EPA-5-MN-KANDIYOHI-GREEN LAKE SANITARY SEWER AND WASTE DlSTRICT-LA-80
'. FINAL ENVIRONMENTAL IMPACT STATEMENT
ALTERNATIVE WASTEWATER TREATMENT SYSTEMS FOR RURAL LAKE PROJECTS
CASE STUDY No. 2: THE GREEN LAKE SANITARY SEWER AND WASTE DISTRICT
KANDIYOHI COUNTY, MINNESOTA
Prepared by the
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V, CHICAGO, ILLINOIS
AND
WAPORA, INCORPORATED
WASHINGTON, D.C.
Approved by:
McGuire
ional Administrator
December 1980
U.S. Environmental Protection Agency
Region V, Library
230 South Dearborn Street X
Chicago, Illinois 60604.
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PREPARERS
This Final Environmental Impact Statement was
prepared by WAPORA, Inc., under the guidance of EPA
Region V Project Officers, Messrs. Gregory Vanderlaan
and Ted Rockwell. Mr. Eric M. Hediger and Mr. Gerald
0. Peters, Jr., served as WAPORA's Project Manager and
Project Advisor, respectively.
Significant input to the Draft EIS was provided
by WAPORA employees and subcontractors, listed in that
document.
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EXECUTIVE SUMMARY
Draft EIS
This Final Environmental Impact Statement (EIS) has been prepared
by the US Environmental Protection Agency, Region V (EPA). It addresses
several issues raised by the wastewater management plant proposed by the
Green Lake Sanitary Sewer and Water District (GLSSWD), the Applicant,
for funding under EPA's Construction Grants Program. The Applicant's
Facilities Plan proposed the construction of a centralized wastewater
collection and treatment system to serve the sewered communities of New
London and Spicer and the unsewered shoreline of Green Lake. A stabili-
zation lagoon facility was proposed that would discharge treated efflu-
ent to the Middle Fork of the Crow River downstream from Green Lake.
Issues that precipitated the preparation of this EIS were:
The documentation of need for the proposed centralized sewerage
facilities
The high cost of centralized wastewater collection and treatment
facilities in view of the availability of less expensive alter-
native technologies
The potential for adverse economic impacts to area residents
The potential for induced growth and adverse secondary impacts
The potential for groundwater contamination from the proposed
stabilization lagoon facility on farmland southeast of Green
Lake.
In response to the first issue, EPA devoted a substantial effort to
document existing water quality problems and potential public health
hazards that are associated directly with malfunctioning on-site waste-
water management systems in the vicinity of both Green Lake and Nest
Lake. This effort included an aerial survey and field investigation of
unsewered residential areas, a door-to-door sanitary survey of approxi-
mately 12% of shoreline on-site systems (Green Lake), a septic leachate
survey of lake shorelines, and water quality modeling based on readily
available data.
EPA concluded that most on-site systems around Green Lake and Nest
Lake are operating satisfactorily, despite the fact that many of these
systems are not in compliance with existing sanitary codes. Sewage
backups and ponding, as well as septic leachate movement into Nest Lake
and Green Lake via groundwater flows, are not widespread. Nutrient
budget analyses indicate that on-site systems contribute insignificant
amounts of phosphorus to Nest Lake and Green Lake under worst case
conditions -- 1% and 8% of the total phosphorus loads to these lakes,
respectively. These analyses further indicate that the largest contri-
butions of phosphorus to Nest Lake originated from non-point sources and
municipal sewage treatment plants upstream; the outflow from Nest Lake
carries, in turn, the largest phosphorus load to Green Lake.
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The results o! the needs documentation effort were integral to the
development of alternatives to the Facilities Plan Proposed Action.
These alternatives ranged from highly centralized (the Modified Facili-
ties Plan Proposed Action and variations of this plan) to largely decen-
tralized (Limited Action and No-Action). Several intermediate alterna-
tives proposed a mixture of technologies involving land application, the
upgrading and expansion of existing sewage treatment plants, off-site
community soil absorption systems (cluster systems), and installation or
rehabilitation of individual septic tank/soil absorption systems.
Present-worth costs were $8.41 million for the Modified Facilities Plan
Proposed Action, to $4.51 million for Alternative 6 and $2.89 million
for the Limited Action Alternative. The latter two alternatives, to
varying degrees, proposed on-site treatment of wastewater along Nest
Lake and Green Lake.
Public Participation
A Public Hearing on the Draft EIS was conducted on 4 August 1979,
within two months of its publication, in New London, Minnesota. Many
comments were voiced at the hearing and were submitted to EPA in writing
through mid-August 1979. The majority of public comments addressed the
following topics:
Validity of EPA's data (field) collection efforts in view of
sample size or collection period
Non-point source pollution of NeKt Lake
Feasibility of continued use of on-site systems
Implementation of decentralized wastewater management approaches
Urgency of need for improved wastewater management at New London
and Spicer.
Final EIS
The primary purposes of this Final EIS are to respond to all sub-
stantive public and agency comments on the Draft EIS and to clarify or
modify information that was presented in the Draft EIS. Information
requiring clarification includes the nutrient loading of Nest Lake and
Green Lake, as well as wastewater management procedures and costs.
Conclusions
In general, the Final ETS confirms the conclusions of the Draft
EIS. Major findings are listed below.
The Facilities Plan Proposed Action does not represent an appro-
priate strategy to serve the wastewater management needs of
sewered and unsewered communities in the Green Lake Study Area.
This conclusion is based principally upon considerations of the
need for sewerage facilities (as defined by the Construction
Grants Program) and cost-effectiveness.
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* Total elimination of on-site wastewater systems from the shore-
lines of Nest Lake and Green Lake will not change the trophic
status of these fertile and moderately fertile water bodies.
The continued influx of non-point source phosphorus loadings to
Nest Lake via the Middle Fork of the Crow River will, in the
absence of non-point source pollution control, offset the com-
bined phosphorus reduction gained through upgrading sewage
treatment plants and replacing or rehabilitating near-shore on-
site systems. Nutrient loads to Nest Lake from non-point
sources increase dramatically during periods of intense rainfall
and high runoff (wet years). Non-point sources and sewage
treatment plant discharges account for 56% and 40%, respec-
tively, of the estimated total phosphorus load to Nest Lake
under wet-year conditions. The outflow from nutrient-rich Nest
Lake accounts for an estimated 73% of the total phosphorus load
to Green Lake.
« Continued use of on-site systems, including new and upgraded
systems, and provision of decentralized off-site systems (clus-
ter systems) are appropriate solutions to the area's wastewater
treatment needs.
Key requirements for maximizing the reliability of on~site and
cluster systems with regard to water quality protection include:
--well-planned and well-executed site analysis
--measurement of, and designing for the natural assimilative
capacity of local soil and groundwater resources
--provision of adequate community supervision of the installa-
tion, operation, and, most importantly, maintenance of the
on-site and cluster systems.
Recommendations
The substance of the Final EIS Recommendations remains the same as
proposed in the Draft EIS: the solution to existing wastewater manage-
ment needs consists of a combination of off-site and on-site sewage
treatment facilities.
Spicer and New London will continue to use their existing col-
lection systems with final treatment facilities to be determined
by additional facilities planning (Step 1)
The shorelines of Green Lake and Nest Lake will continue to be
served by on-site systems except where feasibility or cost-
effectiveness considerations support the need for decentralized,
off-site facilities
For these areas the following sequence is recommended for com-
pletion of the Construction Grants process:
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Shorelines of Green Lake
Spicer and New London aud_tiest jLaks=
Step 1 Conduct detailed site analysis, In application for Step 2,
engineering and environmental provide certifications and
analysis of joint rapid infil- plans regarding construe-
tration, joint spray irriga- tiori, opera clou, i^ainc^-
tion, and separate upgrading nance and access to or-.-&ite
to provide tertiary efflueat ,;r decentralized u£+>siite
for discharge. svret.eius>. Sel^cc i^id i^-le-
merit Sanitary Review boi.ru.
Step 2 Design facilities Conduct site analysis a.:d
Step 3 Construct facilities Construct fa>jii: ties
In proceeding to Step 2 for the detailed design and specification of
decentralized wastewater management strategic^, LLe Applicant will:
« Conduct a survey of a_ll wells (to include homeowner iirc^rview
and well inspection), and perform sejcjceatial euvijonjaenuai. and
engineering analyses of unsewered areas
Begin site analysis on the west shore of Green Lake s<> that, a
decision on whether or not to sewer the seguen'c _-an be made iu
time to reflect this decision in tae design of Splcfcr's waste
water collection and treatment facilities
» Repair and replace en-site systems as required
« Continue and complete on-going site specific data collection.
In proceeding with these recommendations, EPA strongly suggests ciiac the
Applicant give careful consideration to the sections iu this £13 on
Management and I nip1emen tat ion which discuss the nature and advantages of
many of the Applicant's choices. It is also important that the Appli-
cant begin to develop the management structure that «/ill operate iu tlie
future, so that citizens and local officials can themselves take jjairt. in
the site analysis and technology selection. This will allow ail con-
cerned to become familiar with the procedures which will be uesdec to
maintain and improve area water quality in the future.
