for obstruction and groundwater
                                        inflow

                                        Rod the house sewer  and effluent line

                                        Excavate  and  inspect  drainfield
                                        distribution  lines,   if  they are
                                        present
                                    13

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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 absorption
system size or design known to
be less than code requires
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 drinking
water aquifer is shallow or unconfined

Monitor groundwater flow direction
and rate

Locate  effluent  plume in vicinity
of  lakeshore,  using  groundwater
probe   and   fluorescent  analyst,?
Sample groundwater in leachate plune
at  lakeshore.   Analyze  for total
phosphorus, total Kjeldahl nitrogen,
nitrate, nitrogen, and fecal coliform
bacteria

Inspect  property  to assess feasi-
bility of replacement or upgrading
If feasible, document system inadequa-
cies by probing and excavating sample pit

Inspect  property  to assess feasi-
bility of  replacement or upgrading,
     In the  selection  of  technologies for individual sites, this EIS strongly
recommends that:

     •  Alternatives other than  those covered by existing codes be considered

     •  State  and  local officials legally responsible  for  permitting on-site
        systems be involved in selection.
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     •  The  availability  and  cost of  skilled manpower  for maintaining  and
        monitoring  innovative  or  subcode  systems  be weighted  against  the
        feasibility and cost of requiring conventional on-site systems  or off-
        site systems

     •  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

     •  The  individual  homeowner be  informed  of  the  different  options  under
        consideration  (and  their costs  both  to the  individual  and the  dis-
        trict) when technology selections are being made.   The owner's  opinion
        and advice should be solicited.

     Based  on  information  gained from the site-by-site analysis, a technical
expert  should discuss  feasible  problem-solving  approaches  with  the  owner.
Primary criteria  for identifying  the  appropriate technology should be  cost,
benefits,  and  risk  of  failure.   Undoubtedly, the analysis  will  also consider
eligibility  for  Construction Grants  funding.   General guidelines  for eligi-
bility of on-site technologies  are presented  below:

     •  The  replacement  of facilities with obviously  inadequate  designs will
        be  eligible,  if   feasible.   Cesspools are  an example   of obviously
        inadequate  facilities.   Septic  tanks  in very poor  repair  or  sub-
        stantially smaller  than  required by  State codes  are another example.
        Small drainfields,  dry wells,  or unusually designed systems  are not of
        obviously inadequate design and thus  replacement of them is  ineligible
        unless they fall within guidelines described below.

     •  Parts  of  systems  that cause  recurrent surface failures, backups,  or
        the  contamination  of potential  drinking  water aquifers  are eligible
        for  repair  or  replacement.   This  does not apply  to  water  using fix-
        tures.  Systems that fail because they are abused  will not be eligible
        unless the  abuse  is terminated  and  the usage of  the system is  docu-
        mented by water meter  readings and/or reinspection  of the  system and
        failure is still being experienced.

     •  Facilities not  currently causing public health or  water  quality pro-
        blems may be eligible  for  repair or  replacement if similar systems in
        the  area  are  failing.   "Similarity  of  systems"  includes  design and
        site  characteristics  that  are  shown  to be  contributing  to failures.

     •  Compliance with State  and  local on-site design regulations in design
        of  repairs  and replacements  is desirable,  where such  compliance  is
        feasible  and  effective.   Compliance  is  not a  condition   of eligi-
        bility if  subcode  design  or  alternative  processes  can  reasonably be
        expected  to eliminate  or substantially  mitigate  public  health  and
        water  resources  problems.   Similarly,   innovative  designs  will  be
        eligible, with the  added  condition  of assured inspection  and  moni-
        toring commensurate with the  degree  of risk be assured.   For subcode,
        alternative, or innovative systems,  it is expected that water conser-
        vation devices  commensurate  with the  degree  of risk  for hydraulic
        overloading will be installed  at owner or Applicant's expense.


                                    15

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     •  For the Steuben Lakes Study Area,  methods  will be eligible  that modify
        the flow  or  chemical characteristics of effluent plumes entering  the
        Lakes  if  the modification might  reduce the  near-shore plant  growth.
        Construction  Grants  guidelines  consider  such  methods   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-using devices  (such  as garbage  disposals,  dishwashers)
        added  since December  1977  will  not be a basis  for  determining eligi-
        bility.   Systems  adequately  designed for  the building 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:

     •  there  is  a documented  public  health or water  resource  contamination
        problem that any combination of on-site conventional,  innovative, sub-
        code,  flow reduction,  or  waste restriction  methods cannot  abate, or

     •  the life  cycle  costs  of off-site  treatment  and  disposal  for an indi-
         vidual building  or group of  buildings is less than costs  of appro-
         priate on-site technologies for the same  buildings.

     The recommendations  apply  only  to existing systems.  EPA is  recommending
and funding the Limited  Action  Alternative in order to help the  community and
system  owners  minimize  the risk  to water quality  and public health.   For
systems to  be  built for new  housing, EPA makes  no recommendations  on  the
permitting process because  the Agency does not  provide funding  for future
construction.

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 application 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, on-site systems.

     Within this  limitation,  communities  have a wide  range  of  options avail-
able. Many of  these  options are discussed  in the Draft EIS, Section III.E.2.
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 faci-
lities will not  operate as intended, thereby  causing water quality or public
health problems  or inconvenience  for   the  user.   Whether centralized, small-
                                    16

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scale, or on-site,  all  wastewater facilities have inherent  risks;  the degree
of  risk  depends  upon  skill  in  design,  construction,  operation,  and  main-
tenance .

     "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 the
Steuben Lakes only  in sofar as permitting and inspection activities minimized
risk.  The  consequences  of  facility  failure  rest  with  system owners.   In
building sewers around Steuben Lakes, the proposed Steuben Lake Regional Waste
District  (SLRWD)  essentially  would  have accepted  liability for all failure
except plumbing and house  sewer  blockages.  With  the Limited  Action Alter-
native, the community  still has the opportunity to assume increased liability
in whatever manner it sees fit—the only limitation is that the Applicant will
be responsible  for  actively identifying failures of interest to the community
(inconvenience  for the  user  not  included)  and  attempting to  remedy  the
failures.   Strictly speaking, the SLRWD'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 improv-
ing,  monitoring,  and  maintaining all  wastewater  facilities around Steuben
Lakes.  EPA  encourages but  does  not require  such a  role.   The  scope of the
responsibilities  depends  on how much liability  for  wastewater facilities the
Applicant wants,  and  is  legally  capable  to  assume.   EPA will,  by funding
facilities planning,  design,  and construction,  assist  the SLRWD  in meeting
those  liabilities it  assumes when those liabilities  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  SLRWD  would  act  as  the recipient  and distributor  of Construction
Grant  funds.  Homeowners  who wished  to improve their on-site facilities could
voluntarily apply  to  the  SLRWD for this assistance.  After documenting that
minimum requirements  for  on-site  system eligibility are met,  the SLRWD would
receive the funding and distribute it to homeowners  who show proof of satis-
factory installation.   These homeowners would be assessed an annual fee there-
after  to  cover the  cost of  a  site inspection  perhaps  every three  to five
years, and would  be required to show proof of appropriate maintenance activi-
ties as part  of the site  inspection.  A  groundwater monitoring program would
include taking well water samples during the site inspection.

     With this  approach,   the  SLRWD  would not incur  any long-term  debt.  The
SLWRD  would not necessarily have any responsibility for, or interest, in per-
mitting future  on-site  systems.  Without a  comprehensive  site inspection and
evaluation program,  it is  unlikely  that all water  quality  and  public health
problems  would  be  identified and abated because  property  owners  would not be
required  to  participate.   Liability for  facility malfunctions  would remain
wholly with the owners.
                                    17

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     Comprehensive Wastewater Management

     This  is  the  approach recommended  for adoption  by  the  Applicant.   It
involves instituting the  small  waste  flows district concept discussed  in the
Draft EIS  (see  particularly pages  137-143,  202-205,  and Appendix J).   All
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 homeowners, 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 ensure 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
authority  greater discretion  in sharing liability for facility operation with
the resident or building owner.

     Technical  expertise  would come  from any one  of  numerous  sources.   The
Steuben County  Health Department  (SCHD)  could expand  their staff  to  accom-
modate this  type of operation  for the  Steuben Lakes as a demonstration pro-
ject, with additional projects possible in other parts of the county.

     Watershed Management

     The Applicant's  concern with  prevention  and  control of  water  pollution
need not be  restricted  to wastewater facilities.   It is obvious from comments
on the Draft EIS that citizens of the Study Area are interested in maintaining
the water quality of the Steuben Area Lakes.  If that interest is expressed in
the  form  of  willingness   to  pay  for additional  governmental  services,  the
Comprehensive Wastewater Management scenario could be augmented in the follow-
ing ways:

     •  by monitoring non-point sources of water pollutants

     •  by controlling non-point sources of water pollutants

     •  by educating residents and visitors about individual pollution control
        practices,  costs,  and benefits

     •  by inventoring the biological resources of the lakes and their tribu-
        taries

     •  by studying the chemical, hydrological, and biological dynamics of the
        lakes

     •  by coordinating with other  local, State, and Federal agencies on  pollu-
        tion control activities and availability of funding.
                                    18

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3.   Implementation

     As recommended  in  the  Draft EIS, the Recommended Action  is  to construct
on-site systems  (on an  as  required  basis)  with administrative powers  being
given to  the  SLRWD.   Please note that the Limited Action Alternative may vary
from the  technology assumptions  listed  in Appendix  E  and pages 11  to  19 of
this Final EIS.   This  is because the detailed Step 2 or 3 site-by-site design
work will be  needed to  finally decide the level of on-site upgrading for each
house may indicate that particular dwellings have problems requiring different
technologies than those incorporated in the Limited Action Alternative.

     These changes, while affecting specific houses, should not greatly impact
the total amount of work for any one segment, much less  the entire Study Area.
When  it  is   impractical  to  upgrade  existing  conventional septic  tank/soil
absorption systems,  alternative on-site measures should  be evaluated.  These
include technologies such  as composting or  other alternative toilets,  flow
reduction, holding tanks, and separate greywater/blackwater disposal.

     Specific aspects of implementing the Steuben Lakes  project were discussed
in Section VI.C. of the Draft EIS.  Modifications to those discussions follow.

     a.   Ownership of on-site systems serving seasonal  residents—On  page 25
of  the  Draft EIS,  it  was  stated that privately-owned  systems,  serving sea-
sonally-residences  are  not  eligible  for Federally  funded  renovation and re-
placement.   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 systems as long  as the respon-
sible public  agency  is  given "complete access  to  and control  of" the system.
(See Comments and Responses,  under  the  "Implementation/Management" heading,
Section V-E).

     b. Completion of step I requirements for the small  waste flows  district--
EPA Region V developed a new memorandum clarifying project needs documentation
(see Appendix B).   It provides that, at most, a representative sampling (15 to
30%) of  on-site  systems  need to be  developed in Step  I  for  a site-specific
data base.  The remaining 70 to 85% should be done in Step 2 (see Appendix A).
Other remaining Step  I  requirements remain as stated in the Draft EIS.  USEPA
has determined that  a  county ordinance providing for access,  inspection, and
upgrading of  systems (as needed) would  satisfy  the requirements  for public
ownership (see Appendix C).

     For the  purposes of  technology selection and organization development in
Step 2 and construction supervision in Step 3, the grantee should establish a
Sanitary Review Board.  This  board  can consist of members of the various lake
associations   or be  an  independently  elected  body.   The  board's responsibili-
ties will  be  to:

     •   Supervise   the  direction  and  progress  of the  site-specific analysis

     •   Ensure 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  that are  not in
        conformance with present regulations

                                    19

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     •  Provide an appeal process  for  owners who object to the  technology se-
        lected for their property

     •  Ensure that a multidisciplinary team conducts  the analysis  and techno-
        logy selection.  The team should consist of persons with knowledge and
        experience in  soil  science,  water  chemistry,  geohydrology,  wastewater
        characteristics,  innovative,  alternative  and conventional  decentra-
        lized  treatment technologies and  practical aspects of  decentralized
        system construction and maintenance.

     The  application  for  Step 2  funds  should  include  a description of  the
grantee's organization for this  review  board and  the  qualifications of  the
individuals proposed  for the  Step 2 site analysis and  technology  selection.
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.

     This EIS recommends that the necessary technical  expertise be  sought from
several sources, such as:

        Steuben County Health Department
        Purdue University
        Tri-State University
        US Soil Conservation Service
        Corporate consultants
        Individual consultants.

     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.  Within reason,  costs for these services
will be grant eligible.

C.   THE NO-ACTION ALTERNATIVE

     The  No-Action  Alternative  is  broadly  defined  as   an  EPA rejection of
Construction  Grants  applications  for  the  Study Area.   This would  consist of
EPA providing  no  Federal funds for  construction  of wastewater  collection and
treatment systems in the Study Area.  If this course  of action were followed,
all existing on-site systems in the Study Area would presumably continue to be
used in their present  condition.

     The  need  for improved wastewater management around  the Steuben Lakes is
not as  extensive as  stated in the  Facilities Plan.   The USEPA Environmental
Photographic  Interpretation  Center  (EPIC)   1979   remote  sensing  and ground
survey  of  ST/SASs   located only  4  malfunctioning  septic  systems  in  which
effluent  back-up  to the  soil surface occurred.   This  represents  an  insigni-
ficant 0.1% of the  homes in the  Proposed  Service Area.  Perhaps, the Steuben
County Health Department's  (SCHD)  dye-test program  has played a significant
role in minimizing this problem.  While failures such as  those located by EPIC
and also by the SCHD's dye-test program may occur in the  future, the threat to
public health seems an insignificant one, controllable by management.
                                    20

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     The SCHD can  play  a major role in the management of local on-site waste-
water management systems  by  continuously inspecting systems as they have been
in  the  past,  using technologies  now available.   This  effort would  require
increased funding  from  both  the  State and local levels.   The  survey  methods
outlined in  the Limited  Action Alternative would be suitable  for  the Health
Department's use.

     No-Action does not  mean "no  cost."  Assuming  that  existing  systems will
fail at a rate  of  1% per year and be replaced by a mix of conventional septic
tank and or mound systems, the costs associated with the No-Action Alternative
for the Steuben Lakes Area are shown below.  Back-up data for these costs are
included in Appendix F.
     1)  Construction Costs (including salary
         of sanitarian to permit systems)
         a)  Replacements for existing systems
         b)  New systems

     2)  Operation & Maintenance Costs
         a)  Existing systems
         b)  Future systems

     3)  Total Present Worth (@ 6-5/8%)

D.   OTHER ALTERNATIVES
                                                                 (1978 $)
                    87,140/yr
                   203,340/yr
                    32,230/yr
                       800/yr
                $3,420,300
     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:
1.  Facilities Plan Alternatives

Alternatives

Centralized collection system
utilizing conventional gravity
and lift stations
Centralized collection system using
low pressure sewer system with
grinder pumps
Centralized collection systems,
vacuum sewage transport, and
collection
Findings

Because  of   the  topography  of
several parts of the Study system
Area,  a  complete  gravity  sys-
tem  would  be extremely expensive
to construct

Grinder  pumps   and   low  pres-
sure   sewers  were   recommended
for  portions  of the  Study Area,
such   as   waterfront  locations,
hilly  terrain,   and   low  popula-
tion   density  areas.   However,
because  of  the  long  distances
involved in   the  system,   a  com-
plete  low  pressure  system would
not be feasible

As a  result  of  the limited pres-
sure  range available  in  a  vac-
uum   system,  the   system  would
                                    21

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Alternatives
Findings
Centralized collection system,
using collection gravity
system and low pressure
sewer system with grinder
pumps

Land application by spray
irrigation of the secondary
effluent to controlled farm
operations
Mixed-media filtration of
the secondary effluent
Land application by spray
irrigation preceded by
lagooning (flow equalization)
secondary effluent.  (equalized
secondary effluent flow would be
applied to a controlled farm operation)
not be  a viable  alternative  for
the  Study  Area  because  of  the
large  differences in  elevations
and high heads required  in some
areas

Accepted  as the  Facilities Plan
Proposed  Action  and  the applica-
tion   for  Construction   Grants
funding
Rejected  in the  Facilities  Plan
because   treatment   scheme   was
not    readily    adaptable    to
receive   the   varying   weekend
and summertime flows

Rejected  in the  Facilities  Plan
because   treatment   scheme   was
not  readily adaptable to receive
the  varying weekend  and summer-
time flows

Accepted  as the  Facilities  Plan
Proposed  Action  and the applica-
tion   for   Construction  Grants
funding.
2.  EIS Alternatives not Already Considered in Facilities Plan
Residential flow reduction
(various devices)
Small diameter sewers
Alternative toilets  (various designs)
Expected   to  be   effective  in
maintaining  on-site  systems and
minimizing the impacts of on-site
systems  in  the EIS Recommended
Action

Rejected because of  marginal  cost
advantage    over     conventional
gravity  sewers for  large collec-
tion  systems   (could be   advan-
tageous  in  the  design  of   small
waste flows  systems)

Not   specifically    incorporated
in  EIS  Recommended Action but
could be  useful where control of
nutrients  is sought
                                    22

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Alternatives

On-site treatment and disposal
(various designs)
Off-site treatment and disposal
(various designs - cluster system)
Septage disposal by co-treatment
local sewage treatment
plants

Septage disposal by land applica-
tion
Findings

Incorporated  in EIS  Recommended
Action for  the  Steuben Lake area
(discharging   systems   excluded
from use)

Incorporated  in EIS  Recommended
Action  for  Steuben  Lakes  area
where  shown  to   be   worth  the
expense

Mentioned   as   a   possibility
(needs additional analysis)
Mentioned    as    a   possibility
(needs additional analysis)
                                    23

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                                  CHAPTER III

                 AFFECTED ENVIRONMENT AND IMPACTS OF NO ACTION

A.  SOILS

     Study Area  soils  are  typical of those  formed  in  glacial drift deposits.
They  are loamy  (composed  of  clay,  silt,  and sand)  and highly variable  in
nature,  ranging  from  poorly-drained silty  and  clayey loams,  to  the  well-
drained loamy sands, and excessively well-drained gravelly sandy loams.

     A majority  of  the soils in the area have been rated suitable by the USDA
Soil Conservation Service for on-site waste disposal systems.  In the southern
portion  of  the  Steuben Lakes  Study Area,  well-drained  Fox and Boyer  soils
predominate.  These loamy  soils are underlain by coarse sands and gravel, and
have  slight  to moderate limitations for septic  absorption  fields.   Both the
Oshtemo Series and  Riddles  Series are well drained loams appearing throughout
the  Study  Area.   The  Oshtemo  Series is underlain by  coarse  sand and gravel.

     As  a  result of the various  field  studies conducted by  EPA (see Chapter
I),  it  can  be  concluded that most ST/SASs are working well.   However, several
soil  conditions  in the  Study Area  could lead to  increased problems in the
future.  High water tables  may be found  in  clay  soils with permeabilities so
low  that water  is  trapped in  them,  or in perched water tables  of thin per-
meable  soils over  impermeable  clays and  clayey materials.   Where these  occur
in low  areas and depressions,  soils exhibit severe wetness,  ponding of water,
and  periodic  flooding, possibly  making them  unsuitable  for on-site disposal
systems.

     In addition, slopes that exceed 12% exist contiguous to many lakes in the
Study  Area.   In  these areas  inadequately  treated wastewater  effluent from
absorption fields are more likely to emerge at land surfaces.  Some areas have
soils with very  high  permeability rates.  This suggests  the possibility that
septic  tank  effluents  may  not be adequately  treated  before  they emerge into
the  lake.   Survey  data  and detailed site investigations  suggest that treat-
ment, particularly removal of nutrients, is variable.

     Building of new dwellings and on-site systems will continue under the No
Action  Alternative.    Some  erosion will  occur because of this  construction.

B.  SURFACE WATER RESOURCES

     The major surface water features located in the Study Area are Snow Lake,
Lake James, Jimmerson  Lake,  Crooked Lake, Lake Gage,  Lime  Lake, Lake Sylvan,
Lake  Charles,  Marsh  Lake,  Little  Otter  Lake,  Big  Otter Lake,  and Crooked
Creek.  Surface water drainage in the watershed is dominated by Crooked Creek,
which flows south from Michigan through Snow Lake, the upper and middle basins
of  Lake James,  and   northwest  through  Jimmerson Lake.   Another branch  of
Crooked  Creek  also flows  in  a northwesterly  direction through  Crooked  Lake,
Lake Gage and Lime  Lake until it  reaches  the  Pigeon River.   The Pigeon River
is  a tributary  to the  St.  Joseph  River,  which  in  turn discharges  to Lake
Michigan  near  Benton  Harbor.   Follette  Creek originates  in  the northeast
corner  of  the  Study Area  and flows northwesterly  through Marsh Lake,  Little
Otter Lake,  and Big Otter Lake before emptying into Snow Lake.


