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
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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.
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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.
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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
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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.
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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.
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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.
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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
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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.
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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
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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
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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)
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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.
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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.
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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
-------
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
-------
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
-------
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.
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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.
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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.
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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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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
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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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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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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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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.
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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.
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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.
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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
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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.
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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
-------
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
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28
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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
-------
APPENDIX G
Limited Action Site Analysis
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
------- |