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CONTENTS
List of Preparers
Executive Summary
List of Figures
List of Tables
I. PURPOSE OF AND NEED FOR ACTION 1
A. The Applicant's Facilities Plan and Environmental
Impact Statement Issues 1
1. Needs Documentation 1
2. Cost-Effectiveness 5
3. Economic Impact 5
4. Induced Growth and Secondary Impacts 5
5. Public Controversy Over Water Quality 6
B. The Need for Improved Wastewater Management 6
1. Sewered Areas 6
2. Unsewered Areas 7
3. Conclusions 16
II. ALTERNATIVES 17
A. The Facilities Plan Proposed Action 17
B. EIS Recommendations 19
1. Spicer and New London 19
2. Shorelines of Nest Lake and Green Lake 20
a. Technology Selection 20
b. Community Management 24
c. Cost Estimate 26
d_. Implementation _______ _________ 26
C. The No-Action Alternative 29
D. Other Alternatives 30
III. AFFECTED ENVIRONMENT AND IMPACTS OF NO-ACTION 33
A. Soils 33
B. Surface Water Resources 33
C. Groundwater Resources 35
D. Population and Land Use 35
E. Economics 36
IV. ENVIRONMENTAL IMPACTS OF THE ACTION ALTERNATIVES 39
A. Surface Water 39
B. Groundwater ^
C. Population and Land Use 42
D. Economic Impacts 42
vii
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CONTENTS (continued)
Page
V. PUBLIC AND AGENCY COMMENTS 45
REFERENCES CITED
APPENDICES:
Appendix A Region V Guidance - Site-Specific Needs
Determination and Alternative Planning
for Unsewered Areas
Appendix B Costs
Appendix C Letter Response to Mr. F. W. Conner, USDA,
SCS> Regarding Soil Data
Appendix D Letters of Comment on the Draft EIS
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FIGURES
Page
1 Location of the Green Lake Study Area 2
2 Facilities Plan Proposed Service Area 3
3 EIS Service Area 4
4 Total Phosphorus Loading to Nest Lake, Green Lake,
and Woodcock Lake in 1972-1973 8
5 Results of Aerial Observations of On-Site
System Surface Malfunctions, EPIC 1978 10
6 Results of 1978 EPA Construction Grant Survey 11
7 Location of Septic Leachate Plumes Around
Green Lake and Nest Lake 14
8 Location of Potential Cluster System and Land
Application Sites in the Green Lake Study Area 15
9 Facilities Plan Proposed Action (Modified) 18
TABLES
Page
Problem Systems Found in November 1978
Sanitary Survey 12
Revised Cost Estimates for EIS Alternatives
4, 5, 6 and Limited Action 27
Total Phosphorus Loading (kg/yr) to Nest Lake
and Green Lake Under No Action Alternative 35
Population Projections and Average Annual
Growth Rates for Proposed EIS Service Area 36
Phosphorus Inputs (kg/yr) to Nest Lake and
Green Lake Under Action Alternatives 40
Financial Burden and Displacement Pressure of
the Facilities Plan Proposed Action and Remaining
EIS Alternatives 44
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CHAPTER I
PURPOSE OF AND NEED FOR ACTION
A. THE APPLICANT'S FACILITIES PLAN AND ENVIRONMENTAL IMPACT STATEMENT ISSUES
The Green Lake Sanitary Sewer and Water District (GLSSWD), the Applicant,
has requested the participation of the US Environmental Protection Agency,
Region V (EPA) in the funding of proposed wastewater collection and treatment
facilities for the Green Lake area of Kandiyohi County, Minnesota (see Figure
1). These facilities were recommended in the "Preliminary Feasibility Report
on Water Pollution Control Facilities: Green Lake Vicinity, Kandiyohi County
Minnesota" prepared by Noyes Engineering Service and Rieke Carroll Muller
Associates, Inc. (RCM) in December 1974. The Applicant's centralized waste-
water management plan was submitted to EPA in November 1975 for funding under
the Construction Grants Program. Additional facilities planning information,
as required by the provisions of this program and by the Minnesota Pollution
Control Agency (MPCA), were completed by the Applicant in August 1976. The
feasibility report and additional facilities planning data collectively con-
stitute the Facilities Plan for the proposed GLSSWD Service Area (see Figure
2). The expanded Service Area addressed in this EIS, which includes a portion
of the Nest Lake shoreline, is illustrated in Figure 3.
The Applicant's Facilities Plan concluded that centralized sewerage
service was warranted for the Village of New London, the City of Spicer, and
the residential area surrounding Green Lake. This conclusion was based on:
1) inadequate treatment performance at the New London and Spicer sewage treat-
ment plants as well as infiltration/inflow problems in their respective col-
lection systems, and 2) inadequate performance of on-site wastewater manage-
ment systems around Green Lake due to poor soils, high water table, and small
lot sizes. The Facilities Plan also linked these on-site system problems with
deteriorating water quality in Green Lake.
Although the Facilities Plan addressed the implementation of both a
centralized wastewater collection and treatment system and a water supply
system to serve Green Lake area residents, this EIS evaluates only the con-
struction and operation of wastewater management facilities. The EPA Con-
struction Grants Program serves to partially fund wastewater collection and
treatment systems, but not water distribution systems.
The primary purposes of the EIS are to review and analyze the GLSSWD's
application for EPA funding of the Facilities Plan Proposed Action and to
develop and evaluate alternative wastewater management approaches in view of
the five public issues surrounding the project. These issues are described
fully below.
1. NEEDS DOCUMENTATION
Federal participation in the funding of the Facilities Plan Proposed
Action or of any alternative to this action is contingent upon the documen-
tation of need for improved wastewater management facilities. Analysis of
need is necessary to establish the nature of wastewater disposal/treatment
problems and to develop reasonable alternatives for their solution. The
extent and distribution of on-site system problems is a leading issue in this
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MINNESOTA
GREEN LAKE STUDY AREA
MEWL
SWCHI
WILLMM
KANDtYOHl
COUNTY
FIGURE 1 LOCATION OF THE GREEN LAKE STUDY AREA
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project. If the need for improved on- and off-site wastewater management
facilities is better substantiated in the Green Lake Study Area, then their
costs will be better understood and, consequently, more likely to be accepted
by local citizens.
Although indirect evidence was presented in the Facilities Plan indicat-
ing that there may be a water quality problem attributable to malfunctioning
lakeshore septic systems, the relationship between deteriorating water quality
and inadequately functioning septic systems was not documented. With the
exception of two isolated cases involving high nitrate-nitrogen levels
(greater than 10 milligrams per liter (irg/1) in domestic wells along the south
shore of Green Lake (by letter, William Hendrickson, RCM, to James Roth, MPCA,
17 December 1976), claims of possible hazards to the public health were
unsubstantiated.
2. COST-EFFECTIVENESS
The total capital cost for the Facilities Plan Proposed Action was esti-
mated in the Plan (August 1976) to be $4.4 million. This represents an
investment in 1976 dollars of approximately $875 per person and $3,709 per
existing dwelling unit within the proposed GLSSWD Service Area (see Figure 3),
The availability of alternative collection and treatment technologies,
including on-site and small scale off-site facilities, offers the potential
for less expensive solutions to wastewater management problems. In the
absence of needs documentation data, it has not been demonstrated that the
level of resource commitments proposed for large-scale, centralized facilities
(on an area-wide basis) is necessary.
3. ECONOMIC IMPACT
The average local share per residence of the total capital costs for the
Facilities Plan Proposed Action is approximately $2,180*. The Plan estimates
the annual user charge per resident to be $194, which includes annual debt
retirement of the amortized local share of the project cost and annual
operation and maintenance costs. The user charge represents approximately
1.4% of the average annual income for year-round residents. Seasonal resi-
dents, particularly those in smaller, less expensive homes, may corae under
considerable pressure to sell their property.
4. INDUCED GROWTH AND SECONDARY IMPACTS
Although the high costs of new wastewater collection and treatment faci-
lities might compel some residents to sell their property, the availability of
sewers in the Green Lake watershed would facilitate the construction of new
dwelling units around Green Lake at greater density than is POW the case.
Residential development induced by a centralized sewerage system in the Pro-
posed Service Area could have undesirable impacts on water quality and sen-
sitive environmental areas. For example, housing construction on steep slopes
This figure is based on RCM's estimate of local share of project capital
costs (17 December 1976) and the estimated number of residences in the
Facilities Plan Proposed Service Area in 1976.
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could accelerate soil erosion and, therefore, sedimentation of Green Lake and
adjacent wetland areas. Sustained sedimentation of these water bodies could
increase nutrient loadings and severely affect, if riot eliminate, the ability
of wetlands to purify water* and support wildlife. Development induced by the
provision of sewers also may over-tax existing local public services and
fiscal resources.
Based upon their experience with previous wastewater management projects
in rural lake areas, the Minnesota Pollution Control Agency has concluded tnat
sewering of Green Lake may cause the following:
* Increased development of lakeside areas;
« Increased development of adjacent non-lakeside areas; and
* A shift from seasonal to permanent occupancy.