                                    25

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     The drainage  basins  for each lake  cover  from 1.0 to 51.6 square  miles.
The larger  ones  act as  significant  catchments of precipitation that  reaches
the lakes as runoff and groundwater.   Ratios  of drainage basin-to-lake  surface
area range  from  a  low of 2:1  (Crooked Lake--Basin #2) to a maximum of 296:1
(Little Otter  Lake).   The high  ratios  exhibited  by  Little Otter Lake,  Lime
Lake,   and  Big Otter  Lake suggest a relatively  great impact from  non-point
source runoff  reaching these  lakes.   All the lakes have relatively short mean
hydraulic retention times,  varying  from  a  low  of 44  days  to a high  of 2.8
years.

     Based on  water quality  models described in the Draft  EIS,  Crooked Lake,
Jimmerson Lake, Lake Gage, and Lime  Lake are mesotrophic, and Lake James, Big
Otter  Lake,  Snow  Lake  and  Marsh Lake  are  eutrophic.   Little Otter Lake  is
classified as  hypereutrophic.   Phosphorus  limits the  algae production  of the
lakes.   The major  sources of phosphorus  for  lakes in the Study Area,  in their
order of significance,  include:

     •  tributary inflow

     •  immediate drainage around the lake

     •  precipitation

     •  septic tanks (considered as non-point source pollution)

     •  point sources

     The changes in phosphorus loading  imposed by various wastewater alterna-
tives  are not  significant enough to  change  any  of the present trophic condi-
tions  of the  lake.    Snow  Lake  would  exhibit  a  17% decrease  in phosphorus
loading, mainly because the  new tertiary treatment plant at Pokagon State Park
went  into  operation  in May  1979.   This  reduction  of phosphorus  loading is
expected regardless of the alternative implemented.

     Localized growths of algae  and  aquatic weeds have created  nuisance pro-
blems, particularly in Jimmerson Lake and Crooked Lake.   Removal  of the cur-
rent septic tank nutrient  loading from the  lakes would not change the  trophic
status.

C.  GROUNDWATER RESOURCES

     Sand and  gravel   units  within the  250  to  350  feet thick unconsolidated
glacial drift  constitute the major groundwater sources in the  Study Area.  The
aquifers  are  mostly   the   discontinuous   types  characteristic  of   glacial
deposits.   Driller's   well  logs  have  indicated  the  presence of  thick clay
layers,  outcropping  in many areas  and  interspersed with   sand  and gravel
deposits.   These  clay  layers  create  confining  (artesian)  conditions, the
limits  of  which  are  unknown.   The situation  is essentially  one  in  which
artesian conditions and water table  (unconfined) conditions can be expected at
unidentified intervals.

     Groundwater sources  provide all  of  the  domestic water  supplies  of the
Study  Area.  The present groundwater use  within the Study Area is one  million
gallons per day (mgd)  and should double by the year 2000.


                                    26

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     Clayey soils locally  limit  the vertical and lateral  flow  of  soil water.
Most  shoreline  regions  exhibit moderate to  low  groundwater  inflow conditions
(less  than 10  feet  per day  lateral  flow).   Where  clay deposits occur,  the
bedded material  restricts  flow  through  the  porous deposits, even though  the
sand and gravel  deposits may hold considerable trapped water.   However, if an
extensive  lateral  deposit  of  porous  material underlies the poorly  permeable
soils,  and the  deposits extend into  the  lake bottom,  it is  possibile  that
leachate could be transported.

     A detailed  study of  well-water  quality was initiated by  Tri-State  Uni-
versity during 1979 to determine if any groundwater impacts were apparent from
on-lot septic system functioning.  The water  from well samples  was observed to
generally  exhibit  a  high  standard of  quality.   For  well  contamination  to
occur, the well  point must intercept the plume  of  poorly-treated wastewater,
which originates from the  leaching fields.   Because  the position  of the well
point varies in 3 dimensions, the probability of coincidence with the plume is
low.  Five of  twenty samples (20%) showed a coincidental  rise  in the nitrate
and  chloride  elements frequently associated  with leachate conditions.   It is
important  to  note  that the  rises  in nitrate were well  below  USEPA's Interim
Primary Drinking Water Standards of 10 mg/1 as nitrogen.

     The results  of  the Aquatic Productivity Study  (see  Chapter  I) indicate
that  subsurface waste  disposal has  only localized effects on groundwater.
However, the  effluent  plumes are  not  notably stimulating  nearshore aquatic
vegetation in  the  Steuben Lakes.   Other factors, such  as wave action, water
temperature,  boating and   swimming  activity, use of  herbicides,  or  amount of
light,  appear  to   control near-shore  plant  growth  more than  septic  tank
leachate transported to the lakes by groundwaters does.

D.  POPULATION AND LAND USE

     Residential development  is concentrated around  Lake  Gage, Crooked Lake,
Lake James, Jimmerson Lake,  Lime Lake, Snow Lake,  Big Otter Lake, and Little
Otter Lake.  Most  of the  lot sizes around these lakes are small, with 65% of
them  less  than  1/3  of an  acre  (see Table  111-14, page 99 of  the  Draft EIS).
Additionally, numerous  subdivisions exist in the Study Area,  with  lot sizes
averaging well below  10,000 square  feet (see Table 11-13, page 95 of the Draft
EIS).

     Approximately  86%  of  the  Proposed Service  Area population are seasonal
residents.   Tables  1 and  2 present data about the existing and  future numbers
for dwelling units and population in the Proposed Service Area.

E.  ENVIRONMENTALLY SENSITIVE AREAS

     Environmentally  sensitive  areas  within  the EIS  Study Area  include flood-
plains, steep slopes,  wetlands,  prime agricultural lands, and the possibility
of archaeological sites.

     Neither  the Facilities  Plan Proposed  Action  nor any  other alternative
would  directly  affect the floodplain of the lakes  and streams in  the Study
Area  (See  Figure 111-12 of the Draft EIS for extent  of floodplain).   If land-
owners  are provided  with  centralized  sewer  service, building lots  can be
                                    27

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developed near the  floodplain  (if  they comply with the  set-back provisions  of
the Steuben County Master Plan).

     Steep slopes exist primarily in the areas around Lake James and  Jimmerson
Lake  (see  Figure II-l  of  Draft  EIS).   The difficulties  of  installing  on-lot
systems on steep  slopes appear to  be among the factors  that historically have
limited  home  construction mostly  to  lakeshore  and other  level-to-rolling
sites.  However,  sewers and specially  designed on-site  systems  can be  con-
structed on  steep  slopes.   Minor to moderate impacts could result from  imple-
mentation of the Facilities Plan Proposed Action.

     None  of the facilities either  by their construction or by  their  opera-
tion, that are  from the Facilities Plan Proposed  Action  are expected to dis-
rupt  wetlands.   Sewer  alignments  have  been selected to  avoid  direct passage
through wetlands.   However, the  induced growth that is  associated with  sewer-
ing  in  the  system alternatives  may  increase  pressures  for development  of
wetlands not protected by State ownership.

     As illustrated by  Figure  III-7  of the Draft  EIS,  the prime agricultural
soils  in  the  Study Area  are  fragmented and  scattered throughout  the  area,
occurring mainly  in upland areas rather than along  lakeshores  and other sec-
tions of the Proposed Service  Area.   The No-Action or Limited Action Alterna-
tives could  result  in the conversion (at a maximum of approximately 325 acres
or  5%)  of all agricultural lands  in the Study Area  to  residential  use.   The
Facilities Plan Proposed Action could convert approximately 230 acres or 4% of
agricultural lands.  In all cases,  the impacts on prime  agricultural lands are
likely to be insignificant.

     Prior to  the  construction of  any wastewater facilities on publicly-owned
land  in the  Study Area,  the  Indiana  Department  of Natural  Resources  will
require an archaeological survey.

F.  ECONOMICS

     The permanent  population of  the  Study Area  is  characterized by a rela-
tively  low income  that is below the average income for Indiana.  In 1970, 52%
of  family  incomes  were  under  $10,000,  47% from $10,000  to  $25,000, and only
3.5% over $25,000.

     Table V-6,  page  191 of the Draft  EIS  shows the percentage of households
estimated  to face  a  significant financial burden under  each of the alterna-
tives.  The  centralized alternatives would place  a  financial burden on 30 to
50% of households in the Steuben Lakes area, while the Limited Action Alterna-
tive would only impact  about 2 to 5% of the households.   Only 50 to 80% of the
area's households would be able to afford the centralized systems, while 95 to
98% of the residents could afford the Limited Action Alternative.

     The costs of the No-Action Alternative will fall most heavily on property
owners whose on-site  systems  fail.  The homeowner could be  required to choose
and  pay for one  of  the  following  options,  depending  on the nature  of the
failure and  individual  site conditions:
                                    30

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Table 3.  Options and Costs for Installing On-Site Systems
                             Construction Cost
Option
 Initial
Investment
  Annual
Equivalent
                                   Operation and
                                  Maintenance Cost
Permanent
Residence
Seasonal
Residence
Drill a new well
(50' deep)
Install a holding tank*
Connect to a cluster
system
Install a new ST/SAS
ST/Sand mound

$ 700
450

5,350
1,270
8,850

= $ 65/yr
42/yr

500/yr
119/yr
827/yr

-0-
$3,300/yr

75/yr
20/yr
75

-0-
$720/yr

67/yr
12/yr
67
   Although this cost could be reduced substantially by installation of effec-
   tive flow reduction devices and negotiating with the hauler, the cost would
   still be high.  The high cost would be an incentive for homeowners to find
   other, perhaps dangerous, means of disposing of wastewater.
     The most  likely type of repair  that  will be required in  the  Study Area
will be  the  replacement  of septic tanks and/or drainfields.  In the No-Action
Alternative,  these  problems  would be  corrected  as  they  occurred.   In  the
Limited  Action Alternative,  those systems  that  were  discovered  during  the
sanitary survey to have problems would receive initial attention.

     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 $3,000.  If dosed
mound systems are necessary, costs could be as high as $9,000.
                                    31

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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  Alternative.   Please note that, at present,  the Limited
Action Alternative  is not  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.   Such  management  should be in the form of continued
attention to the use  and effects of small-scale  systems,  and it must include
the ability  to  make  balanced decisions, exceptions to regulations in the best
interest of the local environment.

A.  SURFACE WATER RESOURCES

     According  to  either the  Facilities Plan Proposed  Action  or the Limited
Action Alternative, the future phosphorus loads to any of the Study Area lakes
would be minimally  effected (see Table 4).  The changes in phosphorus loading
imposed by various wastewater alternatives are not significant enough to alter
the present  trophic  conditions of any Study Area  lakes  (see Figure 5).  Even
in Snow  Lake, where  reduction of phosphorus loadings  is significant, because
of the  newly opened  tertiary  treatment  plant at the Pokagon State Park, the
water quality  modeling results  do  not  indicate  enough  improvement to change
the trophic condition from eutrophic to mesotrophic.  Jimmerson Lake, with its
phosphorus  loading to be  reduced 21% by  the  Facilities  Plan Proposed Action,
will remain in its present mesotrophic condition.


Table 4.  Comparison of Phosphorus Loading under Alternatives with the Average
          Present Conditions (projected for the Year 2000)


          Lakes                    Limited Action      Facilities Plan
Crooked
Gage
Lime
Little Otter
Big Otter
Snow*
James
Jimmerson
1% increase
<1% increase
2% increase
No change
No change
17% decrease
No change
No change
7% decrease
10% decrease
3% decrease
2% decrease
4% decrease
20% decrease
5% decrease
21% decrease
*  Decrease of 17% in all alternatives as a result of the Pokagon State Park's
   Tertiary treatment plant, which began operating in May 1979.

                                    33

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                              BIG OTTER
                                LAKE
                                 O
                           LAKE JAME
                              CROOKED LAKE


                         OJIMMERSON
                             LAKE
0.01
    1.0                             10.0                            100.0

                         MEAN DEPTH (METERS)


                 L=AREAL PHOSPHORUS INPUT (g/m^yr)

                 R=PHOSPHORUS RETENTION COEFFICIENT

                 P-HYDRAULIC FLUSHING RATE (yr"1)
    FIGURE  5.     TROPHIC CONDITIONS OF MARSH LAKE, SNOW LAKE,
    BIG OTTER LAKE,  LAKE JAMES,  LAKE GAGE,  CROOKED LAKE, JIMMERSON LAKE,

                       AND LIME  LAKE  (1973-1974)
                                 34

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     The Facilities Plan  Proposed  Action would eliminate septic tank effluent
disharges  to  the Steuben  Lakes.   However,  as discussed in Chapter  I,  septic
tanks currently  do  not have significant impacts on water  quality and aquatic
vegetation in the lakes.

     In the Facilities Plan Proposed Action, there is  a possibility of pumping
station breakdown  causing significant raw wastewater discharges  to  the lake.
Careful design  and close  supervision of the pumping  stations  would minimize
this possibility.   Small  wastewater pumping units (3,000 to 5,000 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 ensure against
backups or overflows  to the lakes.  Because  the magnitude  of spills with the
Limited Action  Alternative is  about  two orders of magnitude less than it is
with the Facilities Plan Proposed  Action, the threat  of impact from equipment
failure is less great under the Limited Action Alternative.

B.  GROUNDWATER

     No  significant  short-term  impacts on  groundwater quality  would  result
from the construction of any  of the  alternatives.  Long-term impacts on bac-
terial concentration,  shoreline  algal growths,  and nitrate concentrations are
also expected to be insignificant.

     The Facilities  Plan  Proposed Action  would  eliminate  the  discharge of
wastewater effluents to the groundwaters around the Steuben Lakes.  The threat
of  well  water  contamination   from septic  tank effluents  would be  removed.
However, actual  improvement of  potable groundwater supply would be minor at
best.   Based  on  the   results  of  the  1979  well water  study, the quality of
groundwater  (bacteriological  and  chemical)  in  the  Study Area  is  of  a  high
standard.  The  effects of  more than 50 years  of  septic tank/soil  absorption
systems on water quality are insignificant.

     The Limited Action Alternative would minimize potential hazards to drink-
ing water  by  1)  inspecting existing wells  and  filter  fields, 2) sampling all
wells, and 3) selecting  on-site or off-site measures to stop  actual or pos-
sible drinking  water   contamination.   These repair measures  will include the
elimination of cesspools arid inadequately sized septic tanks,  and the replace-
ment of  malfunctioning ST/SAS's.   Costs for these measures  are  included in
Appendix E and G.  Also,  the  actual  repair (such as  grouting)  of  wells may
often prove less expensive than treatment modifications.

C.  POPULATION AND LAND USE

     Significant population growth differentials are found when the Facilities
Plan Alternative is compared with the Limited Action Alternative.  Restriction
to on-site facilities  throughout  the Study Area would  constrain future popu-
lation growth below the level  that is  anticipated with the provision of off-
site (centralized) wastewater treatment.  In-summer population in the Proposed
Service Area is projected to grow by 33% from 1975 to 2000.  Under the Limited
Action Alternative  the  growth  would be  limited  to an  estimated 22% above the
1975 level.

     Adoption of the  Limited  Action Alternative would result in conversion of
500  acres  of  land to  residential  use, while  the  Facilities  Plan Proposed
                                    35

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Action would  result in  conversion  of approximately  420  acres.   The  greater
residential land  requirement  of the  Limited Action Alternative, despite  its
lower rate  of population growth,  is  because  of  the scattered  lower-density
development  that   is  associated with it.   Thus,  it  is  estimated  that  the
Limited Action  Alternative  will result  in the consumption  of over 40% more
land to accommodate 33% fewer  people between 1975  and 2000 than the Facilities
Plan Alternative would.

D.  ECONOMIC IMPACTS

     The economic  impacts of either alternative are a result  of direct  cost to
system users.   The estimated  direct  cost is the  most  significant difference
between the two  alternatives,  in  terms  of  either  environmental  or  social
impacts.   With  the Facilities  Plan Proposed Action, the  1980 average annual
homeowner's cost*  around the  Steuben Lake would  be $450.   In contrast, with
the Limited Action Alternative the  1980 average annual homeowner's cost around
the Steuben Lakes  is $50.

     The impact of these user  charges  is defined in terms of  the  percentage of
the population facing significant financial burdens and displacement  pressure.
EPA defines "significant financial burden"  as a  charge greater than 1.5 to
2.5% of  total income; the  variable threshold rate is 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 5  presents  the percentage of the population that would  experi-
ence significant financial burden and  displacement pressure for the Facilities
Plan Proposed Action and the Limited Action Alternative.
*  "Average  annual  homeowner's  cost" includes one residence's  equal  share of
    his  community's  1980  debt retirement cost, plus  1980  operating expenses,
    plus  a  reserve  fund  contribution of 20% of  this  debt  retirement share.
    To this  is  added an equivalent annual payment for  private costs (such as
    house sewers) as if they were paid at 6-5/8% for 30 years.


Table 5.  Percentage of Population that would Experience Financial Burden and
          Displacement Pressure


                              Displacement        Financial            Can
     Alternative                pressure            burden            afford


Facilities Plan
  Proposed Action                10-20%           40-50%               50-60%

Limited Action                   <2%               2-5%                95-98%
                                    36

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                                  CHAPTER V
                         PUBLIC AND AGENCY COMMENTS

     Substantive  public  and agency  comments  on the Draft  EIS were received.
They have  been summarized in this chapter.   Those  comments that were offered
through testimony at the Public Hearing on the Draft EIS (28 January 1980) and
through  written correspondence, and  are essential to  the  EIS decisionmaking
process  are responded to  here.   The  comments  and appropriate  responses are
organized by Draft EIS subject area, including:

        Water  quality
        Soils
        Field  data collection
        Alternative
        Implementation/Management
        Impacts
        The EIS process

     Citizens  who  offered  substantive comments on the Draft EIS at the public
hearing or  by  written correspondence to EPA  are  listed below.  Numbers which
follow  the  citizen's names  identify the comments  addressed  in this chapter.
All substantive written  comments  on the Draft EIS are included in Appendix 4.
Name

Buell Ferguson
Richard Mick
Craig Benson
Joseph Cloud

Gordon Leisch
Donald Ahlersmeyer
Charles Whitacre
Mr. Hippensteele
Evelyn Hensel
Affiliation

USDA Soil Conservation Service
Mick, Rowland and Associates, Inc.
Steuben Lakes Regional Waste District
State of Indiana - Dept. of Natural
  Resources
US Dept. of Interior
Study Area Resident
Study Area Resident
Study Area Resident
Study Area Resident
Comment Number
8, 9, 10, 18
11, 12, 13, 14,
 15, 18, 19, 20,
 25, 26
23

24
1, 2, 27
3, 4, 7, 21
6, 16, 17
22
A.  WATER QUALITY

Comment   Why  are  the manmade  channel  areas  suspect  for water  quality pro-
1         blems?  (Ahlersmeyer)

Response  The  septic  leachate   studies  have  revealed a  number  of  effluent
1         plumes in the cut-and-fill canal developments on the lakes.   Average
          levels of  ammonia  were observed to be about 2 mg/1 in winter and 10
          mg/1  in  summer  for  groundwater  plume  samples taken  from canals,
          harbors,  and sheltered or semi-enclosed small bays, particularly the
          Lagoona  Bay,  Lake  James Marina,  and  Red  Sand  Beach  areas.   The
          higher levels  found  during  the August  survey included  one  sample
          from a canal below Pokagon  State Park on the northeast shore (lower
          basin), which registered as  high as 62 mg/1.
                                    37

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Comment
2
Two  factors  produce  the  above-average frequency  of  plumes  in  the
canals.   First,  septic  tank systems  are  installed  in the  dredge
spoils pulled out  of  the  wetlands to make  canals.  This  fill mate-
rial and  the decaying vegetation covered  by the fill  do not provide
adequate  treatment of  septic  tank  effluent.   Second, because  the
canals do not  receive  much  flow and  are protected  from  the wind,
there  is  little mixing of the  effluent with lake water.  This makes
the  effluent  plume stronger and more  easily  detected than  plumes
entering the main body of the lake.

Why  has   no  recommendation  been  made  for  the  elimination  of  the
phosphorus plume emanating from Marsh Lake?   (Ahlersmeyer)
Response  Marsh Lake  is  currently classified by  the State  of  Indiana as  a
2         Northern Pike  fishery.   EPA has discussed  lake  renovation programs
          to clean  up the  lake  with the  State.   The State  has  decided that
          renovation  activities  would harm  the  fishery.   Also,  the  lake  is
          listed for nomination as a National Natural Landmark.