5. PUBLIC CONTROVERSY OVER WATER QUALITY
Residents of Harrison Township and Irving Township have expressed concern
over the wastewater stabilization lagoon system, proposed in the Facilities
Plan, arid its potentially adverse effects upon local groundwater quality.
Farmers and other citizens who live in the vicinity of the proposed treatment
site focus their concern on the potential for contamination of domestic water
supply wells through lagoon seepage into sandy soils. This concern persists
despite the fact that the Plan i.ecommended installation of an impermeable
bentonite liner for the lagoon.
B THE NEED FOR IMPROVED WASTEWATER MANAGEMENT
In determining the need for improved wastewater management in the Green
Lake Study Area, it is appropriate to examine both presently sewered communi-
ties, including the Village of New Lordon. and the City of Spicer, as well as
unsewered areas, which include the corridor between New London and the
northwest corner of Green Lake, the eastern shoreline or Nest Lake, and the
entire shoreline of Green Lake. The extent v,o which the wastewater improve-
ment needs of sewered and unsewered areas were addressed by the Facilities
Plan and the Draft E1S is discussed belov;. The conclusions, of the Facilities
Plan reviewed here are not necessarily those of the EIS.
1. SEWERED AREAS
The need for replacing or upgrading and expanding the wastewater manage-
ment systems presently serving the Village of New London and the City of
Spicer was addressed in the Facilities Plan and the Draft EIS. The Facilities
Plan cited excessive infiltration/inflow problems associated with the sanitary
sewer systems serving these two communities, and the inability of the New London.
and Spicer sewage treatment plants to comply with 1974 MPCA effluent discharge
requirements as justification for replacement of these two wastewater manage-
ment systems per the Applicant's Proposed Action, New London's sewage treatment
plant (STP) discharges priraary effluent at an average rate of 129,000 gallons
per day (gpd) to a point in the Middle Fork of the Crow River approximately
4 miles above Nest Lake. The Spicer aTP discharges a secondary effluent
(114,000 gpd) to Woodcock Lake.
* Wetlands are natural sediment and nutrient traps.
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On the basis of nutrient budgets prepared by the NationaJ Eutrophication
Survey, the Draft EIS reports that approximately 10% of the phosphorus load to
Nest Lake and 93% of the phosphorus load to Woodcock Lake are attributed to
the effluent discharges from the New London and Spicer STPs, respectively.
Removal of or reduction in the phosphorus load generated by the New London STP
will not improve the trophic status of Nest Lake, suggesting the significance
of the non-point source phosphorus load carried by the Middle Fork of the Crow
River (see Figure 4). The Draft EIS indicated that improvements in the water
quality of Nest Lake, as a result of phosphorus reduction at the New London
STP, would be insignificant, given the Nest Lake drainage basin-to-surface
area ratio of 82 to 1. On the other hand, elimination or upgrading and
expanding of the Spicer STP would improve significantly the water quality of
Woodcock Lake. As indicated in Figure 4, 92% of the phosphorus load to this
lake is contributed by the Spicer STP.
2. UNSEWERED AREAS
In the Facilities Plan, the addressed need for wastewater management in
presently unsewered areas focused on the individual sewage treatment systems
surrounding Green Lake. Reported problems with these on-site systems
included:
An estimated 55% of the on-site wastewater disposal systems around
Green Lake cannot comply with the 4 foot separation parameter*
specified in the Minnesota Shoreland Management Act;
The same 55% of the individual disposal systems cannot be upgraded
to comply with the Shoreland Management Act because of the small size
of the platted lots around Green Lake;
Based upon EPA National Eutrophication Survey data (1974), individual
disposal systems around Green Lake are contributing to the nutrient
loading of this basin. The Facilities Plan indicated that the amount
of wastewater discharged to Green Lake from septic tank drainfields
along its shoreline was approximately 23% greater than the total
discharge loading from Spicer and New London (by letter, William
Hendrickson, RCM, to James Roth, MPCA, 17 December 1976); and
Many of the older individual on-site systems installed approximately
20 years ago may be cesspools, which are prohibited under current
sanitation codes.
The Facilities Plan also reported that glacial fill on the northern and
southern shores of Green Lake and sand and gravel soils on the eastern and
northwestern shores of Green Lake are not suited to the successful use of
on-site systems.
A series of studies has been performed by EPA during preparation of the
EIS to evaluate in detail the wastewater management needs of the unsewered
portions of the Green Lake Study Area. These efforts were undertaken to
determine the extent and distribution of water quality and public health
problems associated with on-site problems around Nest Lake as well as Green
Lake.
The Act stipulates that there be a vertical distance of 4 feet between
the septic tank drainfield and the highest known groundwater elevation.
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1,000
2,000
|0f«CT PRECIPITATION, 2%
((MEDIATE DRAWAOE,I%
OH-SITE SYSTEMS, 1%
MIDDLE PORK OF CROW RIVER, 56%
LOWOON AttO WLOflAOE STP* , 40%
KEST LAKE
TOTAL PHOSPHORUS LOAQWG
I,OOO
2.OOO
3,000
OUTLET FROM NtlT LAKE, 73%
4-SITE SYSTEMS, 8%
[HMHEOMTe DIWW*IA«e(ll«CU«HI« OVERFLOW 9W6EN LAK
FRtJ*t W00WSOCK LAKE J, 2% TOTAL PHOSPHORUS LOAWM«
* 2,605 kf/yr
i.OOO
[SPICCR STP, 92%
IKmCOIATE DRAINAGE, 6%
I OWECT PHtCIPITATION
OM-SITE SYSTEMS
2%
WOODCOCK LAKE
TOTAL PHOSPHORUS LOADWQ
= §71
FIGURE 4 TOTAL PHOSPHORUS LOADING (KC./YR) TO NEST LAKE, GREEN LAKE,
AND WOODCOCK LAKE IN 1972 - 1973 (NATIONAL EUTROPHICATION
SURVEY 1974)
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A distinction has been made in this EIS between water quality and public
health problems on the one hand and nuisance or community improvement problems
on the other hand. On-site systems known to contribute to violations oi" water
quality standards or changes in lake trophic status pose water quality
problems. Public health problems may result from ponding of effluent on the
soil surface or contamination of groundwater supplies in excess of drinking
water standards. Water quality and public health problems are the bases upon
which improved wastewater management needs determination is made under the EPA
Construction Grants Program. Where lakes are used for contact recreation,
violation of the fecal coliform standard also constitutes a public health
hazard. Community improvement problems, which include odors, restrictions on
water use, and restrictions on building expansion, do not constitute used for
improved wastewater management facilities under the Construction Grants
Program.
The studies undertaken by EPA to evaluate on-site system problems ^rcunci
Green Lake and Nest Lake are described below:
a. Nutrient budget analyses performed by EPA during preparation of the
EIS have indicated that on-site systems contribute an estimated, 1% of the
phosphorus load to Nest Lake and 8% of the phosphorus load to Green Lake. As
seen in Figure 4, septic tanks are insignificant sources of phosphorus com-
pared to non-point source nutrient loadings. Removal of on-sit& systems would
not improve the trophic status of either lake.
b. An aerial photographic survey was conducted by EPA's Environmental
Photographic Interpretation Center (EPIC) in order to detect any on-site
system surface malfunctions within the Study Area. The survey was made on 20
August 1978. Results of the EPIC survey, shown in Figure 5 indicate that
surface malfunctions were not widespread. Only three marginally faJliDg
on-site systems were found along the Green Lake shoreline. Two of ttiese
failures were located on the north shore. One currently failing and one
marginally failing system were detected along the north shore of Nest Lake.
Any on-site system that gave an indication of previous failure or exhibited
potential for failure was considered a marginally failing system. Since many
of the systems are poorly maintained, however, these surface malfunctions
cannot without further investigation be attributed to site limitations.
c. An on-site sanitary survey of the Green Lake Shoreline was conducted
from 6 November through 26 November 1978. This survey consisted of a sample
of 74 (12%) residences around Green Lake. The purpose of this study was to
identify the extent, nature, and distribution of problems associated with
on-site systems, including violations of the local sanitary code. The study
showed that, despite widespread violations of construction standards for
septic tank/soil absorption systems (ST/SAS), very few systems experienced
recurring backups or ponding. The condition of the systems surveyed between 6
November and 29 November is described in Figure 6. The problems noted by the
residents included occasional backups (3), recurring backups (6), occasional
ponding (2) and one full pit privy. These represent 16% of the 75 systems
surveyed. The problem systems are listed in Table 1, by type of problem,
survey code number, notes on the type of system and relevant site conditions,
and obvious repairs suggested by the surveyor or the resident. Rerrierli as for
those five systems where the solution was not obvious could include rerouting
the surface drainage, flow reduction, dosed mounds f.or lots with high ground-
water and/or hydrogen peroxide treatment cf the soil absorption areas.
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Table 1
Problem .Systems Found in the November 1976 Sanitary Survey
Problem System
Occasional Backup 6
17
48
Occasional Ponding 42
45
-Recurring Backup 5
12B
.28
Full pit privy
37
55
56
53
Type of System and
Site Conditions
Surface .drainage onto
drainfield ar.ea
Old, small septic tank
and drainfield
Trench in high ground-
water
Large septic tank and
trench but high ground-
water
Trench in high ground-
water
Possible holding tanks
Possible holding tank
Old s£ptic tank/drainfield
with _surface drainage onto
drainfield and in nigh
groundwater
Old system with surface
drainage onto drainfield
area
Possible
Repairs
Not obvious
New system on
own property planned
Not obvious
Not obvious
Not obvious
New system on
own property planned
New system on
own property planned
Room on property
for new drainfield
at higher elevarion
Not obvious
Obstruction in house sewer Remove obstruction
Relatively new system with
low water usage well above
lake level
Full pit privy
New drainfiald
on own property
planned
Relocated pit privy
12
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The survey covered 22, or 6%, of the seasonal residences (non-resort) and
45, or 30%, of the permanent residences. All were lakeside properties. Thus,
while the survey is heavily biased toward residences that are most likely to
have problems, the seasonal population was represented. In fact, three of the
12 problems recognized were reported by seasonal residents: two with occa-
sional backup problems and one recurrent backup problem.
d. A through-the-ice septic leachate survey was conducted along the
shorelines of Green Lake and Nest Lake during March 1979. This study was
undertaken to determine whether groundwater plumes from nearby septic tanks
were emerging along the lakeshore causing elevated concentrations of nutri-
ents. Septic tank leachate plumes were detected with an instrument referred
to as a Septic Leachate Detector ("Septic Snooper"). The instrument is equip-
ped with analyzers to detect both organic and inorganic chemicals in domestic
wastewater. Sampling for nutrients in surface and groundwaters and for
bacteria in surface water were coordinated with the septic leachate profile to
clearly identify the source of the leachate.
The following observations were obtained from the shoreline profiles,
analyses of groundwater and surface water samples, and evaluation of ground-
water flow rates and patterns:
A total of 64 locations exhibited effluent plume characteristics.
Of these, 26 originated from surface water discharges and 38 from
groundwater leachate. The locations of these effluent plumes is
shown in Figure 7.
The most pronounced source of effluent was inflow from the Middle Fork
of the Crow River into Nest Lake. The daily winter loading of phos-
phorus from the river was estimated at 8.6 kg/day compared to total
loading from all groundwater plumes around the lake of .15 kg/day.
A noticeable undocumented source of phosphorus loading was observed
originating from the discharge stream of an unnamed lake near the
sewered town of Spicer.
The observed pattern of plumes on Green Lake correlated with projected
groundwater inflow for the surficial deposits. Most plumes were found
on the north and west shorelines, and few were observed in the south
and east segments.
e. In conjunction with the assessment of water quality and public
health problems associated with on-site wastewater management systems, EPA
sponsored a US Department of Agriculture, Soil Conservation Service (SCS)
field investigation of potential land application (rapid infiltration and
spray irrigation), and cluster (community treatment) system sites in the Green
Lake Study Area during 1978. These sites are illustrated in Figure 8. Soils
data collected by SCS during these investigations point to the conclusion
that wastewater management approaches involving land application by the rapid
infiltration, spray irrigation, and cluster systems are feasible for the Green
Lake Study Area. More detailed investigation of feasibility is warranted.
13
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3. CONCLUSION
The need for improved wastew^ter maiiagenk-^io in dewervc areas has long
been established. The in!"iltratioa/iafio,-,' and treatment efficiency problems
associated with the New London arid Spicer wascewat^r management systems as
reported by the Applicant, warrant the iffiiuediate replacement or upgrading and
expansion of these systems. Most on-sice systems around Green Lake and Nest
Lake are, however, operating satisfactorily.
Many of the on-site systems presently ir.. use wi tivia the Green Lake Study
Area are poorly maintained, due. iaauy are inadequately designed. Routine main-
tenance for all on-site systems and upgrading of inadequately designed systems
will substantially reduce the number of problems. Where problems cannot be
solved by routine maintenance or upgrading ulone, alternatives to tae conven-
tional ST/SAS are feasible in the Study Area which will minimize or eliminate
the problems.
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CHAPTER II
ALTERNATIVES
Solutions to wastewater management problems in the sewered and unsewered
portions of the Green Lake Study Area, as recommended by the Facilities Plan
and the EIS, are described in this chapter. The discussion of the EIS Recom-
mendations (Section II.B) focuses on septic tank system installation, opera-
tion, and maintenance considerations surrounding the implementation of a
decentralized wastewater management approach.
A. THE FACILITIES PLAN PROPOSED ACTION
The Facilities Plan proposed the construction of a centralized wastewater
management system to serve the residents of New London, Spicer, and Green Lake
(see Figure 2). Sewage flows [0.55 million gallons per day (mgd), average
daily flow] from these areas would be conveyed by a combined system of gravity
sewers, force main, and approximately fifteen pump stations, to a wastewater
stabilization lagoon facility southeast of Green Lake for treatment. The
Applicant has proposed that the existing sanitary sewer systems serving New
London and Spicer be rehabilitated following the completion of a Phase II
sewer system evaluation survey.
The treatment facility, which would require an area of about 76 acres,
involves a dual or parallel system of ponds operating in series which allow
for the shutting down of one side during the winter when flows are low. The
ponds have a storage capacity of 180 days. Effluent discharge to the Middle
Fork of the Crow River would be "controlled", that is, limited to approxi-
mately a two-week discharge period twice a year. The degree of treatment
achieved by the Applicant's proposed lagoon facility would be secondary and
would comply with the following MPCA standards for controlled effluent
discharge during periods of adequate streamflow: 25 mg/1 BODj., 30 mg/1 total
suspended solids, and 200 MPN/100 ml fecal coliform bacteria.
The Facilities Plan Service Area shown previously in Figure 2 has been
modified to be comparable with the service areas of the EIS alternatives. The
modified Facilities Plan Service Area, which includes the eastern half of Nest
Lake and the corridor between New London and the northwest corner of Green
Lake, is illustrated in Figure 9.
Costs developed in the Draft EIS for the Facilities Plan Proposed Action
have been upgraded to ensure further comparability with the EIS alternatives.
They include:
Construction and engineering,
legal, and contingency costs (1978 $) $8,156,100
Future construction and engineering,
legal, and contingency costs $ 38,000
Annual operation and maintenance
costs $ 85,800/year
17
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$1
$
$
,066,820
160
170
(Spicer and
New London)
(currently
unsewered areas)
Local share of construction
and engineering, legal, and contin-
gency costs
1980 (first year) average annual
user charge
The 1980 average annual user charge includes all initial operation and
maintenance costs plus annual payment on the debt of privately as well as
publicly financed construction costs. The calculation of the user charge is
based on the assumption that local construction, engineering, legal, and con-
tingency costs will be paid through the use of a 30-year bond at an interest
rate of 6-7/8%.
Implementation of the Facilities Plan Proposed Action would include
conventional procedures that are adequately described in the Facilities Plan.
B. EIS RECOMMENDATIONS
Spicer and New London will continue to use their existing collection
systems. Their final treatment facilities will be determined by additional
facilities planning.
The shorelines of Green Lake and Nest Lake will continue to be served by
on-site systems except in localized areas where feasibility or cost-
effectiveness considerations support the need for decentralized, off-site
facilities.
The following sequence is recommended for completion of the Construction
Grants process:
Spicer and New London
Step 1 Conduct detailed site analysis,
engineering and environmental analy-
sis of joint rapid infiltration,
joint spray irrigation, and separate
upgrading to provide tertiary effluent
for discharge.
Step 2 Design facilities
Step 3 Construct facilities
1. SPICER AND NEW LONDON
Shorelines of Green Lake
and Nest Lake
In application for Step 2
provide certifications and
plans regarding construction,
operation, maintenance and
access to on-site or decen-
tralized off-site systems.
Select and implement Sanitary
Review Board
Conduct site analysis
Technology Selection
Construct facilities
EIS Alternatives 4, 5, and 6 can all be considered cost-effective waste-
water management approaches. They differ only in their proposed methods for
19
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treating and disposing of wastewater generated in the sewered areas: EIS Al-
ternative 4 features a rapid infiltration treatment facility to handle New
London and Spicer sewage flows; fully-treated effluent is recovered and dis-
charged to the Middle Fork of the Crow River above Nest Lake. EIS Alternative
5 substitutes a spray irrigation treatment facility for Alternative 4's rapid
infiltration plant with no surface water discharge of treated effluent is
required. EIS Alternative 6 employs new tertiary (advanced) New London and
Spicec treatment facilities to serve the needs of the existing sewered areas.
The EIS recommends that the Applicant conduct, additional Step 1 analyses,
funded by EPA, of these centralized treatment, alternatives . EPA encourages
the use of land application and will requite an evaluation, including detailed
site analyses, of the rapid infiltration and spray irrigation methods diu-
cussed in this EIS. The evaluation oi these methods will include determina-
tions of physical arid chemical uropet tic-s of soils at the potential land
application sites, water-table measurements , and grouuowater quality analyses.