Comment   It appears  that  the National  Eutrophication  Survey's  (NES)  study
3         assumption  that  all septic  tank/soil  absorption  systems  (ST/SASs)
          within 300  feet  of  lakes allow septic  leachate into the lake cannot
          be substantiated,  nor  can the  ST/SAS  regulation with regards  to
          minimum distance between lakes  and wells.  (Whitacre)

Response  Sampling programs  in other  rural  lake  communities in  the  midwest
3         indicate that there  is  more  assimilative capacity for  wastewater in
          this  particular  setting  than assumed previously.  The  Steuben Lakes
          are  a  prime  example of  a vigorous  enforcement  program  and  high
          assimilative capacity combining to provide a high  level of  protec-
          tion  for water resources and public health.

          As discussed  in  this  Final EIS,  EPA  does not  suggest abandoning
          State- or  locally-approved design  standards.  The design  standards
          are appropriate for new systems on new lots, for existing lots where
          the standards can be met,  or in other  situations where the cost of
          detailed soils and  groundwater  studies cannot  be justified.   We are
          proposing that  variances to current design  standards  be considered
          for existing dwelling if site  studies  show  the  risks  of subcode or
          innovative designs to be acceptable.

          Some  states (not  Indiana)  have  objected to the suggestion of allow-
          ing variances  on the basis  that  it is  administratively unworkable
          and will  substantially  increase the State's costs  for  rural waste-
          water management.  If the alternative to variances is sewering, then
          the states  will  achieve  a false economy in their operating expenses
          and a false stability  in their  administrative  routines.  The costs
          of sewering rural communities is much greater than the costs of site
          analysis,  decentralized  technologies  and   communities  management.
          With  sewers the states  may hold their costs to a minimum, but at the
          expense of residents who pay the local costs.

          As for  the NES  assumption that all nearby  effluent plumes  reach a
          lake, this  apparently  does  not. hold  true  for  many  lakes.   There-
                                    38

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          fore, it is a conservative assumption that needs to be verified when
          expensive decisions rest on its validity.   Another NES assumption is
          that 0.25 pounds  of  phosphorus per year per person are carried into
          a lake with  each  plume.   This assumption is more  costly to verify.
          Data collected so  far  suggest that this is a reasonable average for
          those plumes that  do  enter a lake.  However, individual systems may
          generate widely varying  phosphorus inputs,  however, as evidenced by
          the groundwater sampling results reported in Chapter I of this Final
          EIS.
B.  SOILS

Comment   The Draft EIS  has  not addressed the 196 acre Industrial Park within
4         the Study Area,  nor  has  it mentioned a change of use for two areas:
          the Lake James  Country  Club,  and the Pokagon Girls Camp.  Both have
          been converted from recreational areas to residential uses.   Both of
          these areas  have soils  that  will not  support  ST/SASs.   (Whitacre)

Response  Comments noted.   Information  for  design purposes in  the Draft EIS
4         was obtained from  the best available sources, including the Facili-
          ties Plan and  the  Steuben County Planning Department.   However, the
          Limited Action  concepts  could be applied to  light industrial parks
          (by use of  large cluster systems) as well as to the two residential
          areas.

Comment   The soils data  utilized  in the Draft EIS have changed.  (US Depart-
5         ment of Agriculture—Soil Conservation Service)
Response  Comment noted.   New data  are  included in  Appendix F  of  this  EIS.
5

C.  FIELD DATA COLLECTION
Comment   Why is there  a  large discrepancy between the number of positive dye
6         tests  (septic  effluent  entering  lake)  and the  number of  plumes
          detected by the Septic Snooper?  (Hippensteele)

Response  Figure 11-18  of  the  Draft  EIS shows the locations of malfunctioning
6         ST/SASs  that  were  identified in  eight  dye test  programs by  the
          Steuben  County  Health Department   (SCHD).   Owners of  such systems
          were  required to  take  immediate  corrective  actions.   The  SCHD's
          monitoring and enforcement programs  have probably been effective in
          reducing a large majority  of adverse impacts on  surface water qua-
          lity.

          Most of  the positive dye tests found by  the Health Department were
          located  on  upland  sites  and  evidently  represented surface  malfunc-
          tions.   Unless  these systems were  still malfunctioning  and  their
          wastes were running  off  into the lake,  the septic leachate detector
          would not find them.

          The dye  studies  did  not  find many malfunctioning  systems  along the
          shoreline,  possibly  because  the  dye was too  diluted  to be  visible.
          The leachate  detector  is a more  sensitive means of finding effluent
          and actually found  more shoreline plumes then the dye study.

                                    39

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D.  ALTERNATIVES

Comment   The EPA estimate  that  50% of the STs  and  10% of the SASs will need
7         to be replaced is greatly understated.   (Whitacre)

Response  The data collected about the Steuben Lakes'  on-site systems are more
7         extensive  than 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.   However,  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's as  a Step 2 grant (75% if
          conducted with a  Step  1 grant.)  in  order  to  ,  first, provide neces-
          sary  information  for  site  specific facilities  design  and,  second,
          verify or modify  our  conclusion  that continued  use  of  on-site sys-
          tems 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
          alternatives  which  include  continued  use  of  on-site  systems, fac-
          tors  subject  to  uncertainty  were  estimated conservatively  high,
          especially  the percent  replacement  of  septic  tanks and drainfields.
          In  addition,  costs  for  operation  and maintenance and  for  the site
          specific analysis have  been re-examined for this  Final  EIS  in more
          detail and  with conservative estimates.  Boosting these cost esti-
          mates  has  made  no  difference  in  the ranking  of  the  recommended
          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 proce-
          dures (Appendix B).   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.

Comment   The EIS Recommended Action  is only a  temporary  solution for waste-
8         water needs  of the Study Area.   (Mick, Rowland & Associate,  Inc.)

Response  There is sufficient information  on the condition and effects of the
8         existing on-site systems to predict that their continued use in most
          areas around  the  Steuben Lakes  area will be acceptable  for years to
          come.   The  existing systems are  up to 50 years  old; many are under-
          sized 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.

          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

                                    40

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               •  Provision  of  adequate community  supervision of all  waste-
                  water facilities, and

               •  Measurement of  and designing with  the  natural  assimilative
                  capacity of local  soil/groundwater/surface  water resources.

          The Limited Action Alternative may not be  the  optimal  solution for
          the  Steuben  Lakes  area  beyond   the  year  2000.   Housing  density,
          demands  for  commercial  development  and  difficult on-site  system
          problems  could  increase  to  the  point  that centralized  treatment
          becomes economically  justifiable.   If  and  when that point  will be
          reached cannot be  predicted.   EPA's judgement,  based on a  consider-
          able 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.

Comment   The cost of the Limited Action Alternative is completely unknown and
9         cannot be  estimated  until  a  great deal  of on-site engineering is
          accomplished.  (Mick,  Rowland & Associates, Inc.)

Response  The data  obtained  and  utilized  in the  formulation of  the  Limited
9         Action Alternative is  felt to be sufficient to  determine the alter-
          natives'   feasibility   and   cost  effectiveness.   EPA has  estimated
          conservatively high  those  factors that are  subject  to  uncertainty.
          This estimate includes  costs  for the detailed site-by-site analysis
          as well as costs  for operation and maintenance.   The design work for
          the Limited  Action Alternative  will  be  totally dependent  upon the
          actual conditions that the  site-by-site analysis uncovers.

Comment   The Draft EIS Limited Action Alternative shows initial  capital costs
10        of $4.894 million  and 1980 to 2000 capital costs  of $4.751 million.
          This  looks  like 9.645 million  in total  capital  cost.  Will  that
          4.751 million  required between  1980  and 2000  be  funded by  EPA or
          will it end up being paid by local residents as  0  & M costs?  (Mick,
          Rowland & Associates,  Inc.)

Response  Federal participation for on-site wastewater management only applies
10        to homes  constructed  prior  to December  1977 the  same  as  for cen-
          tralized  sewer  projects.   All  other  homes will  be excluded  from
          Federal Construction  Grants  funding.   This  means  in effect that all
          costs beyond those shown for 1980 will have to be  borne locally by
          the small flows district or by the individual homeowner.

          If the small waste  flows  district wants  to, it can develop a local
          reserve fund to pay for future on-site waste management systems.  We
          have assumed that future construction costs are  going to be borne by
          the homeowners who are  going to  use the system.  Therefore, a large
          part of  the total capital  cost  for the project is  deferred  to the
          future and  it  rests  on  those people  who are  demanding additional
          service.   They will pay  in direct proportion to the sewage that is
          going to be generated.
                                    41

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Comment   Uncertainty exists for the availability of Federal funds  for Step 1,
11        2, or 3.   (Steuben Lakes Regional Waste District - SLRWD)

Response  The  future  financial  status  of  EPA's Construction Grants  program
11        rests with  the  United States  Congress.  The possibility does  exist
          that in the future  money may  no longer be  available.  However,  the
          action recommended  by this EIS  represents the  least  cost  project,
          independent of Federal funding.

Comment   For  systems  that do  not have  existing problems, would preventive
12        measures   to  delay  or avoid future  problems  be  eligible?   (SLWRD)

Response  Preventive measures  would be  eligible where detailed  site  analysis
12        on  similar  lots  shows  a  high  rate  of  failure and  indicates  the
          causes of failure.

          Measures  that address  these causes  for failure will be  eligible as
          long as other eligibility criteria  are met.  See  also Section II.B
          of this Final  EIS.

Comment   Could problems other than public health, groundwater quality,
13        or  surface  water quality be  eligibile for the  funding  of  repairs,
          renovations  or  replacements?    Examples   of  "other  problems"  are
          odors, limited  hydraulic capacity,  and periodic  backups.   (SLRWD)

Response  Region V-EPA has  clearly defined its policies on Federal  funds  for
13        on-site waste  management in a document titled  "Site-Specific  Needs
          Determination and  Alternative  Planning for Unsewered  Areas."   This
          document is included  as Appendix B of  this EIS.   Unless  other pro-
          blems were  associated with odors  (such as surface  ponding or well
          water  contamination), odors alone  would  not  qualify  a system  for
          Federal  aid.   On-site  solutions for  the other  two aforementioned
          problems would  qualify for  Federal  aid.  See also  Section  II. B of
          this Final EIS.

Comment   Is  nonconformance with modern  sanitary codes suitable justification
14        for  eligibility to fund  repairs, renovations  or replacements?  Can
          nonconformance be used as a measure of need for preventive measures?
          (SLRWD)

Response  No.  Nonconformance  can be  used as a  reason  to  closely  examine the
14        usage, condition,  and water quality  impacts  of individual  systems.
          See also R-12.

Comment   If  a  system  is  causing public health,  groundwater quality, or sur-
15        face  water quality  problems  but  site limitations  prevent  a  new
          on-site system from satisfying sanitary codes, would a nonconforming
          on-site replacement  be eligible if it would solve the existing pro-
          blems?  (SLRWD)

Response  Yes, if structure was built prior to December 1977.
15
                                    42

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16
Comment   Are cluster systems considered alternative and innovative wastewater
16        management?  Are  they eligible  for  85% grants and  100% federally-
          paid-for replacement  with a  conventional  sewer system,  if  the  EIS
          proposal fails within ten years?  (Hippensteele)

Response  The 1977 Clean Water  Act authorized for a three year  period ending
          in September 1981,  a  program of financial incentives to municipali-
          ties willing to incorporate innovative and alternative  technology in
          their plans  for  sewage  treatment  projects.   The  program is to  be
          funded by EPA Construction Grants.

          "Innovative technology" includes methods and  processes  which, though
          already  developed  and offering  definite  economic  or  environmental
          benefits,  are  not  yet fully proven, and therefore, at  least theo-
          retically,   involve  some  risk  of   failure.    "Alternative  techno-
          logies," although  they  differ from those used in  standard sewage
          treatment  plants,   are  proven  methods  of   wastewater  treatment.
          Cluster  systems  and  ST/SAS's  would fall  in this  latter category.

          To  communities  that  incorporate new  and different technology  in
          their  sewage  treatment  planning,  EPA is  authorized to  offer  sub-
          stantial financial  incentives.   EPA will provide 85 percent of  the
          design and construction  (Step  2 and Step 3)  costs of  approved  pro-
          jects that use innovative  or alternative technology, instead of the
          usual 75 percent.   (The  85  percent funding  also  applies to those
          portions of a conventional project  considered innovative or alterna-
          tive).  In the rare  instance where such a project  fails to meet its
          design goals within its first two years of operation, EPA will repay
          100% of the costs  of measures taken to correct or replace the failed
          system.   The  correction  or  replacement  would not necessarily be a
          conventional sewer system.

          At what point will  Federal funding  for on-site wastewater management
          be stopped?  (Hippensteele)
Comment
17
Response  The  Applicant  is  not  prohibited from  filing  Construction  Grants
17        applications  in the  future.   The  response to  future applications
          will be  directed by Construction Grants policies at that time.  See
          also Response #10.

E.  IMPLEMENTATION/MANAGEMENT

Comment   The  Limited Action  Alternative   requires  establishment of  a small
18        flows district.  Currently,  there is a lack of statuatory authority
          to administer  this  district  in Indiana.  (SLRWD and Mick, Rowland &
          Associates, Inc.)

Response  The  Indiana  State  Board  of  Health  has  consulted with  their legal
18
          department and  has  stated  that  the Steuben  Lakes Regional  Waste
          District  (SLRWD)  has  enough authority  currently to plan,  install,
          and operate cluster systems.   In  addition,  it was  stated  that this
          authority also  extends  to on-site  systems.   EPA has sought  a con-
          curring  opinion  from  the  State's  Attorney  General  but  has  not
          received a response in time  to incorporate it into this  Final EIS.
                                    43

-------
Comment   The Steuben  Lakes  Region Waste  District (SLRWD) does not  have  the
19        ability to raise matching monies  required for continuation of Step 1
          or 2.   (SLRWD)

Response  This  problem would exist  even if  the  Facilities Plan  Alternative
19        were  chosen.   The  Limited Action  Alternative represents  the least
          cost to the SLRWD to take care of its problems.

Comment   Doubt  exists as  to whether  the  State  Board of Health will  ever
20        modify any standards it  has  adopted concerning septic tank and soil
          absorption system (ST/SAS's)  guidelines.   (SLWRD)

Response  There is  a program  currently underway by the Indiana State Board of
20        Health  that  would  modify existing  regulations   concerning on-site
          wastewater management.   The State Board of Health is  funding a study
          by  the  Purdue  University  Department of  Agronomy that  has already
          produced  the preliminary recommendation that the existing  codes be
          modified to  allow operation  on tighter soils, using  such techniques
          as wastewater dosing.

Comment   Can we  expect to see  some  realistic regulations based  on  the data
21        gathered  during the  preparation  of the  Generic EIS?   (Whitacre)

Response  The Generic  EIS  will  discuss  several  aspects  of  current on-site
21        management procedures,  including regulations, in light  of informa-
          tion published  in the  literature as well as  data  collected for the
          Generic and  the seven individual  EIS's.  It  is possible  that  the
          Generic EIS will recommend changes in on-site management procedures.
          Outside of specific projects  funded by EPA,  adoption  of any recom-
          mended  changes  is  the  perogative of  State  and  local governments.
          EPA would  like to  see  several comprehensive  Step  2  site  analyses
          completed before  any  changes  in  design  regulations  for other than
          existing systems are recommended.

Comment   Reservations  exist  about the  establishment  of  a small  waste flows
22        district.   Why can't  the  County Health  Department  be  given these
          responsibilities?  (Hensel)

Response  The Steuberi  County  Health Department  (SCHD) has been exemplary in
22        its approach to monitoring  on-site  system  performance  and in con-
          ducting water quality  studies.    Given  the  Department's available
          expertise, local knowledge and legal authorities, it  is obvious that
          it  should play  a  major  role in  management  of the  decentralized
          system.

F.  IMPACTS

Comment   Several valuable  and  high  quality  natural  areas exist  within the
23        Study Area and  aren't  noted  in the  Draft EIS.   (State of  Indiana--
          Department of Natural Resources)

Response  Comment noted.   This  information  has  been  included in Appendix A.
23
In addition,  an  analysis  was made to  ascertain  whether these sites
would  be directly  impacted  by  either  the No-Action  Alternative,
Limited Action Alternative,  or  the Facilities Plan Alternative.  It
was determined that these areas would not be impacted.

                          44

-------
Comment   The Final EIS  should  indicate that Marsh Lake  Basin  is  a potential
24        national  natural  landmark  currently  recommended for  designation.
          (Leisch, US Department of the Interior)

Response  Comment noted.   Marsh  Lake  lies  near but outside the  Study Area and
24        will not  be impacted  by the Alternative  recommended in  the  Final
          EIS.

G.  THE EIS PROCESS

Comment   The  findings  of the  Citizens  Advisory  Committee apparently  were
25        ingnored in the Draft EIS.  (SLRWD)

Response  Information  generated  by the Citizens  Advisory  Committee  was  uti-
25        lized in  this  EIS.   Much of the information, however, was personal
          opinion  gathered during  a  survey of  the area.   This  information,
          although useful  for ascertaining  attitudes  towards sewers, does not
          help in the technical analysis of alternatives.

Comment   The Board  of Trustees  was  bypassed on  information  as  it was  com-
26        piled,  most noticeably in receipt of the Draft EIS.  It is felt that
          the Trustees should have been the prime recipient of  any information
          because  they are  the  entity  that  will  have  to  take  the  lead  in
          implementing  the  suggested  alternative  and  raising the  matching
          funds required.  (SLRWD)

Response  EPA has had  numerous  meetings and telephone contacts  with the SLRWD
26        and especially with its attorney,  Mr. Craig Benson.  It is felt that
          adequate  information  flow between EPA and  the Waste District did
          indeed take place.

Comment   Why was  the Public Hearing  held  on a weeknight  in the  off-season?
27        (Ahlersmeyer)

Response  The hearing  was held  on January  28,  1980  because Federal  Regula-
27        tions state that a  Public Hearing be held within a certain amount of
          time after publication of the Draft EIS.   The information and recom-
          mendations presented at the  Public Hearing were essentially the same
          as  those  presented  at  a public  information meeting held in the
          summer of 1979 when seasonal residents could attend.
                                    45

-------
         APPENDIX A




Letters and Written Comments

-------
                     DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                      AREA OFFICE

                                   151 NORTH DELAWARE

                                 INDIANAPOLIS, INDIANA 46204
300 Souerlve
Chicago, Illinois 60606                                                        IN REPLY REFER TO:

                                                                       5.4SS:BGD
                                                                        >      .,—
                                                                      t-J       ;
                                                                       c.—
          Mr. Gene Wojcik
          Chief, EIS Section                                             ij^
          U.S. Environmental Protection Agency
          Region V                                                        ^
          230 South Dearborn Street                                             -  ')
          Chicago, IL  60604                                        •_     f5

          Dear Mr. Wojcik:

          Subject:  Draft EIS
                    Alternative Waste Treatment  Systems
                    Steuben Lakes Regional Waste District
                    Steuben County, Indiana

          We have completed our review of the Draft  Environmental  Impact State-
          ment relative to the subject proposal.   Please be advised that we
          have no comments to add at this time.   We  appreciate the opportunity
          to review the Draft EIS and will look  forward  to receiving a copy of
          the Final EIS upon its completion.

          Sincerely,
                 X
          Howard L. CampBell
          Area Manager

-------
             U.S. DEPARTMENT OF TRANSPORTATION
                 FEDERAL HIGHWAY ADMINISTRATION
                             REGION 5
                         182O9 DIXIE HIGHWAY
                     HOMEWOOD. ILLINOIS  6O43O

                         January 16, 1980
                                                   IN REPLY REFER TO_;

                                                     HED-05     __
                                                                c~
Ms. Kathleen Schaub                                             ^
Project Monitor
U.S. Environmental Protection Agency                      -_,     i>o
230 South Dearborn Street                                 T     ^
Chicago, Illinois  60609

Dear Ms. Schaub:

The draft environmental statement for alternative waste  treatment

systems for rural lakes project - case study number 4, Steuben

Lakes Regional Waste District, Steuben County, Indiana,  has been

reviewed.  The alternate waste treatment  systems for  the rural

lakes projects should have no effect on Federal-aid highways  or

highway projects.  We, therefore, have no comments on the proposed

action.