Detailed investigation of potential iaud application sites should also include
an archaeological survey to identity prehistoric archaeological sites that may
be disturbed. The Applicant's
eva
luation of separate wastewater management
options for New London and Spic-pr, an proposed under EIS Alternative 6, should
include the following:
« Applicant's own analysis
plant upgrading;
e feasibility and costs of treatment
* Engineering, cest. and eHvirutuientul. analysis of sludge management
options ; arid
» Engineering, cost, .in<* environmental analysis of effluent disinfec-
tion options,
2. SHORELINES OF NEST LAKE AND GREEN LAKE
The EIS recommends l\n:l the mise-wcred -portions or Nest Lake (eastern half
only) and Green Lake coin. iauf co ht, served by on.-s.ite systems wherever feas-
ible. Where use of existing or upgraded ori-site systems is not feasible,
residents could be served by community treatment (cluster) systems. The
community's role in managing on- situ systems would be expanded to include, at
least, supervision oi system maintenance, monitoring of present or potential
underground potable war.ei sources, and collection of user charges to recover
the costs involved.
Many elements of this approach, including likely maximum costs can be
sketched now, but the final details will not be known until: I)
house-by-house analysis alj'>w:> a selection oi treatment methods for each house
and 2) the Applicant and conumii'ity decide on the method and. degree of manage-
ment to be provided. The two considerations are discussed below.
a. Technology Selection
Identification of on-site systems' problems and the causes of their
problems is the first step to be taken specifying technologies for individual
residences. Site specific analysis id necessary co accomplish this. The
analysis should be sequential, beginning with accessing available health
department records, interviewing residents on the use end maintenance of their
-------
systems, inspecting the site for obvious malfunctions and inspecting the loca-
tion and condition of any on-site wells or springs. Based on the
information gathered, additional investigations may be warranted to identify
the cause and possible remedies for recognized problems. Examples ot addi-
tional investigations, keyed to problems, include:
Problem
Recurrent backup in house or
surface malfunction
I investigations in Sequential Order
Install and monitor water meter
Inadequate separation distance
fmm 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
Uncover pump and inspect septic tank
for obstruction and groundwater inflow
Rod house sewer and effluent line
Excavate and inspect drainfield dis-
tribution lines, if present
Determine soil absorption system size
and degree of clogging by probing and
sample pit excavation. Note soil tex-
ture and depth to groundwater.
Inspect well for proper seal, vent,
drainage, and grouting
Sample well and analyze for fecal
coliform bacteria, nitrates, and
fluorescence
Monitor groundwater flow if aquifer
is shallow or unconfined
Monitor
rate
groundwater flow direction and
Locate effluent plume vicinity of
lakeshore using groundwater probe and
fluorescent analysis
Sample groundwater in leachate plume
at lakeshore. Analyze for total phos-
phorus, total Kjeldahl nitrogen,
nitrate, nitrogen, and fecal coliform
bacteria
Inspect property to assess feasibility
ot replacement or upgrading
21
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Problem Investigations in Sequential Order
If feasible, document system inadequa-
cies by probing and sample pit excava-
tion.
Septic tank or soil absorption Inspect property to assess feasibility
system size or design known to ol replacement or upgrading
be less than code requires
In the selection of technologies f»r individual sites, it is strongly
recommended 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 selections
The availability and cost of skilled manpower for maintaining and
monitoring innovative or subcode systems be weighed against the
feasibility and cost of requiring conventional on-site systems or
off-site systems
That there be a multidisciplinary team, consisting of the sanitarian-
administrator and available specialists in a number of fields (see
Management Section) to advise an organized Sanitary Review Board on a
case-by-case basis
That the individual homeowner should be informed of the different
options being considered (and their costs) when technology selections
are being made. His/her opinion and advice should be solicited.
Feasible problem-solving approaches based on information gained from the
s te analysis should be discussed with the owner. Primary criteria for
identifying the appropriate technology should be cost, benefits, and risk of
f.iilure. Undoubtedly, eligibility for Construction Grants funding will be
considered also. General guidelines for eligibility of on-site technologies
aire presented below:
Replacement of facilities of obviously inadequate design will be
eligible if feasible. Cesspools are an example of obviously inade-
quate facilities. Septic tanks in very poor repair or substantially
smaller than required by state codes are another example. Small
drainfields, dry wells, or unusually designed systems are not neces-
sarily "obviously inadequate".
Parts of systems that cause recurrent surface failures, backups or
contamination of potential drinking water aquifers are eligible for
repair or replacement. This does not apply to water using fixtures.
Systems that fail because they are abused will not be eligible un-
less the abuse is terminated, the usage of the system is documented
by water meter readings and/or reinspection of the system, and the
problems persist.
-------
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" will be determined by
design and site characteristics that are shown to be contributing to
failures.
Compliance with state and local on-site design regulations in design
or repairs and replacements is desired where feasible and effective.
Compliance is not a condition of eligibility if subcode design or
alternative processes can reasonably be expected to eliminate or sub-
stantially mitigate public health and water resources problems. Inno-
vative designs will similarly be eligible, with the added condition
that inspection and monitoring commensurate with the degree of risk
be assured. For subcode, alternative, or innovative systems, it is
expected that water conservation devices commensurate with the degree
of risk for hydraulic overloading will be installed at owner or appli-
cant's expense.
For the Green Lake Study Area, methods will be eligible that modify
the flow or chemical characteristics of effluent plumes entering
Green Lake and Nest Lake if the modification might reduce the near-
shore plant growth. Such methods will be considered innovative.
Monitoring of their effectiveness will be required.
On-site systems built after December 1977 are not eligible for repair
or replacement but will be eligible for site analysis. Accommodation
of new facilities that increase wastewater flow (garbage disposals,
dishwashers, etc.) will not be a justification for eligibility. Sys-
tems adequately designed for the building they serve but malfunction-
ing 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; therefore, off-site treatment (including cluster systems)
will be required. Off-site treatment and disposal will be eligible for Federal
funding if:
1) a public health or water resource contamination problem is documented
that cannot be abated by any combination of on-site conventional,
innovative, subcode, flow reduction, or waste restriction methods, or
2) the life cycle costs of off-site treatment and disposal for an indi-
vidual building or group of buildings is less than costs for appro-
priate on-site technologies for the same buildings.
The recommendations apply only to existing systems. EPA is recommending
and funding the decentralized wastewater management approach to meet the needs
of residents around Nest Lake and Green Lake in order to help the community
and system owners protect water quality and the public health. For systems to
be built for new housing, EPA makes no recommendations on the permitting
process, since the Agency does not fund their construction or repair.
Should it be determined by the Applicant during Step 2 that decentralized
off-site treatment facilities are required, the subsequent detailed investiga-
tion of potential cluster system sites will include a hydrogeological study as
well as an archaeological survey of each site.
23
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b. Community Management
In regard to funding privately-owned on-site systems, current EPA regul-
lations (40 CFR 35.918-1) require that
...the grant applicant shall:...Certify that such treatment
works will be properly installed, operated, and maintained
and that the public body will be responsible for such
actions.
This requirement also applies to publicly owned on-site systems.
Within this limitation, communities have a wide range of options availa-
ble. Many of these options are discussed in the Draft EIS, Section III.D.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 facilities
will not operate as intended, thereby causing water quality or public health
problems, or inconvenience for the user. Whether centralized, small-scale, or
on-site, all wastewater facilities have inherent risks, the degree of which is
dependent on skill in facilities design, construction, operation, and mainte-
nance.
"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 county has accepted liability for facilities around Green Lake and
Nest Lake only insofar as permitting and inspection activities minimized risk.
The consequences of facility failure rest with system owners. In building a
sewer around Green Lake, the Applicant essentially would have accepted lia-
bility for all failure except plumbing and house sewer blockages. Under EIS
Alternatives 4, 5, or 6, 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 Applicant'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 EIS Alternatives
4, 5, and 6 were based on the Applicant's active role in improving, moni-
toring, and maintaining all wastewater facilities around Green Lake and Nest
Lake. EPA encourages but does not require such a role. The scope of the
Applicant's responsibilities depends on how much liability for wastewater
facilities it wants, and is legally capable, to assume. EPA will, by funding
facilities planning, design and construction, assist the Applicant in meeting
those liabilities it assumes that reduce the risk of water quality and public
health problems.
To illustrate the range of approaches the Applicant may take, three
management scenarios are described below:
24
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Minimum Management Requirements
The Applicant would act as the recipient and distributor of Construction
Grant funds. Homeowners who wished to improve their on-site facilities would
apply to the Applicant for assistance. After documenting that minimum
requirements for on-site system eligibility are met, the Applicant 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 3 to 5 years, and
would be required to show proof of appropriate maintenance activities as part
of the site inspection. A groundwater monitoring program would include taking
well water samples during the site inspection.
With this approach, the municipalities would not incur any long-term
debt. The Applicant would not necessarily have any responsibility for, or
interest in, permitting 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 or abated. Liability for facility
malfunctions would remain wholly with the owners.
Comprehensive Wastewater Management
This is the approach recommended for adoption by the Applicant. It
involves instituting the small waste flows district concept discussed in the
Draft EIS (see particularly pages 125-130, 177-178, and Appendix K.) 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 insure that future problems
are minor or short-lived. In contrast to the Minimum Management scenario, the
higher level of responsibility resulting from this approach would allow the
authority greater discretion in sharing liability for facility operation with
the resident or building owner.
Watershed Management
The Applicant's concern with prevention and control of water pollution
need not be restricted to wastewater management facilities. During the public
comment period on the Draft EIS, several citizens recognized the significant
role of the Middle Fork of the Crow River in determining the water quality of
Nest Lake and Green Lake. Many expressed an interest in controlling non-point
source pollution generated upstream of Nest Lake and New London. If that
interest is expressed in the form of willingness to pay for additional govern-
mental services, the Comprehensive Wastewater Management scenario could be
augmented by the following functions:
Monitor non-point sources
25
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Control non-point sources
Educate residents and visitors about individual pollution control
practices, costs, and benefits
Inventory the biological resources and tributaries of the lakes
Research the chemical, hydrological and biological dynamics of the
lakes
Coordinate with other local, state, and Federal agencies on pollution
control activities and funding.
c. Cost Estimate
The costs associated with EPA's recommended wastewater management
approaches, including total present worth, capital costs, and estimated user
charges, are presented in Table 2. The costs have been disaggregated by
sewered areas (New London and Spicer) and imsewered areas (Nest Lake and Green
Lake). Back-up data for these costs are presented in Appendix B.
d. Implementation
Specific aspects of implementing an EPA-funded wastewater management plan
in the Green Lake area were discussed in Section VI.E of the Draft EIS. Modi-
fications of those discussions are:
Ownership of On-Site Systems Serving Seasonal Residents - The state-
ment was made on page 178 of the Draft EIS that privately owned sys-
tems serving seasonally occupied residences are not eligible for
Federally funded renovation and replacement. EPA Program Require-
ments 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 responsible
public agency is given "complete access to and control of" the
system. See Comments and Responses under the "Implementation"
heading.
Completion of Step 1 Requirements for the Small Waste Flows Dis-
trict - The Minnesota Pollution Control Agency (MPCA) has favored
the completion of sufficient site analysis to support preliminary
technology selection during Step 1 for all buildings in the Pro-
posed Service Area. The question of whether detailed site analysis
should be considered necessary for cost-effectiveness analysis in
Step 1 or be defined as design work fundable in Step 2 has also been
raised by other state agencies. In response, EPA Region V developed
a new memorandum clarifying project needs documentation (see
Appendix A). It provides that, at most, a representative sampling
(15 to 30%) of on-site systems needs to be developed in Step 1 for a
site-specific data base. The remaining 70 to 85% should be done in
Step 2. Other remaining Step 1 requirements remain as stated in the
Draft EIS.
26
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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 be made up of members of the Lake Shore
Property Owners Association or an independently elected body. The board's
responsibilities 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
Provide an appeal process for owners who object to the technology
selected for their property
Ensure that site analysis and technology selection is conducted by a
multidisciplinary team consisting of persons with knowledge and
experience in soil science; water chemistry; geohydrology; waste-
water characteristics; innovative, alternative and conventional decen-
tralized treatment technologies; and practical aspects of decen-
tralized system construction and maintenance.
Description of the grantee's organization of this review board and the
qualifications of individuals proposed for the Step 2 site analysis and tech-
nology selection should be included in the application for Step 2 funds. The
Step 2 grant will be contingent upon review and approval of the application by
the Technology Section of EPA Region V's Water Division.
It is recommended that the necessary technical expertise be sought from
several sources, such as:
Kandiyohi County Tax Assessment Office, existing staff or new hires
US Department of Agriculture, Soil Conservation Service (Willmar)
Corporate consultants
Individual consultants
University of Minnesota and other institutions of higher learning
Kandiyohi County Planning Commission.
Similarly, if assistance in developing the organizational structure of
the review board and supporting activities is needed, legal and management
consulting services should be sought. Within reason, the costs for these
services will be grant-eligible.
28
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For the purpose of long-term continuity, it is recommended that at least
one person be hired by the Applicant to have an active role in Steps 2 and 3
work, to act as the review board's staff, and to provide technical expertise
in the future.
C. THE NO-ACTION ALTERNATIVE
The No-Action Alternative is broadly defined as an EPA rejection of
Construction Grants applications for the Study Area. More specifically, the
implication of this is that the sewers and treatment plants in New London and
Spicer would not be rehabilitated, replaced, or upgraded. In the unsewered
parts of the Study Area, the Kandiyohi County Tax Assessment Office would
continue to issue permits for new septic tank systems on suitable lots and to
require correction of surface malfunctions.
With the No-Action Alternative, the Village of New London and the City of
Spicer would continue to violate state and Federal effluent discharge require-
ments. The water quality of Woodcock Lake would not improve. Additional
flows to the Spicer STP would be prohibited because it is already overloaded.
The need for improved wastewater management around Green Lake is less
clear. The number of on-site systems experiencing serious or recurrent mal-
functions is small, less than 10%. The impacts of individual on-site systems
on Green Lake water quality are variable but, taken together, the systems have
not been shown to adversely affect the lake.
With the No-Action Alternative, health authorities will continue to have
inadequate information with which to design on-site system repairs appropriate
to the problems and their causes. They are unlikely to have the time, person-
nel, or monitoring capabilities to be able to specify innovative attempts to
solve the problems. The result will be increasing numbers of holding tanks on
small lots and on lots with high groundwater.
No-Action does not mean "no cost." Assuming that existing systems will
fail at a rate of 2% per year and be replaced by a mix of holding tanks,
conventional drainfields or dry wells, or mound systems, the cost associated
with the No-Action Alternative for the unsewered areas (Green Lake and Nest
Lake) only are shown below. Back-up data for these costs are included in
Appendix B.
Total Present Worth $1,576,700
Construction and engineering,
legal, and contingency costs (1978 $) $ 717,300/yr.
Future construction and engineering,
legal, and contingency costs $ 29,200/yr.
Annual operation and maintenance costs $ 62,600/yr.
1980 (first year) average annual $ 250
user charge
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D. OTHER ALTERNATIVES
Many other alternative wastewater management approaches have been consid-
ered in the Applicant's Facilities Plan and in EPA's Draft EIS. Alternatives
considered are listed below along with reasons for their rejection:
FACILITIES PLAN ALTERNATIVES
Alternatives
Centralized wastewater collection
Decentralized treatment by individual
on-site systems, cluster systems, and
mound systems
Combinations of centralized and decen-
tralized collection/treatment options
Land application
Direct reuse of treated wastewater
Discharge of the District's waste
water to the Willmar treatment
facility (9 miles southwest of the
Study Area)
Upgrade or expand existing treat-
ment plants at New London and
Spicer
Install holding tanks in lots
where groundwater is too high
for compliance with the provisions
of the Shoreland Management Act
No-Action
Finding
Accepted as a feasible alterna-
tive. Proposed Action consisted
of centralized collection and
treatment by lagoons
Rejected on basis of soil and
groundwater conditions around
Green Lake
Rejected on the basis of cost-
effectiveness
Rejected on the basis of cost-
effectiveness
Rejected on basis of prohibitive
costs and lack of need for reused
water
Rejected on the basis of cost-
effectiveness
Rejected because phosphorus re-
moval would be required; Phos-
phorus removal not required for
central treatment facility east
of Green Lake
Rejected
Rejected because of overwhelming
need for improved wastewater man-
agement
30
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EIS TECHNOLOGIES NOT ALREADY CONSIDERED IN FACILITIES PLAN
Alternatives Finding
Residential flow reduction by
various devices
Laundry detergent phosphorus
ban
Pressure sewers
Vacuum sewers
On-site treatment and disposal,
various designs
Off-site treatment and
disposal, various designs
(cluster systems)
Expected to be effective in
reducing homeowners' costs for
water supply, water heating, and
wastewater treatment
Expected to result in an unquan-
tifiable (at present time) reduc-
tion in phosphorus entering sur-
face waters through septic tank
tank leachate
Rejected on basis of cost-effec-
tiveness comparison with gravity
sewers. Could be advantageous in
the design of small waste flows
systems
Rejected (on basis of cost) in
preference to pressure sewers for
comparison with gravity sewers.
Could be advantageous in the de-
sign of small waste flows systems
Incorporated in EIS recommenda-
tion for Green Lake and Nest Lake
portions of Service Area
Incorporated in EIS recommenda-
tions for Green Lake and Nest
Lake portions of Service Area
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CHAPTER III
AFFECTED ENVIRONMENT AND IMPACTS OF NO-ACTION
This chapter describes those components of the natural and human environ-
ment that were either integral to discussion of the EIS issues (see Section
I.A) or essential to the understanding of decisions reached in this EIS.
A. SOILS
Soils in the Green Lake Study Area were developed by weathering and
erosion from underlying glacial deposits. The decomposition of vegetation
over time has created a surface layer of rich, dark soils 1 to 3 feet thick.