                                     S inc er ely yours,

                                     Donald E. Trull
                                     Regional Administrator
                                     _     /   , s          -*
                                     By:
                                          W. G. Emrich, Director
                                          Office of Environment and Design

-------
     United States
     Department of
     Agriculture
                     Soil
                     Conservation
                     Service
5610 Crawfordsville Road
Suite 2200
Indianapolis, Indiana 46224
                                                         February 6, 1980
      Mr. Gene Wojcik, Chief
      EIS Section
      Environmental Protection Agency
      230 South Dearborn Street
      Chicago, Illinois  60604
      Dear Mr. Wojcik:
                                                                         c
                                                                         c
      We have reviewed the draft environmental impact statement on Alternative
      Waste Treatment Systems for Rural  Lake  Projects, Steuben County, Indiana,
      and offer the following comments:

      Page 37

      The soils data were provided  to  you in  December 1977 by Art Mumma, District
      Conservationist, Angola Field Office.   This data was correct at that time,
      however, some changes have been  made since then.  We recommend modifying
      this section to reflect these changes.

      1.   The Fox series is now the Kosciusko series.

      2.   Effective March 31,  1978, both the Boyer and Kosciusko series are  now
           listed as having severe  limitations for septic tank absorption fields.
           Soils with permeability  rates greater than 6 inches per hour in any
           layer below 24 inches are rated severe due to poor filter.  Both of
           these soils have a layer between 34 and 60 inches with permeability
           greater than 20 inches per  hour.

      3.   Permeability of the  Riddles series ranges from 0.6 to 2.0 inches per
           hour.

      4.   Permeability of the  Oshtemo series ranges from 2 to greater than 20  inches
           per hour.

      Figure II-6 on page 38 should be corrected to reflect these changes in  limi-
      tations .
A
The Soil Conservation Service
is an agency of the
Department of Agriculture
                                  SCS-AS-1
                                  10-79

-------
Mr. Gene Wojcik, Chief                                      Page 2
Page 41. Table II-2

The following soils are now listed as being Prime Agricultural Lands of
Steuben County:
Soil Symbol    Soil Name

Ad             Adrian muck, drained
BnA            Blount silt loam, 0 to 3 percent slopes
BtA            Brems fine sand, 0 to 2 percent slopes
Bz             Brookston loam
CcA            Carmi sandy loam, 0 to 2 percent slopes
CrA            Crosier loam, 0 to 3 percent slopes
Dr             Del Rey silt loam, 0 to 3 percent slopes
Ed             Edwards muck, drained
GnB            Glynwood silt loam, 2 to 6 percent slopes
HaA            Haskins loam, 0 to 3 percent slopes
Hw             Houghton muck, drained
KoA            Kosciusko sandy loam, 0 to 2 percent slopes
KoB            Kosciusko sandy loam, 2 to 6 percent slopes
MbA            Martinsville loam, 0 to 2 percent slopes
MbB            Martinsville loam, 2 to 6 percent slopes
MfB            Metea loamy sand, 1 to 6 percent slopes
MfC            Metea loamy sand, 6 to 12 percent slopes
MhB            Miami loam, 2 to 6 percent slopes, eroded
Mn             Milford silty clay loam
Mm             Millgrove loam
MX             Morocco loamy sand
Mz             Muskego muck, drained
OhA            Oshtemo-Ormas loamy sands, 0 to 2 percent slopes
OhB            Oshtemo-Ormas loamy sands, 2 to 6 percent slopes
OhC            Oshtemo-Ormas loamy sands, 6 to 12 percent slopes
OsC            Oshtemo-Kosciusko-Riddles, complex, 4 to 6 percent slopes
Pa             Palms muck, drained
Pe             Pewamo silty clay loam
RaB            Rawson loam, 2 to 6 percent slopes, eroded
Rb             Rensselaer loam
RxA            Riddles sandy loam, 0 to 2 percent slopes
RxB            Riddles sandy loam, 2 to 6 percent slopes, eroded
Ry             Riverdale loamy sand
Wa             Wallkill silt loam
Wh             Washtenaw silt loam
WsB            Wawasee loam, 2 to 6 percent slopes
Wx             Whitaker loam
Some of these soils names and mapping symbols were changed during final soil
mapping correlation.  Enclosed is a copy of the final correlation showing
the old field symbols and map unit names and their corresponding new publi-
cation symbols and map unit names.

-------
Mr. Gene Wojcik, Chief                                      Page 3
Table II-7 on page 42 should be checked and corrected to reflect changes in
the above listed soils and the enclosed final correlation.

Page 174, 3rd Paragraph

There are no state or local erosion control requirements, therefore we
recommend this paragraph be changed as follows:

     Recommendations for erosion control measures will be requested
     from the Angola Field Office.  These recommendations will be
     followed during installation of this system.

We appreciate the opportunity to review and comment on this draft environmental
impact statement.  If you need additional data, please contact us.

Sincerely,
Buell M. Ferguson
State Conservationist

Enclosure

cc: w/o enclosure
Administrator, SCS, USDA, WO  20013
Director, Office of Fed. Activities, EPA, WO  20460(5)
R. Mast, ASTC, SCS, Indianapolis, IN
F. Schoeck, AC, SCS, Kendallville, IN

RLS:C: 7/2-4

-------
 CONVERSION LEGEND  FOR
STEOBEN COUNTY, INDIANA
     JANUARY 1979

Field
symbol
Ad
Am
AuA
EaA
Be

En
Bo A
BOB
BoB2
BoC
BoC2
BoD
EoD2
BpA
Bp
3s
BtA
EX
BZ
CaB
CaB2
CaC

CaC2
CaC3
CaD2
CaD3
Cf

ChA
ChB
ChC
ChD
CrA
CsA
Ce
crA
Dr
Ed

FoA
FOB
FOB2
FoC
FoC2
Publi-
caticn
symbol
Ad
Ad
Hy
BnA
Be

.in
BOB
BOB
BoB
BoC
BoC
BoD
BoD
By
Ry
Ry
BtA
BZ
Ez
CaC
CaC
CaC

CaC
CaC
CaD2
CaD2
Ud

ChB
ChB
ChC
ChC
CrA
CrA
Dr
Dr
Dr
Ed

KoA
KoB
Ko3
KsC
KsC

Field
symbol
FxC
Gf
Gp
GS
Ha A

Ht
Hw
Hx
Lb
Ha

MbA
MbB
MbE2
HbC
MbC2

Me
Hd
He
HfA
HfB
MfC
MhB
HhB2
HhC
MhC2
HhD

MhD2
HhE
Mh£2
3kC3
MkD3
Hn
HOB
HoB2
MoC2
HoD2

HoE2
HrC3
MrD3
MsC3
MsD3
Publi-
cation
symbol
KsC
Co
Pg
GS
HaA

Ht
Hw
Hn
Be
Ha

MbA
MbB
MbB
HbC
HbC

He
Gs
Gs
HfB
HfB
MfC
MhB
MhB
HhC
HhC
HhD

HhD
HhE
HhE
HXC3
HkD3
Hn
GnB
GnB
HoC2
HoD2

HoE2
HrC3
HrD3
HrC3
MrD3

Field
symbol
HxA
HZ
OCA
OcB
OCC
Of
OhA
OhB
OhB2
OhC
OhC2
OhD2
OsC
OSC2
Pa
Pd
Pe

Fg
PnA
PnB
PnC
RaB

RaB2
EaC2
Bb
PcB2
RcC2
Rh
RxA
RxB
RXB2
RXC
RXC2
RxD
EXD2
Sb
Se
Sf
Sh
Td
Ha
HcA
Hh
SsB
Publi-
cation
symbol
Hx
HZ
PnA
PnB
PnB
Ud
OhA
OhB
OhB
OhC
OhC >
BoD
OsC
OSC
Pa
Pa
Pe

Pg
PnA
PnB
PnB
RaB

RaB
RaB
Rb
RaB
RaB
Rb
RxA
RxB
RxB
ExC
RxC
RxD
RxD
Hm
MB
Hn
Sh
Hx
wa
CcA
Wh
WsB
Publi-
Field cation
symbol symbol
WsC WsC
WsC3 WvC3
WsD WsD
WsD3 WvD3
WsE WsE

WtA Wx
WvC3 WvC3
WvD3 WvD3





































          11

-------

. — tCkClCt AID FkOPOH lOllTi. tlTtKT OF IMk SOILS
A«p
sy»be
Id
BE
81 1
BOB
BoC
boD
Btl
ax
c*c
C«D2
CCl
CkB
ChC
CO
Crl
be
Ed
CaB
C>
Hat
HI
Ht
H»
noi
KoB
KSC
Rbl
BbB
BbC
BC
H«
BfC
BhB
HfcC
nkD
HkC
nkC3
nk03
H>
B»
floC2
noD2
ltoE2
nrC3
nc03
HI
B*
Okt
OkB
OhC
0»C
Pa
p«
H
P0»
PnB
I«B
Bb
IXI
IxB
BIC
IlD
• I
Dd
u*
Kb
USB
use
USD
y«e
K»C3
1
1 Soil 0,1 ••
•11
1
1








|Cacco gravelly sandy loan* 12 to 18 per cunt slopes* eroded


















in art ins villa loan* 6 to 12 percent slopes — 	 	 	 — .------



(Riant, loan* 2 to 6 percent slopes 	 * 	 	 	 	 	 ----



(Riani clay loan* 6 to 12 percent slopes, severely eroded- -




jnorlity silt loan* 12 to 18 percent slopes, eroded-* 	 	 	
(Horley silt loan* IB to 25 percent slopes* eroded- 	
(florley silty city loan, 6 to 12 percent slopes, severely e
(ftorley silty clay loan* 12 to 18 percent slopes, severely


|Oshte»o-OrBdS loany sands, 0 to 2 percent slopes- 	
(Osbteno-oraas loany sands* 2 to 6 percent slopes — - — • 	
(O&hteno-Ornas loany sands* 6 to 12 percent slopet 	 • 	

| Pains nock, drained — * 	 	 — * — ------ — ---- — ---. 	 . 	


(Plain field fine sand* 0 to 2 percent slopes 	 	 	 	 	 	
(Plain field fine sand* 2 to 10 percent slopes-- 	

(Benssclaer loan — 	 	 	 	 	 	 	 — 	 	
(Bid diet; sandy loan, 0 to 2 percent slopes-- 	 	 	
(Biddies sandy loan, 2 to & percent nXopes 	
(diddles sandy loan* 6 to 12 percent elopes 	 	 	
(Biddies sandy loan* 12 to Ib percent slopes 	

(Shoals loan 	 ~-~ 	 	 	 ' 	 " 	
JUdorthctita, loany- 	 	 	 .—.------. — 	 	
(Wallkill silt loan 	 	 	 * 	 " — * 	
IVashtenav silt loan 	
( Vawaseu loan* 2 to n percent slopes 	 	 	 --
(Vavasev loan* 6 to 12 percent slopes 	 	 	 " 	 	 	 	 • —
|Ua«ase« loan* 12 to 18 percent slopes-- 	 * 	 * —
(Vawa&ce loan* IB to 25 percent slopes 	 	 — * 	 * 	
IVavauee sandy clay loan* 6 to 12 percent slopes, severely















" 	 • 	 	 	













	 	 — --—---*--»--------





	 	 	 ..----*






































i
lct«s (Pucceot
915
141
10,717
5,Ut>8
2^071
4,198
1,328
1,335
651
927
655
1,283
4,010
610
1,411
23,018
1,483
1,417
5,795
6,558
1,253
3,829
b,633
5,810
281
1,565
701
739
1.516
eoa
6.124
642
843
251
689
374
1.580
2.311
11.876
979
239
2,695
946
397
490
2,243
2,064
H07
979
1,367
7,371
358
1,213
1,481
5,173
3.504
1,659
8,403
5,689
713
759
1,331
2,500
751
1,367
3.374
4,095
956
369
991
0.4
0.1
5.2
2.6
2.2
1.0
0.2
2.0
0.6
0.6
0.3
0.4
0.3
0.6
1.9
0.3
0.7
11.1
0.7
0.7
2.8
3.2
2.1
1.8
3.2
2.B
0.1
O.B
0.3
0.4
0.7
0.4
3.1
0.3
0.4
0.1
0.3
0.2
0.8
1.1
5.7
O.S
0.1
1.3
O.S
0.2
0.2
1.1
1.0
0.4
O.S
0.7
3.6
0.2
0.6
0.7
2.S
1.7
0.8
4.1
2.7
0.3
0.4
0.6
1.2
0.4
0.7
1.6
2.0
o.s
0.2
O.S

VvD3
HI











9 bOO

207 360

03
00
1* (

100 0


-------
          United States Department of the Interior

                        OFFICE OF THE SECRETARY
                          NORTH CENTRAL REGION
                        175 WEST JACKSON BOULEVARD                  - i
                          CHICAGO, ILLINOIS 60604

                                                      February  4;,.. 1980
ER 79/1169

Mr.  John McGuire
Regional Administrator                                           p..
U.S.  Environmental Protection Agency
Region  V                                                         £,      _,'
230  South Dearborn Street
Chicago, Illinois  60604

Dear  Mr. McGuire:

We  have received  the  draft  environmental  statement for  Alternative  Waste
Treatment  Systems for Rural Lake Projects,  Case Study No. 4, Steuben Lakes,
Steuben County, Indiana (ER 79/1169) and have  the following comments.

Basically, we  were pleased to note that the  Limited Action Alternative  is the
recommended plan and will preserve remaining  wetlands in the area.  If within this
alternative  any lands in  Pokagon State Park will be  converted  to  other than
recreational uses, a  Section  6(f) conflict might  result since  Land  and  Water
Conservation Funds are involved.  Contact should be made with the State Liaison
Officer (S.L.O.) responsible for Land and Water Conservation Funds in the State of
Indiana.  The S.L.O. for Indiana is Mr. Joseph  D. Cloud,  Director, Department of
Natural Resources, 608 State Office Building, Indianapolis, Indiana 46204.

Based upon the information provided in the draft environmental statement,  we do
not expect any adverse effects to the Marsh Lake area. The  final  statement should
indicate  that Marsh Lake Basin is a potential national natural landmark,  currently
recommended for designation.  It lies near but outside  the study area.  If you have
any  questions  regarding the  potential landmark, please  contact  the  Heritage
Conservation and Recreation Service,  Lake Central Region, Federal Building, 200
East Liberty, Ann Arbor, Michigan  48107 (FTS 8-378-2027, commercial 313/668-
2027).

The  statement in general indicates  proper consideration  of the  potential for
impacts  on  ground water; however,  septic  disposal  should  be  included  in the
discussion of alternatives and in the assessment  of impacts. A discrepancy between
the estimates for ground-water storage appears in  the first  and last paragraph on
page 56.
                                     Sincerely  yours,
                                                                I
                                     Regional Environmental  Officer

-------
          DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
                         PUBLIC HEALTH SERVICE
                        CENTER FOR DISEASE CONTROL.
                          ATLANTA, GEORGIA 30333


                                    February 4, 1980
Mr. Gene Wojcik                                            '•'    ^    ""
Chief, EIS Section
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois  60609

Dear Mr. Wojcik:

We have reviewed the Draft Environmental Impact Statement (EIS) for
Alternative Waste Treatment Systems for Rural Lake Projects, Case Study
Number 4, Steuben Lakes Regional Waste District, Steuben County, Indiana.
We are responding on behalf of the Public Health Service.

Our review of this statement indicates that the impacts of the proposed
action and the alternatives have been adequately addressed.

Thank you for the opportunity of reviewing this draft document.  We would
appreciate receiving a copy of the final statement when it is issued.

                                    Sincerely yours,
                                    Frank S. Lisella, Ph.D.
                                    Chief, Environmental Affairs Group
                                    Environmental Health Services Division
                                    Bureau of State Services

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STATE:
INDIANA
   DEPARTMENT OF NATURAL RESOURCES

           JOSEPH D. CLOUD
               DIRECTOR
                                                         INDIANAPOLIS, 46204
   Mr. Gene Wojcik, Chief
   EIS Section
   U.S. Environmental Protection Agency
   230 South Dearborn St.
   Chicago, Illinois  60609
                                      FEB 1 4 19S1-
  Re:  DNR #1534, D.E.I.S. - Steuben Lakes  Study  Area,  Steuben County,
  Indiana.
  Dear Mr. Wojcik:

       The above referenced project has been  reviewed  by the  Indiana
  Department of Natural Resources  to enable you  to  assess  its effect on
  the environment.

       When a final project plan has been  developed, and if it is
  anticipated that any of the lake shorelines  will  be  altered or if any
  lake or stream beds will be crossed by sewer lines,  then approval of
  the Indiana Natural Resources Commission will  be  required.

       No known historical or architectural sites will be  affected.  The
  area is suitable for sites of prehistoric occupation, and there must be
  an archaeological reconnaissance of all  undisturbed  areas which will be
  impacted by construction associated with the project.  The  survey must
  be carried out by professionals  meeting  qualifications established by
  the Department of the Interior.   Before  this project can be approved, a
  description of the survey methods and results  must be submitted to our
  Division of Historic Preservation for review and  comment.

       According to our Division of Nature Preserves,  there are several
  high quality natural areas within the study  area  and undoubtedly others
  that are unknown at this time.  These areas, for  the most part, are
  wetlands and our understanding,  based on the report  that you submitted,
  is that they will not be impacted by the proposed project.  However,
  because of the importance of these types of  areas, they  are brought to
  your attention so that any unanticipated impacts  can be  avoided or
  mitigated.
                         "EQUAL OPPORTUNITY EMPLOYER"

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     These areas, briefly described, are as  follows:

     a.  Binkley East Bog - A large bog located  in the center  of the
         W 1/2 of Sec. 31, T38N, RISE and a  portion of the  E  1/2 of the
         E 1/2 of Sec. 36, T38N, R12E.  This tract is a  high  priority
         for preservation and both the Division  of Nature Preserves and
         the Izaak Walton League have hopes  of acquiring it.   It
         includes a forested tamarack bog community, a tall shrub  bog
         community, a low shrub bog community, a gramineous bog
         community, a quaking sedge meadow,  and  a quaking bull rush -
         royal fern community.

     b.  Arethusa Bog - Located in Sec. 19,  T38N, R13E.  This  site has
         a large lowland peat bed forest of  red maple and yellow birch
         and a tamarack-spahagnum bog forest.

     c.  Jimmerson Lake Tamarack Stand - This site is located  in Sec.
         30, T38N, R13E and is predominantly composed of tamarack.

     In addition, several vulnerable plants  and  animals  of  state
significance are known to occur at the above mentioned sites.  For
further information, please contact our Division of Nature  Preserves.

     The Natural  Heritage Program's data has been checked and  to date,
two additional sites have been reported as locations for vulnerable
plant species of state significance.  These  sites are located  in the NW
1/4 of Sec.  36, T38N, R12E and in the NE 1/4 of Sec. 1, T37N,  R12E.

     As to the two plant species, Platanthera flava and £_.  leucophaea,
that were discussed on pages 74 and 75 of your report, our most recent
information indicates that these are now in the  genus Habenaria.
Before November 10, 1979, these plants were of federal significance and
to date, are of state significance.  According to our data, the only
reported occurrence for Habenaria leucophaea in Steuben  County is from
Graveyard Lake and the habitat for this species  at this  site  has been
destroyed.  The reported occurrence for H. flava is probably  in fact H_.
flava var. herbiola, which is not of federal concern.  To our
knowledge, these species have not been reported to occur within the
project area, although the wetlands described by our Division  of Nature
Preserves are indeed suitable habitat for both Habenaria flava var.
herbiola and H_. leucophaea. but not for H_. flava.

     We appreciate this opportunity to be of service.  If we  can be of
further assistance, please do not hesitage to contact me.
                                      Sincerely,
                                      Jo$jeph|D.  Cloud,  Director
                                      Department of  Natural  Resources
JDC:JRA:bb

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                            COMMENTS ON DRAFT E I S
                                      FOR
                    STtUBEN LAKES REGIONAL WASTE DISTRICT
                                      by
                              RICHARD H. MICK, P. E.