These soils are underlain by glacial till and sand and gravel deposits several
hundred feet thick. Soils around Nest Lake and northwest of Green Lake con-
sist; of well-drained sand and gravel intermixed with loam; their limitations
for development include rapid perme&bility, steep slopes, and high groundwater
levels. Soils OK Green Lake's south and northeast shore are well- to poorly
drained loamy soils with marshes; slow permeability and a seasonal high water
table are development limitations in these soils. Steep, well-drained loams,
intermixed with sandy soils, are found on Green Lake's north central shore;
steep slopes are limiting factors for development. To the east of Green Lake,
soils are characterized typically by a seasonal high water table; they consist
of poorly drained, loamy glacial outwash underlain by sand and gravel.
Major factors restricting the use of ?ome soils for on-site wastewater
management systems in the Study Area include permeability and high water table
elevations. In view of these restrictions, it is expected that surface mal-
functions and backups of existing onsite systems "ill continue to occur at a
low rate under the No-Action Alternative, Rapi>J, permeability of sand and
gravel mixtures ir< the Study Ar^ suggests that septic tank effluents may not
be treated adequately before emerging into Nest Lake or Green Lake. Survey
data and detailed site investigations indicate that treatment, particularly
nutrient removal, is variable. Under the No-Action Alternative, on-site
systems that provide notably poor treatment would not be located and modified
to provide adequate treatment.
Construction of new dwellings and on oite systems will continue under the
No-Action Alternative. Some erosion will occur as a result of this activity.
B. SURFACE WATER RESOURCES
The surface areas of Nest Lake and Green Lake are approximately 945 acres
and 5,406 acres, respectively. The Middle Fork of the Crow River flows
through both of these lakes. V/oodcock Lake, occupying an area of approxi-
mately 125 acres, is land-locked; it is reported to flow occasionally into
Green Lake (EPA 1974).
As indicated in Figure 4, the combination of tributary inflow and waste-
water treatment plant discharges contributes a significant amount of phos-
phorus to Nest Lake (96% and 80% of total phosphorus loads in 1972 through
1973). It is important to note that non-point phosphorus loading from the
Middle Fork of the Crow River accounts for about one-half of the total load to
33
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Nest Lake. Outflow from Nest Lake, in turn, accounts for approximately three-
quarters of the phosphorus load to Green Lake. The load from the Middle Fork
of the Crow River is classified as non-point because it originates from
nutrient sources upstream of Nest Lake that cannot be pinpointed. These
upstream non-point sources are typical of an intensively agricultural water-
shed. In contrast, the septic tank systems contribute only a small
portion (1% to 8%) of the phosphorus to these two lakes. Kerfoot (1978)
calculated that the daily winter loading of phosphorus into Nest Lake from
the Middle Fork of the Crow River (8.6 kg/day) was approximately 57 times
greater than the loading from all groundwater plumes around the lake
(0.15 kg/day). These groundwater plumes are assumed to be septic tank efflu-
ents. Because of the limited data base available for Green Lake and Nest
Lake, the phosphorus budget derived and presented is considered to be the
best estimation from available data and standard loading methodologies used
by EPA.
The Draft EIS indicated (Table II-5, page 52) that Nest Lake and Green
Lake retain over 50% of the phosphorus loaded into them from various
sources. Nitrogen retention differs considerably between the two lakes, with
Nest Lake retaining 23% of its nitrogen load and Green Lake retaining 56% of
its nitrogen load. The relatively long hydraulic retention time"' of Green
Lake (3.7 years versus 0.5 years for Nest Lake) allows for greater accumu-
lation of nitrogen in sediments and organic materials and also allows for
transformation of nitrogen to nitrogen gas.
Evaluation of four key water quality parameters, including total phos-
phorus, chlorophyll a_, secchi depth, and hypolimnetic dissolved oxygen satura-
tion suggests no measurable trend with regard to the water quality of Green
Lake and Nest Lake over the period from 1972 through 1978. The variation in
water quality over this period is no more than annual fluctuations inherent in
the lake system. The parameters listed above are the bases on which trophic
classifications for lakes are made. According to the simple trophic classifi-
cation system, Nest Lake and Woodcock Lake are eutrophic; these lakes contain
an abundant supply of nutrients and organic matter. According to the same
sy.stem, Green Lake is mesotrophic; it contains a moderate supply of nutrients,
and, compared to eutrophic lakes, produces less organic matter.
Under the No-Action Alternative, Nest Lake arid Woodcock Lake will remain
eutrophic and Green Lake will remain mesotrophic. Data in Table 3 indi-
cate that, under the No-Action Alternative, phosphorus inputs to Nest Lake and
Green Lake will be less than 1% greater than those occurring under normalized
existing (flow) conditions.
The time required for natural processes in a lake to replace the entire
volume of the lake.
34
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TABLE 3. lot si Phosphorus L-adine, (k«/yr) to
Ncs . L.^ke an-J Gr?er< La£3
Under No--^cti.on A
Co£dition ^E'O^^^ Green lake
1972-1973 conditions 4,330 2,605
(wet year)
Normalized existing conditions 3,020 1,963
No-Action 3 , 02^ 1 , 969
The 1972 through 1973 conditions are presented to illustrate phosphorus load-
i.ig:> during a relatively wet year (significant amowt of rainfall and runoff)
a?; compared with an average year. Under the 'Jo-Action Alternative, phosphorus
inputs to Nest Lake ar?, for i»"ricipal, -ru>.>s trial. ^aral ^.'wa^sti", ?r\? irrigation
uses. Water is generally of ejo^d npr.Hty, r.lt>ough h^d.
The results of =>, J"ly I??? pn'-v«y of 97 private wells aroijr.i fjceeo lake,
sponsored by the Green Lake Pr.->p2rtv Own errs Association, in.lic^.ed that
approximately 29% of the wel" . /'t is "'nportant to no to that, informa-
tion on specific well construction and rraintcrance "oald be required to
identify the sources of the well pollution. This in^'r.^Ption wgr, ;tc,>- n-site svs~.e"is will be
funded by EPA, and therefore, is rot lively to be undertaker). Consequently,
the source of groundwater co^ta^iration that "^y ~C-M-- will prob?-h]y ne"er be
Identified.
D- POTULATIOT|_^[D_LW«)_ USE
Approximately 65% of the EIS Service Area population are seasonal resi-
dents, with homes located primarily in the uns^wered areas surrounding Nest
Lake and Green Lake.
35
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The total summer population of the proposed E1S Service Area in tne year
2000 is projected to be approximately 8,400, a 22% increase over the 1976
figure. However, the future ratio of seasonal to permanent residents Is
expected to decline (42% seasonal to 58% permanent in 2000 versus 65% seasonal
to 35% permanent in 1976) Implicit in this assumption is the understanding
that the conversion of seasonal residences to permanent residences will out-
number new seasonal residential construction. A drop of 20% in seasouaJ
population is projected to occur by the design year 2000. New London aud
Spicer will continue to have predominantly permanent populations in the design
year.
Summary estimates of permanent and seasonal population and average annual
growth rates for the period from 1976 to 2000 in the proposed EIS Service Area
are presented in Table 4.
TABLE 4. Population Projections and Average Annual
Growth Rates for Proposed EIS Service Area
Average Annual
Population Growth/Decline Absolute change
Component 1976 2000 Rate (1976-2000) li^L^^l
Seasonal 4500 3600 3% decline -900
Permanent 2401 4807 4% growth -r2406
Total 6901 8407 1% growch +1506
Growth in the EIS Service Area, under tne No-Action Alternative, would be
Limited to sites suitable for on-site systems or to cases where residents can
afford to install and maintain holding tanks. Because of these restrictions,
population may not grow at the rate projected.
Land use in the EIS Service Area consists of: commercial, residential,
and institutional uses in the Village of New London and City of Spicer;
permanent and seasonal single family residences adjacent to Nest Lake arid
Green Lake; agricultural land; and open land consisting of woodlands, wet-
lands, and lakes. The aesthetic and recreation appeal of the area has
resulted in substantial residential development around Green Lake.
With the No-Action Alternative, the types of development found in the
Study Area are unlikely to change from what is present now. Some agricultural
aud open land (principally woodlands) will be converted to residential and
small commercial uses. The distribution and amount of residential and small
commercial development will be strongly influenced by the availability of
soils suitable for on-site sewage disposal. In lakeshore areas, housing
densities are unlikely to increase substantially. An increasing amount of
future development would occur in areas not adjacent to the lakes.
E. ECONOMICS
In 1970, the mean average family (permanent residents only) income in the
Green Lake Study Area was $9,285. Although the Study Area's mean family
income was slightly greater than the county mean, it was substantially less
36
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than the national and state figures of $10,999 and $11,048. Significant
variation in mean incomes of the individual communities within tbe Study Area
were evident, ranging from a low of $6,626 in Irving Townsbip to a high of
$14,385 in Harrison Township. Thus, it appears that while aggregate figures
for the Study Area were indicative of a moderate income area, pockets of low
income households are present.