    In view of the unfavorable and unfair comparisons presented in this Draft
EIS, I feel compelled to present the following comments in defense of the
integrity of the program as presented in the Facilities Plan prepared by
Mick, Rowland & Associates, Inc., and in defense of our reputation as
professional engineers.
    First of all allow me to state that as Professional Engineers, we are not
at liberty to recommend the spending of large sums of the public's money for
uncertain, uriproven, experimental programs.  Planners, whatever they are, are
bound by no such ethical professional restraints.  If what they planned does
not work out, there is no professional  license at stake or no law suit for
professional incompetence.
    They state on page iii of their summary that the "recommended action
would provide a satisfactory solution - - -".  They would be more accurate if
they called it a "temporary solution".
    At the outset, let us get one thing understood.  At the time the Facilities
Plan was in preparation, the main thrust of EPA was toward large regional systems
(see news article reprint, page 14, Appendix A-2).  At that time many small
local plants that were perfectly adequate were being abandoned with their
sewage pumped to large regional plants, thus creating large regional systems.
    Large regional systems are the most efficient if smaller local plants arc
inadequate, non-existant, or poorly operated, all of course, dependant upon
the economics of the situation.  At the time the Steuben Lakes Regional Waste
District Facilities Plan was prepared,  the EPA would not have considered any-
thing else.  At any rate, it was a typical situation for a regional system.
                                    -1-

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As its name implies, it is a regional  study area,  and a large region at
that with no small plants to be abandoned.   In fact, the State SPCB and
the EPA increased the area to be studied at the preapplication conference.
So with this said, let's put an end to criticism of our plan - - it was the
only one LPA policy at the time would  permit.
    What is tne cost of this EIS?  There were  five other contracts  awarded
in addition to the main contract to WAPORA. Much  of this work and  its
results are of doubtful value.   For instance,  the  infra-red photography
failed to indicate septic effluent lying on the surface to say nothing  of
what it detected beneath tiie surface.   The  famed Snooper-Sniffer survey
conducted by K-V Associates is  entirely experimental, untested, incomplete
and unproven.   In addition, most of the detailed on-site sutdy data was
provided to WAPORA by Hick, Rowland i  Associates,  Inc., and the Steuben
County Health Department, free  of charge, other information and data was
obtained by telepnone calls to  state agencies  from people who have  little
knowledge of local conditions.   Hone of their  data, to our knowledge, was
gathered, assembled and uvaluated by their  own people working in the area.
What are the costs of the Services of:
    UAPORA
    Environmental Photographic  Interpretation  Center
    Arthur Beard Engineers
    A. T. Kearney Associates
    K-V Associates
    Tri-State University
    Tne cost comparisons In the Draft LIS are  deliberately misrepresented.
They arc assuming that all collector sewers were grant ineligible at the
time our Facilities Plan was submitted which was not the fact.  At  that time
only $1,340,000, or 11%, of our proposed project was determined by  EPA  to
be ineligible.  Almost all of this was subsequently eliminated as unnecessary


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 in a revision  to  our  plan dated May  3, 1977.  What they  fail to mention is
 that eligibility  of sewers was drastically changed by PRI! 78-9 issued March
 3, 1978.   PRH  78-9 practically eliminates any collection system funding,
 but it instituted a change in policy 18 months after our Plan was submitted,
 and five  months after the EIS was started.  This should be clearly understood
 by all  -  - our financial analysis and local costs were correct at the time
 they were submitted,  but are now made to look ridiculous by a policy change
 instituted 18  months  later - - this is grossly unfair to us and makes us
 appear to be incompetent.  This fact should be explained in the EIS final
 draft although I'm sure most people will not read the final draft after
 seeing this unfair cost comparison in this preliminary draft.
     For their  Limited Action Alternative, the EIS (Appendix Table K-2)
 shows  initial  capital cost of 4.894 million and 1980 to 2000 capital cost
 of 4.751  million.  This looks like 9.645 million in total capital cost.  Will
 that 4.751 million required between 1980 and 2000 be funded by EPA or will
 it end  up being paid  by local residents as 0 & M, cost?  If it ends up as
 0  & M  costs, that will make the 0 & M cost 6.54 million which will certainly
 blow their claimed $50 per year per customer to pieces.
     Can you please explain how Table IV-2 shows a project cost of 1.968
 million and Appendix  K-2, page 22 shows a total present project cost of
 4.894 million?  All  of the local  costs of $177,000 are based on the 1.963
 million and riot on the initial  cost of 4.894 million or the total capital
 cost of U.b54 million, half of which could possibly be without Federal &
 State participation  of any kind.
    At the initial meeting held on July 21, 1978 where WAPORA presented the
 preliminary report on the engineering portion of tiiu report, they had no
 Limited Action alternative.   We are convinced that they were in agreement
with us,  that a real  sewage collection and treatment system was needed.
                                     -3-

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They presented Alternatives 1 thru 6, a couple of which were real  possibilities
and the rest were a necessity to develop the required cost effectiveness
analysis.  In fact, their recommendation at that time was so close to ours
that they were almost saying, "you already have the right solution to the
problem".  At this point, EPA, in its determination to deny the application,
told them to go back to the drawing board and come up with an on-site
experimental system.  There is no Facility Plan, only estimates of costs
where the numbers come out right.  The engineering is yet to be done and
will be astronomical in comparison with conventional engineering costs.
Checking the condition of 4000 septic tanks and leach beds will be time
consuming and very costly.  Even the EPA (Alfred Krause) expects engineering
costs for preliminary engineering investigations, before designing can
begin, to exceed 25% of construction costs.  Acquisition of sites for cluster
systems, where indicated, will be very difficult and costly.  The cost of
this Limited Action Alternative is completely unknown and can not be estimated
until a great deal of on-site engineering is accomplished.
    As far as implementing the proposed EIS Alternative is concerned, the
proposed system can not be implemented under existing Indiana law (page  137)
and changing existing laws and regulations seem highly unlikely, or if
possible, a lengthy proposition.
                                    -4-

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                            ADDITIONAL COMMENTS

    It would seem appropriate to mention what the EPA cused delays, administration
and policy changes has done to our small engineering firm financially.  Our
initial engineering cost estimate was $84,141 plus reimbursible out-of-pocket
expenditures of $2,500, based on the existing requirements and the expected
time required to complete.  Because of the many delays and changes in re-
quirements and policy, our costs exceeded-$144,000 by December, 1976.  Let me
emphasize, this is our cost not including overhead and profit.  Our $86,641
contract was cut arbitrarily by EPA to $65,130 total without explanation or
justification.  Of this amount, we have been paid a total  of $60,459, leaving
us short $83,500 of recovering our cost, to say nothing about a reasonable
profit for our efforts.  We are certainly losers of more than $100,000.
    It would be interesting to compare the $60,459 paid to us with the amounts
paid to the six private firms hired by EPA to pick our plan apart which they
did not do very effectively or fairly.

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                                                  January 26.1930
I!r. C«ne Wojcik
Chief, EIS Section
United States Environmental Protection Apency
Region V
230 South Dearborn St.
Chicago, Illinois
Fear Fr. Wojcik:

     I am taking this opportunity to comment on the Environmental Impact

Statement (KIS) for the Steubon Lakes Regional Waste District  (SI^WB),

Steuben County, Indiana.

     The USEFA and WAPORA, Inc., have expended a tremendous amount of

time, 2 years plus, and money in preparing this EIS.  I believe the EF'A

has overlooked some important facts, has marie b(>v& inconsistent assurtjjtioor,

has cone to some inaccurate conclusions and has not taken  into consideration

the expressed preferences of the public into account.

     It would appear that a reassenent or existing regulations would be

in order.

RFPTRPNCP - Page 29-

     ltRValuation of the course of action open to US^FA must start from

     an analysis of existing situation".

     It is questionable as to whether the regulations written  by FPA

     jrovprning clean water did follow an analysis of existing  situations.

     Otherwise the State would not have written the regulations for

     private sewage disposal systems that cannot be met or apparently do

     not need to be met.

     It appears that the NES Study assumption that all Septic  Tank/Soil

     Absorbtion Systems (ST/SAS) within 300' of lake allow septic leachate

     into the lake can not be substainiated , nor can the ST/SAS regulation

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     with regards to minimum distance between lakas and wells.  If




     the EPA had analyized the existing situation the conflicting-



     regulations would not have been written or if you choose to




     ignore these studies and follow the national goal of clean water




     by 1985, the EPA should be recommending the facilities plan



     proposed action.




ICFPRRNCR - Page 22 -




     Can we expect to see some realistic regulations based on the data




     gathered during the preparation of this EIS?




REFERENCE - Appendix J-2 -




     The changes in State Law required to operate your recommended



     "Limited Action Proposal" would be very close to being illegal.




     Statements such to allow authorized agent to check out a "source




     of pollution" or "protect the public health" could allow the




     stretching of the law beyond what existing public utilities




     (electrical-telephone) require to maintain service.




     Tht> ^13 has not addressed 196 acre Industrial Park within the study




     area, nor has it mentioned change in two areas, the Lake Janies



     Country Club and the Pokagon Girls Camp from park or recreation




     to residential in oither present of future land use. (Ref. Figure  11-15



     and Figure 11-16.)   Both of these areas have soils which will not




     support ST/SAS , Ref. II-6.   The Country Club area will also add



     to the point and non-point polution into the drainage ditch which  goes




     into Lake James at Lagoona Park.




REFERENCE - Page 159 -



     I believe the FPA estimate that 50$ of the 3T and 10# of the SAS




     will need to be replaced - is greatly under stated.  I find it

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                                                                  PAGE 3



     hard to believe that if a Septic Tank is too small, too old, not

     functioning properly, etc, that the SAS was installed properly,

     was maintained properly and is functioning properly.

     With the cost of SAS running between $1.50 to $2.00 per square

     foot, I have extimated an additional 1405 residences will require

     SAS at a cost of $1,800,000.00 more dollars.


     In conclusion, I feel the EFA has over estimated its ability to

Up-grade ST/SAS to solve an ever growing and continuing problem which

a centralized sewer would correct much more effectively.
                                           Submitted by.
                                           Charles J. Whitacre
                                           R.R. #2   Box 61-E
                                           Angola, Indiana

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                                                   Frerront,  Indi-?,hr
                                             79 DEO>e3l
Kr. Gene Vvojcik
Chief, EIS SecV.on                 "           WAI L:K  u'^
Chicago, Illinois

Dear sir:

\\e received t'oe environments!  • eport,  "nd ere ^ nx i ^u £ lv r wait ing
Action to relieve the  ?nti;upted  living c end it '.onr tl:~t ni-rny of
11 s find increasingly difficult.   Needles- to nay, v:e believe
sewers v.ill be the ult'r^te  solution.   I guess I v.ould say this
will be rore rr.oney down  t::e  dr.oin,  only to rervire cve?.ter
expenditure in the not too distG/it  future.

The report seeded extensive; "~ovever,  it ree-ed t "..'•. t r.uch of
the dnti was bcsed on  ol'er  loc^l test'ng, ~nd telephone cclls
to v-rious people In this rreo.   I  >:nov funds for such testing
-...o-'ld be " frert herds'." ip for  such  «. sx- 11 corr.^vnity .  Perhaps
it v.ould n.ot be so difficu t if core Fecerrl T"x dollars would
be returned to csn • unities.  Last week °n Article •. ? s  'n the
70rt nayne Sentinel, stating Pres.  Carter would be extern ing
rrore ^id to r^r.il Tress  in relr ti^n '0 severs ete.  This is
an election ye^r.

Any reit^.rk th--t I irr^y  .r^ke 1~  '-'Ot cf -• ; erEon-^1 n-t^re, -nd
all -re the result r,f  trying to cope with - frustrstinr dirty
situation,  I wish to  comment  on  the following:

I.  Adjust life style  to acccnir.odrte existing facilities:

     a. Life style r~o\; h.? ? r-everted  to cc.ndit'.ons q Tiil?r
        to the Dark Ares.  Vfnen the  poor old dredged ruck
        refuses to absorb the  8 Oz.  of \~ter to br;-sh your
        teeth, you have  cut  b^ck  further thrn -ny gadget
         ill do.  On site solutions  see^ re-rote.  Springs
        bubble up here nnd there, ""-id  \e "re not •'bout to
        stop them.  I  -m not talking cbo^t a nicroscopic
        lot, such as "round  Lake  Jarres or Crocked L-he.
        I r^m t? Iking "bout ^ l°rrrer  lot with a aev; expeas ive
        septic svsteir.   These  -~re ti'res --nd ?iti;rt'ons that
        one feels the  need of  » Ralph N'dcr to explore
        and expose.

II. Cost:

     b.  The Clivis I-1'" It rum  Corp. rent out liters tuie on
        their solution' to the  problem.  The cost of this
        -ronstroslty vill r^nge from ^1600 tc 2COO, this
        does not include freight  or installation.

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I cf-n not imagine the cost of rebuilding your home to accommddate
this monstrosity.  I v.ould irr^r-ine th-t by the time one installed
all the gadgets, the $4oo/year sewer would seem like the "best
dollar one ever spent.  I believe Senator Proxmire resertly
awarded The Golden Fleece Award to the Cliyis Kultrum or the
study thereof.  I ?m only spying ve °re already using more
stringent methods than any of these methods vill produce in the
conservation of water

III.  Population:

       a.  Since T--our report went to press the following hes
           occurred.
           1.  Pokegcn Girl's G^mp 3s now Timber Bey.  Four
               home0; ?re constructed.  This vill be s large
               development.  I fear for the wetland? in that
               °.rea.

           2.  Otter Lake Development:  In this crea wetlands
               were disturbrd, and I do not know wh.?t action
               has been taken,  Steuben County mnst have known
               r't the time permission perrlts * ere issued th?t
               Marsh -Hake was polluting these other lnkes, thus
               all the more rep,son to keep the wetlands undisturbed

           3.  There is another development bet: een L?ke Barnes
               ana Crooked Lake,  At the present time there
               are 13 to 14 new homes, it would s'-em this will
               be a large development of expensive water using
               homes,  This sewage will all run dovn.

           4.  North Snow Bay keeps going and going.  wow
               believe me/this is only part of the growth.
               With or without sewers the people will settle
               around ? body of water, be it clean or filthy.
               I feel the energy short?r-e v,ill oily increase
               the multitude of existing problems.  I feel
               a moratorium should l:e c&led on ?11 bulbing
               in this area.  I know "ignorance is no excuse"
               but many poor souls will become Involved in
               this situation.  I know how rruch we hsve spent,
               it could be enough to bankrupt n. family. The
               ccntrib- tion to the study 'n itself was two hundred
               dollars, but we felt the rrea deserved to be s"tzed.

IV.  feter Quality;

       a.  I can sumarize my feelin^p very ouickljr, regardless
           of ^ny report, I do not wsnt V-s water in me or on me.
           Un fortunately now pnd then I mvst go against my better
           Judgment.  Last spring the 1,9ke water h?d a foul
           musty sour odor.  Standing on the pier you could see
           the sediment suspended in the water.

       b.  I would surely question the reliability of reports on
           the number r-na kind of fisH.

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We found a beautiful northern pike fin our beach this  summer,  nnd
ndtme i'ho saw it could detect any injury.   I  sav: another near
Timber Bay.  I just wish they would float to  another  area,  I  havw
dogs who invariably find them, and I certainly  do not feel  they
should eat them, but dogs will be dog§.

One last comment, this November I met p. doctor  in Florida who
was from A'Aic: igsn.  I told him about our  severe problems, the
condition of the lakes, and the unsanitary  living conditions.
His comments did not improve my rr rale.   He said "you need  not
tell me anything about th?t lake area.  I fought the  battle in
the Health Department for years, and never  got  anywhere. Every
lake in that area in itself is a septic field.   I stood by  and
saw the death of beautiful lakes, forget  it if  you think anything
will be done."

I will hope that with your help that living conditions vd.ll
be improved.  So many have invested in this area, and frankly
have already over extended themselves in  trying to sove these
problems they find themselves in.  These  sewage problems
=re too much, indeed impossible for any one person to do on
their own. I hope Steuben County will have  mercy on any fu^uee
souls who desire to settle here.
                                            Sincerely,
      Betty J. Goodoon
      R. R. #4, Box 164
      Fremont, Indiana
      48737

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                      LARRY HDLLMAN
                         2023 MATHIAS
                     FORT WAYNE, INDIANA 4999S tic systems.

     My lot size  is 33'  X 16©'..  My place is  year around

but, has a  very large draw  back.   It has  only  a  35>0 s-allon

steel holding tank.  We  catch  around 90$  of  the  running

water in a  dish nan and  emnty  5t outside.  Our  tub  and

shower  naturally  are not used.  10^ of water usa.se  and

the stool usape are all  that enter  my holding  tank.

     My tank  needs  Dumoed every two weeks with weekend

use only and  oumped weekly  if  used  like on a vacation.

At $[{.0.00 per Dumping it is v«ry expensive plus  beinp

rather  expensive  it is very inconvenient.

     There  *re  other cottage near me that have  other

holding tonks similar to mine.  I  therefore  lam not

alone   with my  septic nroblems.  What are the  options

available to us under PHASS II?':????

     I  am submitting to  the county  foar a  septic  permit.

I am positive it will be refused and rightfully  should

be.  With Tiy  tank being  stbel  and  old it  is  only a  matter

of time until it leaks directly into the  lake as it is

located on  the  lake front.

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                     LARRY HDLLMAN
                        2023 MATHIAS
                     FORT WAYNE, INDIANA
     Am I in consideration as a *orime candidate for

limited action alternatives like  in Section ,? 9,  item # 1

Dao;e -# 1^9 of case study # 14. ??   Or I may be best suited

for Item # 2 section A  pa^e 202. Perhaps a cluster system?

Probably this would be determined in implementation of

Phase TI  correct??

    I therefore volunteer to be an example or test site.

I will co-operate with you in every way possible.  Please

feel free to contact me when ever I may be of assistance.

If necessary my cottage could be  available as a working

headquarters or office for you.

     Enclosed is a letter from Clivus Multrum with another

way to 20.

     T am interested and concerned.  I am also willinf to

assist in any way possible.  Thank You for your time and

information.



                                    Best le-T


                                    -/.     /
                                    H^*y

                                    Larry L. Hoilman

-------
Clivus
Multrum

                                                         r.7  no  ,,
      Hello:                                          \fft~,'
                                                     *''*-' / : . r\ .  ,
                                                              '"'•' I v. i U<^
      Recently the Environmental  Protection Agency drafted  an Environmental
      Impact Statement (EIS) for  the Otter Tail Lake area in Minnesota which
      recommended a Limited Action  Alternative as opposed to sewering the
      area which was recommended  by the County Commissioners facilities plan.
      The main reason for the differing opinion was due to  the high cost of
      sewering and the financial  burden that would be placed on the individual
      homeowner as well as the County.  In addition, EPA has recently announced
      a finding that over 60% of  the 17,000 municipal sewerage plants in
      operation in the U.S. fail  to meet minimum clean discharge standards.

      The Limited Action Alternative which would be funded  by EPA in summary
      would:

          a.  repair and upgrade existing on-site systems

          b.  separate Grey water/Black water along problem high
              groundwater areas  and the installation of either
              air compressor toilets or composting toilets such
              as "Clivus Multrum".

      Since this is considered an innovative and alternative waste treatment
      system, federal funding would be 85%.  The state contributing an additional
      9% would leave only 6% of the installation expense to be borne by the
      local homeowner.  EPA estimates that to be approximately $700 for the
      air compressor type toilet  and only $250 for the composting Clivus Multrum
      toilet.  In addition, the compressor type toilet requires a holding tank
      which involves pumping and  proper disposal (another additional expense).

      Enclosed is some information  about Clivus Multrum and our composting
      toilet.  There are already  over 1,000 installed here  in the U.S. and
      many more in Sweden and other countries.

              Clivus Multrum is  a  much more sensible way to handle
              the treatment of organic wastes.  It does not use our
              water resources nor  does it pollute the environment.
              Please give us your  consideration.

      If you wish additional information, please call or write our office
      in Cambridge, Massachusetts.

      Best regards,


      William Wall
                  14A ELIOT STREET, CAMBRIDGE, MASS. 02138 • (617) 491-5820

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             APPENDIX B

EPA Region V Guidance Site-Specific
Needs Determination and Alternative
   Planning for Unsewered Areas

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                                                                             B
                             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 particu-
      larly 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 indis-
      criminate 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  prima 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 plan 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 recog-
      nizes 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 repre-
      senting a planning risk that requires resolution by the acquisition of
      original data.

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Region V Guidance
Page 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 question-
              naires, 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.

          4.   Flowing effluent pipe detected by remote  infrared photography,
              site visits, knowledge of local officials, or  results of  mailed
              questionnaires.

          5.   Contamination  of water supply wells (groundwater)  can be  demon-
              strated by sampling and analyses for whiteners, chlorides,
              nitrates, fecal coliform bacteria, or other indicators, and a
              finding of their presence in concentrations which significantly
              exceed background levels in groundwaters  of the area or primary
              drinking water quality standards.  Demonstration 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 limita-
          tions 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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                                                                             B
Region V Guidance
Page 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 perco-
              lation rate.

          6.   Rapidly permeable soil  with less than 0.1  minutes/inch  percola-
              tion rate.  Soil permeability will  be assessed by  evaluting
              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-site investi-
              gation.

          7.   While holding tanks, in certain cases, can be a  cost-effective
              alternative,  for purposes of site-specific needs determination,
              a residence equipped for 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  prac-
              tices or current sanitary codes may be documented  by  owners,
              installers, or local permitting officials. This category would
              include cesspools, inadequately sized system  components (the
              proverbial "55 gallon drum" septic  tank),  and systems which
              feature direct discharge of septic  tank effluent to surface water.

          9.   On-site systems:  (a) incorporating components,  (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 I will consist of  a  review of existing or
      easily obtainable data.  Phase  II will consist of  on-site  investigation
      and representative 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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B
       Region V Guidance
       Page 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
                     on-site system and its performance

                 2.   Review of  soils maps

                 3.   Review of  local permit records

                 4.   Lot evaluations 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:

                 1.   Obvious-problem
                 2.   No-problem
                 3.   Inconlusive.

                 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  avail-
                 able 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

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Region V Guidance
Page 5

          upon the interred 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 there 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 infor-
          mation 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,  tfi. 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-Course Meeting facilities plan review is an appropriate time
          for the presentation and discussion of 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 used area.  In this case,
              a preliminary cost estimate for conventional collection and
              treatment should be compared to that for the innovative/alterna-
              tive treatment solution.  If cost estimates and technical analysis
              indicate that the use of alternative technology is not  cost-
              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

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B
       Region V Guidance
       Page 6
                     justified,  where a high concentration of  dwellings  occur  in a
                     municipality,  and where on-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  in accordance with PRM 78-0 and  PRM 79-8.

                 2.   The number  of  lots to be investigated during the on-site  evalua-
                     tion 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 sub-
                     mitted 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  wastewater  treat-
                     ment.  Should  need be demonstrated for a  given residence,
                     sufficient  information should be acquired to determine potential
                     treatment alternatives.   (For example, if a residence is  deter-
                     mined to need  treatment facilities on the basis of  an illegal
                     discharge of septic tank effluent, additional  information will
                     be required to determine if any limitations to on-site treatment
                     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 representa-
                 tive 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 minutes/inch)  would be  con-
                 sidered 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:

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                                                                            B
Region V Guidance
Page 7


          1.  Delineate areas that exhibit indirect evidence and/or inconclu-
              sive 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-site
              sewage treatment or the indirect evidence of need and correlate
              with actual occurrence of wastewater treatment deficiencies.
              The number of lots, 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 depth, 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 condi-
              tion of existing on-site systems.  Sampling may be random or
              stratified according to the requriements 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 evaluted and utilized as
              pollution indicators include,  but are not limited to:  chlorides,
              nitrates, phosphate, fecal coliform, surfactants, whiteners,  and
              other synthetic organics 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, residence should
      be categorized as follows:

      A.  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.

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Region V Guidance
Page 8


      B.  Residences not having adequate treatment facilities.

          1.  Capable of on-site upgrading of septic tank and filter field
              (standard system).

          2.  Capable of on-site upgrading with non-standard on-site treatment.

          3.  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 limitation of the discrete area.

      Standard system ypgrading is defined as expansion of an existing filter
      field, construction of a filter field, repair or replacement of defec-
      tive 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 ground-
      water and slow percolation preclude standard systems.  Off-site treat-
      ment 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 of 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
      should assume 100% replacement.

      When a system 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 infor-
      mation acquired during Phase I and Phase II, including any representative

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                                                                             TO
Region V Guidance
Page 9


      sampling.  Only the limited amount of on-site investigation,  normally
      less than 30% of the total lots that exhibit inconclusive need and/or
      indirect evidence of need, should be conducted in the Phase 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 s'elect 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 estab-
      lishment 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 authori-
      zation to proceed with construction procurement is granted under a
      Step 2+3 grant.

VI.   Public participation

      The following comments are 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 owners of residences within
          unsewered areas in the planning area and other interested and
          affected parties.

          The requirement for consulting with the public set forth in 40 CFR.
          35.917-5(b)(5) will be considered satisfied if questionnaires are
          submitted by individuals on the "mailing list."

      B.  The public meeting required by 40 CFR 35.917-5(b)(6) 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 determina-
          tion 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 should be
          scheduled at the end of facilities planning.

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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON O C  20460
                                                                OFFICE OF WATER
                                                             AND WAIITE MANAGEMENT
MEMORANDUM
SUBJECT:  Access and Control for* On-Site System Upgrading

F10M:     William A. Whittington, Acting Director      ,,,                  '"""
          Facility Requirements Division (WH-595) ,,'_(t(> ••«.'•• '
TO:       Charlea Sutfin,
          Water Division, Region V
    Thank you fcr your inquiry of June  16, 1980, regarding  the
possibility of grant applicants meeting the requirement  for  "access  and
control of on-site wastewater treatment in compliance with  PRM  79-8,
HO CFH 35.9l3-l(h) and 40 CFH 35.9 5'5-3(b)( 3) ,  'though county or  municipal
ordinance, using public health and police  powers to allow access,
inspection end the right to require upgrading  of on-site systems.
    Ki A regulations requiring the Regional Administrator  to  determine
tnat  Interests in the land are sufficient to  assure  undisturbed  us« and
poasasaion for the purpose of construction and operation  for  the life  of
the project have been satisfied by  the use of perpetual or
life-of-the-projeot easements or other binding oonvenanla running with
trie land.

    In our opinion, an ordinance whioh would  assure  the granteo  a
perpetual (or life-of-project) and  assignable right  of unlimited aooess
to each individual system at ell reasonable times  for such purposes as
inspection, monitoring, construction, maintenance, operation,
rehabilitation and replacement could  be  used  to  .satisfy EPA  funding
requirements for "complete access to  and control of  wastewater  tr«a^»*nt  .
works on private property. . .".  Of  course th&  use  of arty such  ortftin*no4j
srirmld be approved on a "by project"  basis.                        - ;

    We would appreciate receiving samples of  arty ordinances  you  may
develop as this may prove to be a very eft'octive means fcr providing
required access for these on-site systems.
                                                                               >
                                                                       o~    O

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          APPENDIX C

EPA Memo on Access and Control
 for On-Site System Upgrading

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                 APPENDIX D

Septic Leachate and Groundwater Flow Survey -
          Steuben Lakes, Indiana
                August 1979

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                           1.0  INTRODUCTION






     Previous investigations of the Steuben Lake study area on-site septic



systems have revealed little degradation of surface or groundwaters in the



project area (EPA, 1979).  Groundwater throughout the region is of the cal-



cium magnesium bicarbonate type, very hard with a high iron content which



becomes solubilized under reducing conditions.  This chemical composition




of the natural waters promotes rapid precipitation of soluble phosphorus



compounds.



     A previous late fall septic leachate survey was conducted along the




shorelines of Charles Lake, Little Otter Lake, Big Otter Lake, Snow Lake,



Lake James, Crooked Lake and Lake Gage of the Steuben Lakes region (KVA, 1979),



Only 65 septic leachate groundwater plumes and four stream source plumes




were found entering the lakes.  The total of 69 plumes was a very small



number of plumes in comparison with the estimated 3,494 lakeshore residences



lying within the proposed sewer service area (EPA, 1979).  The frequency of



the plumes was directly related to the soils classification (Figure 1).



The majority of the plumes, 41 of 69, was associated with moderately rapid



and rapidly permeable soils or occurred in cut and fill canal regions of



uncertain soil type (Figure 2).




     The most substantive inputs of phosphorus related to wastewater have



been identified with a large plume of bog-like leachate issuing from Marsh




Lake through Little Otter Lake, Big Otter Lake, Snow Lake, and finally dissi-




pating in the upper basin of James Lake (KVA, 1979).  The path of the stream



source plume corresponded to a noticeably high level of total phosphorus



ranging from 0.096 mg/l at the entrance of Little Otter Lake to 0.011 at the




discharge from James Lake to Jimmerson Lake (Figure 3).  The trophic analysis

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i^ i
4-> rH
,0
T3 CO
•H CO
ae
CO (H
« CO
(^
^5
rH >j
COrH
43 -ci
OS-H
^ a
CO CO
•d«
0
s





CO
_j
srmeab]
Ul
rt
fM
w^
Pi
_j
i i
(4
o
tS
m

CO
0) 0)
j-j r.
**-» H
4J CO
C CO
i-t CD
1^4
CO CO
0) i-q
cx
>i C
43 0)
ft
•H 3
•H CO
0 43
CO CO

•
t-i
CO
f-4
3
bfl

-------

-------
D
                                                                                                                                                                     oo
                                                                                                                                                                    1
                                                                                                                                                                     o
                                                                                                                                                                     01
                                                                                                                                                                    a
                                                                                                                                                                     v


                                                                                                                                                                     M
                                                                                                                                                                     3

                                                                                                                                                                    co
                                                                                                                                                                     
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                                                                                 D
of the lakes, based upon Dillon's model (1975) projected Marsh Lake, Big




Otter Tail Lake, Snow Lake, and James Lake as eutrophic in status with signifi-




cant input from the single stream source (EPA, 1979).



     Some public comments were received that the late fall survey may not




have been conducted during the period of year most conducive to detecting




failures*  Summer loadings from seasonal dwellings usually peak during the



late August period and traditional overflow failures may be more common at




this time.  Ironically, past studies of septic leachate plume emergence have




found the highest discharge frequency during late fall or early winter,




corresponding to the delay of travel of peak summer loadings through soil




before shoreline emergence.



     To provide a comparison to the late fall study, during August 1979




K-V Associates, Inc. conducted a septic leachate survey along the shorelines




of James Lake, Crooked Lake, and Jimmerson Lake of the Steuben Lakes region.




Continuous leachate transects were performed on these three lakes along with




pertinent groundwater flow measurements to establish the general inflow pattern



of these three lakes as well as Lake Gage, Snow Lake, Little and Big Otter



Lake.  The August period represents the time of heaviest recreational usage




of the local water resources*  More than 767. of the total on-lake summer



population around these lakes is seasonal (16,681 total residents with 12,731




seasonal units in 1976) (Wapora 1979).  The purpose of the study was to com-




pare the frequency of discharges during summer to that found earlier during




December.

-------
D
             While the late fall - early winter period is usually an optimal



        period for observing the seepage of slowly moving groundwater leachate




        discharges resulting from midsummer on-site septic system loadings, temp-




        orary traces of summer overflow failures might be obscured by such time.




        Previous bacteriological sampling of the lake shorelines during December




        revealed very few locations with fecal contamination shown by the presence




        of fecal coliforms.  Only three locations exceeded the limit of 200




        fecal coliform organisms/100 ml, although elevated concentrations (>100



        organisms/100 ml) were found in canals on the eastern shore of Crooked




        Lake and on the stream linking Crooked Lake and Lake Gage.

-------
                                                                               D


                                2.0  METHODOLOGY


      K-V Associates,  Inc.  equipment employed  in this  survey included a

 portable battery-powered  septic leachate  detector  (ENDECO Type 2100),

 a portable well  point sampler,  and the  K-V  Associates Model 10 Dowser™

 groundwater  flow meter.  The  general procedure  has been  described  pre-

 viously  (Kerfoot and  Skinner,  1979;  KVA,  1979).  A dual  channel system

 recorded conductivity and  UV   fluorescence  of background and discharges

 along the shallow  lake perimeters.  The septic  leachate  detector is  cali-

 brated against stepwise increases  of wastewater  effluent from a local

 sewage treatment plant, added  to the local  lake  water.

      The intake  probe of the  leachate detector  is placed in the lake

 water along  the  shoreline  in a  vacuuming-like manner  as  the boat progresses.

 The common procedure  is to scan the  shoreline bottom  in  depths from  1 to

 3  feet (I meter  or  less) and draw  in shallow groundwater inflow through
                                                        «,
 the lake bottom.  Even though  septic installations some  distance back from

 the shore may create  discharges in water depths  greater  than 3 feet  (I meter),

 usually  some seepage  to the surface  is  apparent.  By  driving the groundwater

 sampler  beneath  the shallow bottom and  probing vertically,  the operator

 can locate the core of the deeper  plume sample without having  to make

 time-consuming transects out from  shore through deeper waters.   Both  ground

 and surface water samples collected  from plume locations were  filtered  to  .40

urn and acidified  to pH 2.   Samples  were  placed in chilled coolers and shipped

 to WAPORA, Inc. in  Cincinnati,  Ohio for  nutrient analysis.  The Indiana State

Board  of  Health in  Indianapolis provided fecal coliform  bacteria analysis.

-------
 2.1  Types of Plumes




 2.1.1  Groundwatcr Plumes




      Three different types  of groundwater-related wastewater plumes are




 commonly encountered during a septic  leachate  survey:  I) erupting plumes,




 2)  dormant plumes, and 3) stream source  plumes.  As  the soil becomes




 saturated with dissolved  solids  and organics during  the  aging  process of




 a  leaching on-lot septic  system,  a breakthrough of organics occurs first,




 followed by inorganic penetration (principally chlorides, sodium, and




 other salts).  The active emerging of  the combined organic and inorganic




 residues into the shoreline lake  water describes an  erupting plume.  In




 seasonal dwellings where  wastewater loads vary in time, a plume may be




 apparent during late summer when  shoreline cottages  sustain heavy use,




 but retreat during winter during  low flow conditions.  Residual organics




 from the wastewater often still remain attached to soil particles in




 the  vicinity of the  previous  erupting plume, slowly  releasing into the




 shoreline waters.   This dormant plume indicates a previous breakthrough,




 but  sufficient treatment  of the plume exists under current conditions




 so  that  no inorganic discharge is apparent.  Stream  source plumes refer




 to either groundwater teachings or near-stream septic leaching fields




 which enter into  streams  which then empty into the lake.




 2.1.2  Runoff Plumes




      Traditional  failures of  septic systems occur in tight soil conditions




when  the  rate  of  inflow into  the unit is greater than the soil percolation




can accomodate.  Often leakage occurs around the septic tank or leaching




unit covers, creating standing pools  of poorly-treated  effluent.   If  sufficient




drainage is present,  the effluent may flow laterally  across  the  surface into

-------
                                                                                D
nearby waterways.  In addition, rainfall or snow melt may also create an




excess of surface water which can wash the standing effluent into water




courses.  In either case, the poorly-treated effluent frequently contains




elevated fecal coliform bacteria, indicative of the presence of pathogenic




bacteria and, if sufficiently high, must be considered a threat to public




health.






                           3.0  COMPARATIVE RESULTS




     This survey was conducted in an attempt to determine if heavy summer




loading would increase the frequency of discharge plumes previously




observed during an early winter survey in December, 1978 (K-V Associates,




1979).  The following is a lake-by-lake comparison of effluent plumes,




nutrient loading, and bacterial content of the summer survey versus the




winter septic leachate survey.  See Tables 1  and  2     for nutrient anal-




yses, Table 3  for bacterial analyses and Figured  for plume locations and




sample sites of the August, 1979 leachate survey.




3.1  Crooked Lake




     Nutrient analyses of Crooked Lake water samples taken during the




summer and winter months showed characteristics very similar to previous




analyses.  Plumes were found concentrated in canal or stream areas.  Total




phosphorus concentrations appeared to be slightly lower during the summer




survey.  Levels of phosphorus were generally less than .01 mg/l during




August and were above this in most cases in December.  Nitrates also proved




to be equivalent between the two seasons, with the results averaging around




.15 mg/l.

-------
                                                  10
 Table 1
-.nalysis of Surface Water (S) and Groundwater (C) Samples Taken '.round the Periphery of
Crooked Lake, Indiana, August 1979.

Sample
Numbers 3k
Crooked
IS
23
2G
3S
3G
43
-G
53
5G
63
6G
73
7C
Jimmerson L.
33
93
9G
10S
10G
113
11G
123
12G
133
13G
143
16G

TDS
g/Ctr ppm

363
324
717
327
744
436
529
444
1089
421
570
334
-.59
a«>
244
263
573
260
378
267
325
251
694
269
359
263
363
Ortho PO
as P
ppm

<.Q1
^. 01
.50
< « 01
«< , 01
< *Q1
.01
<.01
<.01
.07
•^.Ol
i.Ol
i.Ol

•=.01
i.Ol
.02
-=.01
i.Ol
-C.Ol
-..01
-..01
i.Ol
-..01
<-,01
•'-.oi
< .01

4 Total P
_ PP°

«.01
«. .01
.52
< .01
-..01
•c.Ol
.02
< .01
-= .01
.08
i .01
-= .01
.01

•* .01
* .01
.03
-.01
-. .01
-..01
i .01
— .01
- .01
— .01
-..01
-:.01
.01

MO.-N
pom

-=-.01
i.Ol
i.Ol
1.01
<-.01
.01
.01
.02
*.01
1.01
^.01
i.Ol
i-.Ol

--.01
-..01
1.01
i.Ol
i.Ol
-.01
i.Ol
i.Ol
i.Ol
i.Ol
i.Ol
i.Ol
•^-.01

NOj-N
Ppm

.01
.02
.01
.02
.05
.14
.07
.67
.01
.39
.04
.02
.02

.02
.01
.07
.01
< .01
.01
< .01
.01
.01
<.01
.30
.01
.02

ppm

-.03
-.03
2.08
i.03
1.70
.04
.98
.08
.18
i.03
1.73
'"•.03
2.75

-.03
1.03
22.2
< .03
1.75
•=-.03
* .03
*= .03
10.8
i .03
.76
<-.03
1.90
Organic
N

.57
.68
10.4
.72
1.90
.96
60.4
.18
1.07
.37
1.82
.68
24.4

.50
.74
10.3
.68
2.95
.62
.36
.60
1.20
.63
.49
.74
3.60

Cl-

76
76
133
76
183
95
39
72
336
38
66
77
75

30
30
6
30
12
31
2
32
22
30
3
23
9

Na

43
43
175
41
59
60
65
43
165
50
31
44
37

13
16
5
17
7
17
5
17
12
17
i
15
5

Fe
ppm

110
90
17,500
60
5,500
750
11,700
T50
3,500
630
10,400
500
122,000

630
130
16,500
90
5,400
190
3,600
30
3,900
50
1,400
90
33,000

Comments

Center basin 1
Gold Coast

House >>268

?ast end canal, north fort

East end canal, south

4-H Park Stream

Lagoon - basin 2


Center
Sbhart's

West shore

3 toner' s

ynrch by 300 «

Canal - northeast bay

"arsh south west bav

 Janes  Lake
 163
 173
 17G
 133
 18G
 19S
 19G
 20S
 20G
 213
 21C
 223

 133
243
24G
253
25G
263
;&c
273
27C
283

303
3CC
262
270
273
555
257
273
254
408
243
353
266
289
261
463
257
304
648
259
453
328
700
259
286
286
257
264
412
-.01
* .01
*.01
•=..01
-=..01
"-.oi
t;°l
•1.01
•*-. 01
•=..01
•*-.01
« .01
--.01
•=•.01
-=.01
.02
< .01
--.01
<^.01
i.Ol
i.Ol
i-.Ol
i.Ol
* .01
•^-.oi
"--.01
•=.01
"^.01
"SOI
i.Ol
i.Ol
i- .01
-=..01
i.Ol
—-.01
i-.Cl
•-.01
-.01
.01
•=-.01
i- .01
.04
•'•.Ol
•^-.01
- .01
.02
* .01
.01
i.Ol
.01
- .01
•=-.01
-.01
•c- .01
-=.01
<• .01
<.01
1..01
•=-.01
—_01
•=..01
i.Ol
•=^.01
•=..01
•=•.01
.01
.04
.01
.01
.01
.01
.01
.01
.01
.01
.01
.03
.01
.01
.02
.03
.02
.01
.01
1..01
.02
i.Ol
.01
.01
.02
.02
i.Ol
.50
.01
.01
.01
i.Ol
.01
.01
.01
.01
.03
.41
i.03
•c. .03
i.03
26.0
1.03
.03
.37
1.33
i.03
-=-.03
.14
<.03
14.0
^.'.03
.05
30.0
".03
2.30
•< .03
62.0
-L.03
.05
< .03
<.03
*.03
i.03
.56
1.43
.50
2.00
.70
3.30
1.60
18.3
1.38
3.60
.60
15.4
.87
10.5
.37
1.35
17.5
.30
5.00
.38
68.5
1.15
3.45
1.32
1.34
1.37
1.2S
32
61
31
17
31
27
52
23
56
3
30
3
28
26
30
30
15
31
45
49
26
57
49
56
63
67
73
18
IS
17
10
17
17
17
7
13
4
17
13
15
15
13
17
14
17
26
29
18
19
17
22
18
19
6



10,

2,
14,

10,

2,
13,

1,
194,

11,

37,

3,




90
90
160
600
190
000
320
200
270
400
160
100
130
300
130
600
000
500
500
600
300
90
500
130
90
470
300
I'iddle iasin
upper basin
Fiddle basin "2726

"iddle basin east shore

Upper basin east shore
Upper basin west shore

Sorin* ?t. Om«l

Lake James Varina
Pa tawa tamee Can* I
3evond bridse Lagoon 3av

\,r,T 3fj s«nrt "»"c'n

Canal before Potawataraee

I'poer basin - north «hore

Snow Lake inlet
Pokaeon View
Uoper basin - west shore


-------
                                      11
                                                                                    D
              Table 2.  STEUBEN LAKES:  Distribution of Leachate Plumes

LAKE
TYPES OF PLUMES
Erupting
1978 1979
Little Otter
Big Otter
Snow
James
Crooked (1st & 2nd Basins)
Gage
Jimmerson
Crooked (3rd Basin)
TOTAL
—
2
5
18
16
I
ns
ns
42
ns
ns
ns
17 (7)
3 (2)
3 (2)
4
_»
24 (9)
Passive
1978
—
--
2
5
3
13
ns
ns
23
1979
ns
ns
ns
7 (I)
I
ns
5
3
16 (I)
Stream
1978
I
—
--
I
I
I
ns
ns
4
Source
1979
ns
ns
ns
I
I
ns
--
__
2




(D
(D



(2)
() = Repeats of Previous Locations



ns = not sampled

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                                         12
D
      Table "* .   Bacterial count of shoreline water samples of Crooked and
               Jimmerson Lakes, Steuben County, Angola, Indiana.  August,  1979,
           Lake
     Jimmerson
Station
Fecal Coliform
  No/100 ml
              Location
Crooked Lake 81
B2
B3
B4
B5
B6
B7
B8
B9
BIO
270
430
50
80
<10
1428
East end canal, inlet stream
East end canal, north fork
Sunset Inn
Second basin lagoon
Oak Grove Resort
?r'168 Moser








3rd basin, end of road 425 west
3rd basin, lot ->2814, marshy
canal
  Bll
  B12
  B13
  B14
  B15
  B16
  B17
  B18
  B19
  B20
     270
     <10
       0
     «10
      10
     -rlO
     100
                                    -ilO
                                     70
Bledsoe Trailer Park, vA-18
East corner, near lot #8485
North end channel
Trailer Park north
Northwest outlet of lake
Oak Shores Rd., opposite farmlands
Speculation house in development tract
Tanglewood subdivision,  Bobays
Hilltop Trailer Park, south cove
Marshy canal, east end of south shore

-------
                                      13
         ' UJ
or
UJ
                                                                                                 D
                                                                                                CO
                                                                                                •<

                                                                                                I

                                                                                                CO
                                                                                                w
                                                                                                (d
                                                                                                oa
                                                                                                CO

                                                                                                z
                                                                                                o

                                                                                                CO

                                                                                                o
                                                                                                1-4
                                                                                                H


                                                                                                §
                                                                                                _1
                                                                                               z:

                                                                                               _i
                                                                                               a.

                                                                                                i
                                                                                                a
                                                                             o—

-------
                                         14
D
           Most surface water samples were found to contain around .03 mg/l of


      ammonia-nitrogen during the summer survey.  In winter conditions, ammonia-


      nitrogen levels of water samples ranged between .1 and .2 mg/l.   Ground-


      water samples were found to contain higher levels of ammonia-nitrogen (NH^-N)


      during the summer, falling within the range of I - 3 mg/l.


           Levels of fecal coliform bacteria  in surface waters  were  shown  to  be


      slightly higher in August,  1979.  In December,  only one of the  10 samples  was


      higher  than  the State's  maximum  safe  level  of  200 organisms/100 ml of water.


      In  the  August sampling period,  two  sites  (the  4-H Park Stream and the


      Canal in Steuben County  Park) were  found  with  greater  than 200 organisms/

      100 ml  water  and the  remaining eight  samples averaged about  36 cells/100 ml


      water.


      3.2 Jirnmerson Lake


           As was the case with Crooked Lake, Jimmerson Lake exhibited  almost no


      noticeable difference in the  nutrient content  of most samples  taken  at  the


      two times of the year.   The levels  of total phosphorus (TP)  and  ammonia-


      nitrogen (NH^-N) in the  surface  waters  were very similar.   Total  phosphorus


      averaged .01 mg/l for both time  periods while  mean  values  of about .03  and


      .05 mg/l  were shown for  ammonia-nitrogen  during  the  summer and winter collec-


      tions respectively.   However, groundwater levels of  ammonia-nitrogen were


      noticeably higher during the  summer survey. The highest  concentration  found


      in  the  winter survey was 1.49 mg/l  and  all  other samples  were  below  .1  mg/l.


      During  the  summer,  507, of  the samples taken were above UO mg/l with  a  high


      level of 22.2 mg/l at a  nominal  background  site  of  muck bottom along  the north


      shore.   The  high groundwater  concentrations of ammonia-nitrogen  apparently


      did not correlate with plume  locations.   Nitrate-nitrogen concentrations


      increased during winter  with  .01 mg/l or  less  during the  summer,  and  a  mean


      concentration of .048 mg/l  during the winter survey.

-------
                                  15
     Ten locations were sampled for bacterial content during summer, com-




pared  to nine  the previous December survey.  Bacteria levels were 10 or




fewer  fecal coliform organisms/100 ml water at both times of the year with




the  summertime exceptions of 270 near Bledsoe Trailer Park and 100 organisms/



100  ml water in a marshy canal near a development on the west shore.




3.3  Lake James




     Again, as in the other two lakes, locations and frequency of plumes




closely coincide, and only minor or occasional variations could be observed




for  each time  of the year.  Only a slight reduction in total phosphorus




could  be seen  from the summer surface samples when consistent concentrations




of less than .01 mg/l were observed compared to levels averaging just over




.01 mg/l in winter.  Average levels of ammonia were observed to be about




2 mg/l in winter and 10 mg/l in summer for groundwater plume samples taken




from canals, harbors, and sheltered or semi-enclosed small bays, particularly




the Lagoona Bay, Lake James Marina and Red Sand Beach areas.  The higher



levels found during the August survey included one sample from a canal




below Pokagon  State Park on the northeast shore (lower basin) which registered



as high as 62 mg/l.  Nitrate concentrations correlated very closely between




the  two seasons.  Levels of fecal coliform bacteria were not analyzed on




Lake James due to a delay in sample transit to the laboratory.

-------
                                         16
D

                        4.0  GROUNDWATER FLOW DETERMINATIONS

           The field team made measurements at 76 sites around seven lakes to
      determine  the rate and direction of shallow groundwater flow at the near-
      shore water  table surface.  Lakes  included in this survey were Gage, Big
      and Little Otter, Snow, Crooked, Jitnmerson and James.  Plow vectors pointed
      into the lake for most north and eastern shores, indicating a net westward
      procession.  Tight soils, notably  clay and dense mucks around the Otters
      and Snow Lake preempted any discernable readings at several locations*
      Because of unfavorable terrain considerations, we could not take data on
      the many canal embankments.  Flows were usually less than 10 feet per day
      (see FigureS and Table 4).

-------
17
                                                                                          D
                                                                                            4-1
                                                                                        •C   U)
                                                                                        4)   3
                                                                                        4J   tO
                                                                                        O   3
                                                                                        O  •<
                                                                                        i— I
                                                                                        
                                                                                         0)   01
                                                                                         (0
                                                                                        •o
                                                                                         G   C
                                                                                         3   4)
                                                                                         o  ^a
                                                                                         »-i   3
                                                                                        o   
-------
                                   18
Table 4.  Observed rates of groundwater flow
Station
   Location
  Plow
Direction
Flow Rate FPD
Lake Gage
   1           #227
   2           #222 Lake Gage Dr.
   3           #97
   4           #144
   21          #236 High Vu Camp entr.
   22          #194 Lake Gage Rd.
   23          #169 Keirns (Lake Gage Rd.)

Little Otter Lake
   65          Boat Rental site
   79          Opposite Sta 78 (Big Otter)

Big Otter Lake
   66          Cranston Development
   67          Lot 12 + 13
   77          Cranston Development
   78          Near Little Otter (S. shore'
                             330° NW
                              90° E
                             270° W
                             335° N
                             265° W
                             250° W
                              50° NE
                             315° NW
                   9
                   5
                  10
                   9
                   4
                   5
                   4
                             2-4' deep dry holes (no water)
Snow Lake
   68
   69
   70
   71
   72
   73
   74
   75
   76

Crooked Lake
   5
   6
   7
   8
   9
   10
   11
   12
   13
   14
   15
   16
   17
   18
   19
#250
#303 Roebels
#376
#438 Sprague Addition
#495 Sprague Addition
#510 Next to canal
#126 Morley Addition
Deer Island
Pokagon Estates
#308
#1008
First house on canal
#906
#740
#830 Doty
Opposite Sunset Inn
#810
Public Beach
#142
#220
#326 Laubers
#1919 Gremaux
3rd basin east side
#2430
225° SW
60° NE
225° SW
hard rock fill -
300° NW
340° N
215° SW
325° NW
275° W
295° w
No flow through
185° S
dry holes to 3*
245° W
50° NE
270° W
180° S
235° SW
235° SW
245° W
330° NW
2850 w
305° NW
225° SW
255<> W
230° SW
35° NE
No flow
1
5
6
could not dig down
2
6
3
4
3
5
muck
4
no flow
7
3
5
5
5
5
7
6
2
4
6
7
4
10
no water readings

-------
                                  19
Table * *  (Continued)
                                                                               D

Station
Crooked Lake
20
51
52
57, 58
59
60, 61
62, 63
64
Jimmerson Lake
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
80
Lake James
39
40
41
42
43
44
45
46
47
48
49
50
53
54
55
56

Location

#2821
#1122 Burkett (site A)
Ml 22 Burkett (site A)
#168 Moser (site B)
#168 Moser (site B)
Oak Grove (site C)
#894 (site D)
Garner (site E)

Trailer park
North end of trailer pk.
#8306 County 300 W
flow
Direction

210° S
280° W
250° W
300° W
270° W
355° N
255° W
265° W

no f low
270° W
250° W
Point between canal N. shore235° SW
#6804
North shore W. end
North shore W. end
North shore S. of Crooked
#4521
West shore
West shore
#3030 Targlewood Seibert
Southwest shore
Near a point
#1043
#144 S. end of Crooked

#2828
N. basin-SE shore
#2348 Spring Pt.
#1866 Potawatamee Acres
S. basin- South end
#1306 Savles Bay
#1052 Nelson
#738 Glen Eden
#39 W - Elen Eyer
Po tawa tame e I nn
Pokagon Beach
#3152
#4064 Pokagon View
#3490
Phillips Bay
N. basin-North End
no water
175> s
-
_
265° W
no water
no water
130° SE
290° W
335° NW
2500 u
390° N

300° w
270° E
110° £
275° w
250° w
210° SW
315° NW
195° S
320° NW
265° w
35° NE
dry hole
320° NW
295s W
285° W
295° W
                                                          Flow Rate FPD
                                                             8
                                                             4
                                                             1
                                                             4
                                                             2
                                                             3
                                                             3
                                                             5
                                                             no water measured
                                                             4
                                                             9
                                                             9

                                                            20
                                                             8
                                                             2
                                                             2
                                                             3
                                                             9
                                                              3
                                                              7
                                                              11
                                                              5
                                                              3
                                                              7
                                                              5
                                                              3
                                                              4
                                                              3
                                                              3
                                                              no
                                                              3
                                                              11
                                                              3
                                                              5
water

-------
                                         20
D

                                5.0  DISCUSSION

           Two  types of possible problems are common to on-site systems:  hydraulic
      failures and qualitative failures.  The categories can be defined thusly:
           1.  A hydraulic failure of the leaching system refers to a system
           backup causing poorly-treated sewage  to overflow on the surface  of the
           ground, a failure to be expected  of almost all on-site  systems as a func-
           tion of time and loading rate.
           2.  A qualitative failure refers  to a  failure of the leaching system
           to adequately oxidize wastewater,kill  microorganisms and precipitate
           phosphates,  a failure inherent with improper design with respect to
           groundwater.  The term "qualitative"  implies that the system has
           failed to meet the degree of  treatment expected from a  properly-
           operating system.  This  is reflected  by poor water quality in leachate
           produced by  the recharged treated  water.
           Hydraulic failure of systems  near  lakeshores areas can  be detected by
      rivulets of stream source plumes which  enter shallow water.   Bacterial analy-
      sis  of  the  direct inflow also  exhibits  high bacterial cell counts of  indicator
      organisms.   Qualitative failures can be detected  in two ways.   In uncon-
      solidated  deposits,  most plumes from nearshore  septic systems  will enter the
      lake through the  lakeshore  bottom  into  the  shallow periphery,  from 0  to 3
      feet (1  meter or  less)  deep.   Rather than scanning the  entire  bottom  area,
      one  conducts  a survey    along  a line parallel to  the  shoreline in about 1
      foot depth  of water.   Even  though  the center of a  plume may  exit  at greater
      depths,  usually a  portion of  the dispersing  leachate  will  create  a signal
      which is  then explored  by probing  vertically with a wellpoint  sampler.
      When the core of  the  leachate  plume from the septic  system is  located,  a
      sample is withdrawn  to  evaluate the quality  of  the water  relative  to  ex-
      pected performance.

-------
                                    21
                                                                               r

     In consolidated and stratified deposits, the possibility exists that a

septic system may leach into a highly porous strata which is slanted.  Such

a formation may channel poorly treated wastewater into greater depths of a

lake through an interrupted confined aquifer, while no plumes of wastewater

would be apparent along the lake shoreline.  The Steuben Lakes study area

soils are generally loamy (composed of clay, silt and sand) and highly

variable in composition, ranging from poorly-drained silty and clayey loams

to the well-drained loamy sands and excessively well-drained gravely sandy

loams (EPA, 1979).  The earlier winter survey (December 1978) and summer

(August 1979) surveys conducted along the Steuben Lakes shorelines found

few failures of on-site septic systems, the most noticeable number in James

and Crooked Lakes.  Most identified failures were restricted to cut and fill

canal regions, highly porous soils, or stream inflows.

     In high bluff regions east of Lake James, a large number of traditional

hydraulic failures have been identified by local health officials (Figure 6).

The tight soils of the area may predispose septic installations to hydraulic

failures.  However, a high frequency of hydraulic failures can exist without

any impact on the lake water as long as the liquid does not flow into the

lake shore.

     The clayey soil compositions of the area limit the vertical and lateral

flow of soil water.  Most shoreline regions exhibited low groundwater inflow

conditions (less than 10 feet per day lateral flow).  Where clay deposits, the

bedded material restricts flow through the porous deposits, even though the

sand and gravel deposits may hold considerable trapped water.  However, if an

extensive lateral deposit of porous material underlies the poorly permeable

soils, and the deposits extends into the lake bottom, the possibility of trans-

port of leachate exists.

-------
22

-------
                                 23
                                                                                 D


      The southern portion of  the Steuben Lakes  study area contains surface

 deposits of well-drained  Pox  and  Boyer soils.   In many regions, these soils

 are underlain by coarse sands and gravel which may serve as natural under-

 drainage  systems.  A detailed study of well-water quality was initiated by

 Tri-State University during 1979 (TSUER, 1979) to  determine if any ground-

 water impacts were apparent from on-lot septic system functioning.

     The water observed from well samples  generally exhibited a high standard

 of quality. Well samples taken near Crooked Lake showed some potential impact

 from wastewater systems.  The probability  of on-site well failure  is low,

 even in areas with high frequencies of qualitative failures.  For  well con-

 tamination to occur, the well point must intercept the  plume of poorly-

 treated wastewater originating from the leaching fields.  Because  the position

of the well point varies in 3 dimensions,  the probability of coincidence with

 the plume is low.  Hypothetically, only 87. of the wells in a checkerboard  lot

area would intercept plumes from leaching  pit installation on 20,000 sq. ft.

 lot areas (KVA, I976b).  Five of twenty samples (207.) showed coincidental

rise to nitrate and chloride elements frequently associated with leachate

conditions.  It is important to note that  the rises in  nitrate are well

below the permissible 10 mg as nitrogen of US EPA's Interim Primary Drinking

Water Standards.  However, further investigation may be warranted  in the Crooked

Lake region, particularly along the northern and eastern shores, to determine

 if a confined strata may be diverting wastewater loadings to deeper water

regions.

-------
                                  24
                             6.0  CONCLUSIONS






      The septic leachate survey of August,  1979 around  the  shores of  Crooked



 Lake, James Lake and Jinnerson (Steuben County, Indiana)  enabled some com-



 parisons of the impacts of septic leachate  intrusions  to  the  lakes  from



 nearby soil tank absorption systems under summer recreational stress  versus




 winter slack use conditions.  The conclusions  below derive  from leachate




 detector shoreline scans,  nutrient and  bacterial water  sample analysis,



 and shallow groundwater flow measurements.




      I)   Groundwater plumes occurred irregularly around the shorelines of



 the three subject lakes, and coincide closely  with  locations  developed




 earlier  in the December,  1978 survey.  Plumes  again appeared  to correspond



 closely  with soils classified as  moderately  rapid to rapidly  permeable




 and especially stream inlets or  weedy   more stagnant cut and fill  canal




 regions  common on each of  the lakes.  The actual number of plumes revealed



 was low  overall,  25  sites  on Lake James,  and less than  ten on each  of Crooked




 Lake and Jimmerson Lake.



      2)   The large stream  source  plume  emanating from Marsh Lake and  entering



 James Lake  from the  southern end  of  Snow Lake was still detectable  in summer



 above  background  level, but   again was at a  low level in  phosphorus and



nitrogen.



      3)  With  the  exception  of ammonia  levels  on James and Jimmerson  Lakes,




 nitrogen and total phosphorus values for interstitial groundwater  samples




 taken in summer were substantially lower than  the distribution of similar




 samples  drawn  in the winter.



      4)   The fecal coliform bacterial survey of Jimmerson and Crooked Lakes




 turned up only three locations exceeding the State's maximum  safe level of

-------
                                   25
                                                                                  D

bacteria  for  full body contact.  These locations were the 4-H Park stream and
Canal at Steuben Co. Park on Crooked Lake, and the shore stretch alongside
the high density Bledsoe's Trailer Park.  Bacterial impacts are isolated and
do not appear to be a significant hazard to recreational swimming areas.
     5)  Groundwater flow patterns showed some irregularities resulting from
complex soil matrices (which include clays and mucks), but portray a general
southwesterly flow with a low velocity estimated at less than 10 feet per day.
     6)  While shoreline surveys of the Crooked Lake region have revealed few
instances of plumes from nearshore hydraulic or qualitative failures of on-lot
septic systems, well samples indicate that confined subsurface strata should
be evaluated for the possibility of natural underdrainage discharge into deep-
er portions of the Lake.

-------
                                   26
                            7.0  REFERENCES
 EPA. 1979.  Environmental Impact Statement:  Alternative Waste Treatment
     Systems for Rural Lake Projects.  Case Study Number 4,  Steuben Lakes
     Regional Waste District, Steuben County, Indiana.

 EPIC. 1979.  Steuben Lakes Septic Tank System Analysis.  EPA Environmental
     Monitoring and Support Laboratory, Cincinnati, Ohio.

 Heier, A. and M. Osborn. 1977.  Malfunctioning Septic Tank Systems.  Steuben
     County Health Department, Angola, Indiana.

 Kerfoot, W.B. and S. Skinner. 1979.  Septic Leachate Surveys for  Lakeside
     Sewer  Needs Evaluation.  Presented at the Water Pollution Control
     Federation Conference, Houston,  Texas.

 Kirchner, W.B. and P.J. Dillon. 1975.  An Empirical Method of Estimating the
     Retention of Phosphorus in Lakes.  Water Resources Research,  Vol. 11 No.  1.

 K-V Associates. 1979.  Investigation  of Septic Leachate Discharges into  Steuben
     Lakes, Indiana.  K-V Associates, Inc. Falmouth, Massachusetts 02540.

 K-V Associates. 1979b.  On-lot Waste  Disposal Systems:   Public Health and
     Water Quality Implications.  Department of Public Health, Town of
     Barnstable.  K-V Associates,  Inc. 281 Main Street,  Falmouth,  MA 02540.

TSUER. 1979.  Investigation of Well Water Quality within the Steuben County
     Regional Waste District,  April and May,  1979.  Tri-State University
     Engineering and Research Center. Angola,  Indiana.

-------
   27
                                                    D
8.0  APPENDIX

-------
Ill
or
ID
                               28
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-------
                           29
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-------
                                                   30
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-------
                           31
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-------
                             33
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-------
                    APPENDIX E

Revised Limited Action Present Worth and User Charges -
              Steuben Lakes Project Area

-------
                         LIMITED ACTION ALTERNATIVE
                         PRESENT WORTH, USER CHARGES
ASSUMPTIONS

On-Site
 Systems
Capital
 Costs

0 & M
Salvage
 Values

Present
 Worth

User
 Charges
Year 1980 - 4171 EDU's (50% seasonal, 50% permanent)
Year 2000 - 6196 EDU's (50% seasonal, 50% permanent)
50% (4171) septic tanks to be replaced
10% (4171) ST-SAS's to be replaced

$1,877/ST-SAS
$  265/septic tank

$60/ST pumping (50% once/3 years, 50% once/5 years)
$400/H202 treatment (2% of drainfields/year)
$6/well sample (1/well/5 years)
$40/groundwater sample (20 tests, 3 samples/test)
Sanitarian @ $25,000/yr. - 260 days/yr.
Surveyors <§ $12,000/yr. - 130 days/yr. (1980), 200/yr. (2000)
Secretary @ $12,000/yr. - 260 days/yr.
(20% fringe benefits for sanitarian, surveyors, secretary,
soil scientist @ $325/day - 51 days/yr. (% day rentals -
see cost calculations

50 year useful life for ST's; 20 years for all else
6 5/8%, 20 years
Eligibility - 100% of site analysis and replacement system charge
Federal funding - 85% of site analysis; replacements
State funding - 6% of these items
Debt retirement - 6 7/8%, 30 years, 1980 capital
Debt reserve - 20% of debt retirement
Alternative Costs
Existing Systems:
     Replace 2086 ST's
     Replace 417 ST-SAS's
     Pump 1043 ST's/yr.
     H0  83 DF's/yr.
                                     ($
                     Capital
                      Costs

                      552.8
                      782.7
                      -0-
                      -0-
                     1,335.5
 x 1000)
  O&M
 Costs

 -0-
 -0-
62.58/yr.
33.20/yr.
95.78/yr.
                                                                     Salvage
                                                                      Value
Fut ure sys t ems:
     Add 2025 ST-SAS's
                       190.05/yr.
                       190.05/yr.
 1.52/yr./yr.   429.3
 1.52/yr./yr.   429.3

-------
Alternative Costs  (Continued)
Salaries:
Sanit. - $25,000/yr. - 260 days/yr.
Surveyors - $12,000/yr. - 130 days/yr
            $12,000/yr. - 3% days/yr/yr.-O
Secretary - $12,000/yr. - 260 days/yr.  -0
20% fringe benefits
Retainer:
Soil Scientist - $325/day - 51 days/yr.
Water samples analyses:
Wells - $6/sample - 834/yr.
Wells - $6/sample - 20/yr./yr.
Shallow groundwater - $40 x 20 x 3
Engineering, Legal, Contingencies:
Site Analysis
Legal, etc.  (9% construction cost)
Alternative Costs

Total Alternative Costs
     Total 1980 costs
     Total 1980-2000 costs
-0-
-0-
T.-O-
-0-


-0-

-0-

. -0-
-0-
-0-
-0-
-0-
-0-

120.2
1,176.6
1,296.8
2,632.3
190.05/yr.
25
6
0
12
43
0
8
0
51
0
16
16
5
0
2
7
0



171
1
.0/yr.
.0/yr.
.16/yr./yr.
.0/yr.
•0/yr.
.16/yr./yr.
•6/yr.
.03/yr.
.6/yr.
.19/yr./yr.
.58/yr.
.58/yr.
•0/yr.
.12/yr./yr.
.40/yr.
.40/yr.
.12/yr./yr.
-0-
-0-
-0-
.35/yr.
.83/yr./yr.
-0-
-0-
-0-
-0-


-0-

-0-

-0-
-0-
-0-
-0-
-0-
-0-

-0-
-0-
-0-
398.0
429.8
Present Worths
                                          ($ x 1000)
Total Alternative P.W. = 2,632.3 + 10.9909  (171.36 +
     (1.83) - 0.2772  (398.0 & 429.8) = 6523.7

Local Share (1980)
                                 ($ x 1000)
1980 Local Share = 9% ($2,632.3) - 236.91

User Charge (1980)

Debt Retirement - O.U/y58  (9%)  ($2,632,300)
Debt Reserve - 20% (above)
Annual 0 & M
     Total 1980 annual local cost
190.05) + 81.155
U.155
                        ($)
                       18,853
                        3,770
                      171,360
                     $193,983
User Charge = $193,983/4171 % $50/residence/year

-------
           APPENDIX F

No Action Alternative Present Worth -
    Steuben Lakes Project Area

-------
ASSUMPTIONS

On-Site
 Systems
Capital
 Costs
0 & M
 Costs
                            NO ACTION ALTERNATIVE
                                PRESENT WORTH
                Year 1980 - 4171 EDU's (50% seasonal, 50% permanent)
                Year 2000 - 6196 EDU's (50% seasonal, 50% permanent)
                1% of existing systems needing to be replaced/year

                $1,877/ST-SAS
                Sanitarian @ $18,000/yr.  - 260 days/yr.  to permit on-site
                 systems (12 hr/new system, 16 hr./replacement)

                $60/ST pumping (once/10 years)
                Surveyors @ $12,000/yr. - 130 days/yr. (1980), 200 days
                 (2000) to inspect on-site systems once/5 years
                50 year useful life for ST's, 20 years for all else


                6 5/8%, 20 years


Alternative Costs
Salvage
 Values

Present
 Worth
Existing Systems:
     Replace 42 ST-SAS's/yr.
     Pump each ST once/10 yrs.
Future systems:
     Add 2025 ST-SAS's (inc. pump).  190.05/yr.
                                     190.05/yr.
  s
Salaries:

Sanit. - $18,000/yr. - 260 days/yr.   18.00/yr.
Surveyors - $12,000/yr. - 130 days/yr. -0-
         $12,000/yr. - 3% days/yr./yr. -0-
20% fringe benefits                    3.60/yr.
Capital
Costs
78.83/yr.
-0-
78.83/yr.
($ x 1000)
O&M
Costs
-0-
25.03/yr.
25.03/yr.
Salvage
Value
178.1
-0-
178.1
Total Costs
Present Worth
                                      21.60/yr.


                                     290.48/yr.
                                                       0.61 vr/yr 429-3
                                                       0.61 yr/yr 429.3
 -0-         -0-
 6.00/yr     -0-
 0.16/yr./yr.-0-
 1.20/yr.    -0-
 0.03/yr./yr.	
 7.20/yr.    -0-
 0.19/yr./yr.

32.23/yr.    607.4
 0.80/yr./yr.
Total Present Worth = 10.9909  (290.48/yr. + 32.23/yr.) + 81.155  (0.80/yr./yr.)
                       0.2772  (607.4)
                    = $3,443.4

-------
period.  Also, emergent plumes from on-slte systems will be detected by scanning
the lake shore with a fluorescent meter;  sites having plumes will be further
analyzed using a shoreline transect with 5 samples per plume to be analyzed
at the Tri-State University for bacteria and nutrient levels).

     The results of the site analyses described above will be used to identify
specific measures that can be taken to correct malfunctioning on-site systems
and polluted wells in the Study Area.

-------
                         LIMITED ACTION ALTERNATIVE
                                SITE ANALYSIS

Description of Work to be Done

     The first step in adopting the Limited Action Alternative will be a site
analysis of existing wastewater disposal units and wells in the Study Area.
This site analysis will consist of a sanitary survey,  sampling and metering of
wells, soil sampling, inspection and excavation of on-site systems, and shallow
groundwater sampling near lake shores.

     A survey team will conduct a sanitary survey of each home, resort, and
business in the Study Area.   The team will ask residents to complete a ques-
tionnaire regarding their wastewater systems and wells and will inspect these
facilities.  The results of  the survey  will be used to plan work to be done
for the remainder of the site analysis.

     Following the sanitary  survey, a team will obtain well water samples from
wells located within 50 feet or downhill from septic systems.   These samples
will be tested at Tri-State  University  for fecal coliform bacteria and nitrates.

     Also following the sanitary survey, a team will inspect septic tanks that
are suspected of being undersized or leaking.   The team will locate tanks
to be inspected, will uncover and pump  them, and will inspect  them for construc-
tion, size, leaks, condition, and types of sanitary tees and baffles.  The team
will also rod influent lines (noting roots, other obstructions, and collapsed
pipe) and effluent lines (noting these items plus distances to headers, distri-
bution boxes, bends, and obstructions).

     Next, soil samples will be taken on lots where there have been septic
system malfunctions not explained by the sanitary survey or septic tank inspec-
tions and on lots where drainfields are suspected of being inadequate to provide
effective effluent disposal.  The samples will be examined to determine soil
texture and color, depth to  the seasonal high groundwater level, and water
table depths at suspected areas of soil disposal units and at alternative disposal
sites on or near the lots.  The soil sampling team also will probe the suspected
part of the soil disposal unit for depth, size, and type.

     After soil samples have been taken, a team of laborers will inspect subsur-
face disposal units of those on-site systems having recurrent backups or past
surface malfunctions not explained in prior steps.  The team will hand excavate
effluent lines, will hand excavate test pits (to examine size, depth, and type
of soil disposal unit), and will evaluate soil hydraulics  (soil crusting, decom-
position and silting in of aggregate,  soil distribution) as reasons for on-site
system failures.

     Then well water meters will be installed to monitor flows to those on-site
systems with limited hydraulic capacity as determined by the sanitary survey, soil
sampling,  and excavation of the soild  disposal unit.

     Finally, the  impact of wastewater disposal on  lake water will be investigated
by examining shoreline  groundwater.  The direction of  groundwater  flow along
lake shores will be determined at h mile intervals  two  times over  a  one  year

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         APPENDIX G




Limited Action Site Analysis

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ASSUMPTIONS
Existing
 Systems
Step 1 -
 Sanitary
 Survey
Step 2 -
 Well
 Sampling
Step 3 -
 Septic Tank
 Inspection
Step 4 -
 Soil
Step 5 -
 Drainfield
 Inspection
Step 6 -
 Well Water
 Meters
Step 7
 Groundwater
 Sampling
4171 EDU's (56% permanent, 44% seasonal)
70% possibly having undersized or leaking septic tanks
50% requiring soil sampling (small lots, old systems)
10% requiring drainfield inspection
100% (4171 EDU's) *
Sanitarian -
Sr. Engineer -
Soil Scientist -
Jr. Engineer -
Surveyors -
W. Q. Scientist -
(5/person/day)
 75 days
 75 days
 42 days
 75 days
525 days
 42 days
834 days
834 days
70% (4171 EDU's) * (10/person/day) = 292 days
Surveyors -          250 days
W. Q.  Scientist -     42 days
                     292 days

Well sample tests - $6/sample x 2920 (Tri-State University)

70% (4171 EDU's) * (6/person/day) = 487 days
Jr. Engineer -        487 days

3-person crew - $450/day x 487 days
Waste Disposal - $10/tank x 2920

50% (4171 EDU's) * (4/2 persons/day) = 1042 days
Soil Scientists -    540 days
Surveyors -          502 days
                   1,042 days

10% (4171 EDU's) * (3/supervisor/day) = 139 days
10% (4171 EDU's) * (1/2 persons/day) =  834 days
Sanitarian -          139 days          973 days
Laborers -            834 days
                      973 days

20% (4171 EDU's) x (6 inspections) * (24/day) = 208 days
Surveyors -           208 days
                Meter installation - $175/meter x 834 meters
Scan of lake shore (Kerfoot estimate) =
100 plumes * 2 plumes/day x 2 persons =
Sanitarian -
W. Q. Scientist -
Surveyor -
 35 days
 68 days
 35 days
138 days
     38 days
    100 days
    138 days
                Nutrient analyses - $40/series x 5/plume x 100 plume

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ASSUMPTIONS (continued)
Step 8 -
 Shoreline
 Hydrology
 Surveys
Step 9 -
 Supervision,
 Documentation
 Clerical
                Shoreline work = 20 days
                Sanitarian -          10 days
                W. Q. Scientist -      3 days
                Surveyor -             7 days
                                      20 days

                Steps 1 - 8 = 400 days
                Sanitarian - 400 days (including Steps 1,5»7,9)
                Sr. Engineer - 25% (400) + 25 for report =125 days
                Secretary - 400 days

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LABOR SUMMARY


Sanitarian
Sr. Engineer
Jr. Engineers
Soil Scientists
W. Q. Scientists
Surveyors
Laborers
Secretary

Local Management
Salaries






Rent
Service
Contracts




Equipment
& Sampling





Summary




DAYS PER STEP
12345678
75 139 35 10
75
75 487
42 540
42 42 68 3
525 250 502 208 35 7
834

834 292 487 1,042 973 208 138 20
Agency Costs
Sanitarian @ $25,000/yr. x 400 days
Surveyors @ $ll,000/yr. x 1,527 days
Laborers @ $12,000/yr. x 834 days
Secretary @ $12,000/yr. x 400 days

20% fringe benefits

Office @ $300/month x 18 months
Well samples analyses* - $6 /sample x 2,920
Septic tank inspection - $450/day x 487 days
- $10/tank x 2,920
Well water meters - $175/meter x 334
Groundwater samples* - $40/sample x 500

Fluorescent meter
Groundwater flow meter
Field sampling equipment
Paper supplies
Cameras & film for documentation
4 vans @ ($350 & $120 gas-oil) /mo. x 18
Total Local Agency
Salaries
Rent
Contracts
Equipment & Supplies
Total Local Agency

9 TOTAL
141 400
50 125
562
582
155
1,527
834
400 400
591 4,585

$ 38,460
64,600
38,500
18,460
$160,020
32,000
$192,020
$ 5,400
$ 17,520
219,150
29,200
145,950
20,000
$431,820
$ 14,000
4,000
4,000
6,000
3,000
33,840
$ 64,840
$192,020
5,400
431,820
64,840
$694,080

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Consultant Costs
Direct
 Labor
Other
 Direct
 Costs

Travel
Summary
Sr. Engineer @ $35,000/yr. x 125 days
Jr. Engineers @ $20,000/yr. x 562 days
Soil Scientists @ $25,000/yr. x 582 days
W.Q. Scientists @ $25,000/yr. x 155 days
Report Reproduction
Communication
Graphics, report preparation


House  rental  for office,  sleeping -  18 mos.
Other  per diem @   $20/day x  1,424
100 RT x 20 miles  x $0.20/mile
Direct labor x 3.0
Other direct costs x 1.2
Travel x 1.2
Total Costs

Local Management Agency Costs
Consultant Costs
  16,830
  43,230
  55,960
  14.910
$143,715

$    400
   1,500
   3.000
$  4,900

$  9,000
  28,480
     400
$ 37,880

$431,145
   5,880
  45.456
$482,431
                                                        $  694,080
                                                           482,481
                                                        $1,176,561

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                                       INDEX
Aerial photographic survey, iii
    surface malfunctions detected, 4

Agriculture,  iii

Alternatives:
    Limited Action, iii, 11
      costs,  iii-v, 13, 30, 36
      description of iv, 11
      impact  on land use, 30, 35
      impact  on population growth
       iv, 35
      impact  on water quality, iii-iv,
       33, 35
    No-Action, iii, v, 20
      costs,  v, 21, 30-31
      description of, 20
      impact  on land use, 30
      reasons for rejection, vi
      See also, Facilities Plan

Aquatic productivity.  See Productivity,
 aquatic

Archaeological survey, 30

BOD:
    effluent standard, iii

Chloride:
    drinking water levels, 5-6, 27

Construction  Grants Program.  See
 Funding, federal

Costs:
    capital per residence, 1, 3, 31
    construction, iii, 11, 21, 31
    operation and maintenance, 11, 13,
    21, 31
   present-worth,  iii, v, 13, 21
   revision of, v, 13
   user charges, 1, 11, 36
   See also, Alternatives,  costs

Crooked Creek:
   course of, 25
   discharge to, iii, 11

Draft EIS:
   issues addressed,  iii, 1, 18
   recommendations, iv-v, 11, 19
   studies  included in, 4
Erosion, 1, 25

Eutrophication, 26
   contribution of leachate to, 4
   modeling of, 4, 9
   See also, Phosphorus

Facilities Plan, iii, 1
   alternatives, iii, 21-22
   costs, iii, 1, 3, 11, 13, 36
   impacts on
      construction, 1
      land use, 36
      population growth, 1
      water quality, iii, 1, 3, 33, 35
      wetlands, 3
   problems identified in, 3
   recommendations, iii, 11
   socioeconomic impacts, 3

Fecal coliforms:
   effluent standard, iii
   survey of contamination, 5, 6, 14, 35

Final EIS, v
   recommendations, v, 11, 19

Floodplains:
   development near, 30
   impacts on, 27

Funding:
   federal, 1, 20
      eligibility for iv, 3, 11
       15-16, 19
   local, 11, 21
   state, 21
      eligibility for, 11

Groundwater:
   contamination, 3, 5, 14, 27, 35
   flow, 6, 8, 14, 27
   levels, 3, 25
   monitoring program, 17
   quality, 5, 9, 27, 35
   sources, 26
   survey, iii-iv, 5, 14
   use, 26

Land use, iii-iv, 27-28, 30, 35-36

Nitrates:
   drinking water standard, 5, 27
   groundwater levels, 5-6, 9, 14,
    35
   loading, 3

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NPDES permit:
   limitations, iii

On-Site Wastewater Management District:
   management requirements, 3

Phosphorus:
   drinking water levels, 6
   groundwater levels, 9
   loading, 3-5, 26, 33
      projections, 33
   See also, Eutrophication

Population:
   characteris tics, 27
   constraints, iv, 35
   induced growth, iii, 1
   present, 29
   projections, iii-iv, 29, 35

Productivity, aquatic:
   correlation with phosphorus level,
    9, 26
   correlation with plume emergence,
    9, 27
   problems, 6, 26, 35
   trophic state, iii, 4, 26, 33-34
   See also, Eutrophication

Proposed Service Area:
   map of, 2, 12

Public Hearing:
   concerns raised, iv

Recommended Action.  See Final EIS,
 recommendations

Rural Lake Projects, iii

Sanitary Review Board:
   responsibilities of, 19-20

Septic leachate, 3
   dye tests for, 3, 14, 20
   effects on groundwater, 27
   influence on productivity, 9, 27
   plumes detected, 4-7
      relationship to soil type, 4, 6
   sinks, 3
   survey, iii-iv, 4, 6

Septic tanks.  See Wastewater treatment
 system, on-site
Small Waste Flows District, iv, 18
   features of, iv,  v

Socioeconomic:
   characteristics, 1, 27, 30
   impacts,
      cost to homeowners, iii, 1,
       3, 11, 17, 30, 36
      displacement, 3, 36
      on seasonality of residence, 3

Soils:
   analysis, iii, iv
   suitability of, iv, 25
   types of, 6, 25-26, 30.
      relationship to groundwater
       flow, 27
      relationship to plume
        formation, 4, 6

Steuben Lakes:
   management needs, 20
   water quality, iii, 4, 18, 35

Steuben Lakes Regional Waste
 District:  1
   liability of, 17
   management requirements of, 17, 19
   recommendations to, v

Surface water resources, 25,  26

Suspended solids:
   effluent standard, iii

Topography, 1,  25
   constraints on centralized
    collection, 21, 22
   constraints on housing, 30

Vegetation:
   aquatic, 6,  9
      analysis of, iii-iv
      growth controls, 27
      problems associated with, 26
   threatened,  1

Wastewater:
   flow reduction, 22, 31
   management,  14-18, 20-21

Wastewater treatment system:
   central, iii, 11, 21-22
   land application, iii, 1,  11, 22-23

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   on-site, iii,  11,  13-15,  23
      costs, 30-31
      current state of,  3, 20
      eligibility for funding,  15-16,  19
      impact on population growth,  iv,  35
      impact on water quality,  iii-iv,
       3-4, 33, 35
      management  of,  iv, 14-17
      options, 31
      problems associated with,  13-14
      rehabilitation  of, iv-v,  11,
       13-14, 35
      survey of,  iv-v
   sizing of, 1,  11

Water quality, surface:
   impact of erosion,  1
   impact of leachate, iii-iv,  3-4,  33,
    35
   modeling, iii, 26,  33

Wetlands:
   development pressures, 1
   impacts on, 3, 30
                                               U.S. GOVERNMENT PRINTING OFFICE: 1981 250-800

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