The costs of No-Action in the ETS Service Area will fal] most heavily on
homeowners who must install holding tanks. A homeowner with four residents
generating 45 gallons per person per clay and paying $60 per 1,000 gallons
pumped would be paying almost $4,000 per year for sewage disposal. Although
this could be reduced substantially by installation of effective flow reduc-
tion devices and by negotiation with the hauler, the cost would still be
substantial. The high cost would be an incentive for the homeowner to find
other, perhaps dangerous, n«;aps 'f disposing of wastewatpr.
As long as their systems do not. fail, other homeowners could maintain
them with very minimal expense, perhaps $60 every 10 years for pumping of
their septic tanks. Residents whose systems fail but who can make a standard
repair would incur a one-time expense of perhaps $1,300. If dosed mound
systems were necessary, costs could be as high as $8,800,
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CHAPTER IV
ENVIRONMENTAL IMPACTS OF THE ACTION ALTERNATIVES
This chapter presents the environmental impacts of the conceptual or
system alternatives incorporated in the Facilities Plan Proposed Action and in
EIS Alternatives 4, 5, and 6. The EIS recommendation that the Applicant
proceed immediately with detailed investigative and design efforts in the
unsewered areas proposed for decentralized wastewater treatment, it is noted,
is not presently a set of explicit construction proposals for each building in
the EIS Service Area. Rather, it is an approach, based on the assimilative
capacity as well as the environmental sensitivity of the local natural
resources, that relies on environmental management in the form of continuing
attention to the use and effects of small-scale systems. This approach also
involves the ability to make balanced decisions about small-scale systems,
including exceptions to standard procedures, in the best interests <>i the
local environment.
The action alternatives evaluated in this chapter include those described
in Chapter II. To summarize:
Action Description
Facilities Plan Proposed Centralized collection of wastewater from New
Action London, Spicer (and corridor between), Nest Lake,
and Green Lake for treatment at a 0.55 mgd stabi-
lization lagoon facility southeast of Green Lake;
effluent discharge to Middle Fork of Crow River
downstream from Green Lake.
EIS Recommendations EIS Service Area to be segmented; New London and
Spicer (and corridor between) to evaluate (under
additional Step 1 funds) wastewater management
options for sewered areas included in EIS Alter-
natives 4, 5, and 6: land application by rapid
infiltration and spray irrigation methods, and
upgrading/expanding existing sewage treatment
plants (STPs); unsewered areas including eastern
half of Nest Lake shoreline and entire shoreline of
Green Lake to proceed with detailed design (includ-
ing site analyses) of decentralized wastewater
management approach under a Step 2 EPA grant.
A. SURFACE WATER
No changes in the trophic status of Nest Lake and Green Lake are antici-
pated as a result of phosphorus loadings associated with the implementation of
any action alternative. This assessment is based on an estimate of major
phosphorus inputs from several sources:
Tributaries (Middle Fork of Crow River to Nest Lake and outflow from
Nest Lake to Green Lake);
39
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Wastewater treatment plants (Belgrade and New London STPs to Nest
Lake via Middle Fork of Crow River and Spicer STP to Woodcock Lake);
On-site (septic tank) systems;
Direct precipitation; and
Immediate drainage around the lakes.
Other sources known to contribute to nutrient loading, such as groundwater,
detritus, waterfowl, and sediments, are less significant than those listed
above.
Future phosphorus loads from STPs and septic tank leachate were calcu-
lated according to the specific conditions associated with each action alter-
native. The immediate drainage contribution is usually relatively insigni-
ficant in this Study Area and was assumed to be constant until the year 2000.
Direct phosphorus loading was derived from average rainfall and concentration
figures.
The total phosphorus inputs to Nest Lake and Green Lake that are associ-
ated with the action alternatives are indicated in Table 5 and differ insigni-
ficantly under normal flow conditions. Phosphorus loads to Nest Lake under
EIS Alternatives 4 and 6 are estimated to be 1% and 5% higher, respectively,
than those under the Facilities Plan Proposed Action. Phosphorus loads to
Green Lake are less than 1% and 3% higher under EIS Alternatives 4 and 6,
respectively, than those under the Facilities Plan Proposed Action; phosphorus
inputs to Green Lake under EIS Alternative 5 would be insignificantly less
than those under the Facilities Plan Proposed Action. The action alternatives
reduce, by as much as 22% for Nest Lake and 15% for Green Lake, the amount of
phosphorus received annually by these lakes under normal existing conditions.
The reductions are not sufficient to improve Nest Lake's fertile (eutrophic)
status or Green Lake's moderately fertile (mesotrophic) status.
Table 5. Phosphorus Inputs (kg/yr) to
Nest Lake and Green Lake under Action Alternatives
(year 2000)
Condition Nest Lake Green Lake
Facilities Plan Proposed Action 2,356 1,680
EIS Alternative 4 2,386 1,686
EIS Alternative 5 2,356 1,673
EIS Alternative 6 2,474 1,725
Normalized existing conditions 3,020 1,963
1972-1973 conditions 4,330 2,605
The 1972 through 1973 loadings are included in Table 5 for comparison to
the existing normalized loadings. It is emphasized that the major difference
in loading between the 1972 through 1973 level and the so-called normalized
level is due to the year-to-year flow fluctuation in the Middle Fork of Crow
River. The period from 1972 to 1973 was a relatively wet year, with a signi-
ficant amount of rainfall and runoff compared with the average year. In
addition, the year-to-year loading fluctuation, which could be over 1,000
40
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kg/yr for Nest Lake and over 500 kg/yr for Green Lake between the 1972 and
1973 level and the normalized level, is much more significant than the reduc-
tion of phosphorus loading resulting from combined effort of upgrading the
STPs and eliminating septic tanks. This means that water quality improvements
(i.e., fertility reduction), gained through implementation of an improved
wastewater management approach, could be eliminated during a wet year. There-
fore, caution must be exercised in assessing potential improvement of the
trophic status of Nest Lake and Green Lake through the implementation of any
action alternative. These results do not Imply that the elimination of septic
tanks is a poor approach to severe eutrophication in Nest Lake and Green Lake.
On the contrary, eliminating septic tanks is the first step necessary to
reverse the trend toward further degradation of water quality in Nest Lake and
Green Lake.
Phosphorus input to Woodcock Lake will decrease dramatically (more than
50%) under any of the action alternatives evaluated in this EIS. This reduc-
tion would result from either the discontinuation of the present Spicer STP
discharge or from the proposed upgrading of the plant to provide effluent
phosphorus concentrations of 1.0 mg/1 or less.
Under the Facilities Plan Proposed Action, pumping station malfunctions
could result in substantial bacterial contamination of the lakes. Rigorous
inspection and maintenance of pumping stations, back-up electrical power
supplies, standby pumps, and an overflow alarm would minimize this possi-
bility. Similar measures should be taken with pumping stations for cluster
systems.
Primary impacts on surface water quality related to the construction of
ST/SAS and the replacement of old systems is likely to result in increased
soil erosion. Similarly, installation of sewers, especially those that pass
under the many small drainage ways leading to the lakes, will increase ero-
sion. Compliance with state and local soil erosion control requirements could
substantially reduce the erosion problem and the subsequent impact on water
quality.
B. GROUNDWATER
The Facilities Plan Proposed Action would eliminate the discharge of
on-site system effluents to the groundwaters around Nest Lake and Green Lake.
The threat of well water contamination from wastewater effluents would be
removed. The elimination of on-site systems from around these lakes and the
attendant loss of groundwater recharge is judged to have a negligible impact
on water levels, since these levels are recharged outside of the Green Lake
Study Area.
Land treatment of wastewaters generated in the existing sewered areas
involve the infiltration of suspended solids, organic matter, and pathogens
into the soil. These pollutants are very unlikely to reach the buried outwash
aquifer because the overlying impermeable confining layer provides an adequate
barrier to their entry into potable water supply sources. Depth to this
aquifer is generally more than 20 feet; such pollutants are normally removed
by infiltration through approximately 5 feet of soil.
41
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The decentralized wastewater management approach for unsewered areas
would detect and reduce or eliminate plumes in the shallow groundwater around
Nest Lake and Green Lake. The plumes can change, with time, in size, shape,
and strength, depending on wastewater or groundwater characteristics. At
present, wells penetrating these plumes, particularly ungrouted wells, could
receive nitrate and other chemical loads.
The decentralized approach would eliminate the hazard to drinking water
through 1) inspection of existing wells and filter fields, 2) sampling of
wells that are down-gradient or within 50 feet of septic tanks or soil absorp-
tion systems, and 3) selection of on-site or off-site measures to stop actual
or possible drinking water contamination.
These repair measures might include elimination of dry wells and filter
field repair or relocation. Cluster system sites would receive geohydrologic
surveys, and well water would be monitored at regular intervals. In all cases
except for new construction on lots with more than 5 feet to groundwater,
costs for these measures are included among the analysis or maintenance costs
of the decentralized approaches Alternative (see Appendix B). Also, actual
repair (grouting, etc.) of wells may often prove less expensive than treatment
modifications.
C. POPULATION AND LAND USE
Population projections used for the design of alternatives in the EIS
were based on recent growth trends and data from a variety of sources. The
projections did not incorporate any constraints or inducements related to the
amount of developable land or other complex economic, demographic or land use
factors.
Examination of development potential as an impact of centralized sewage
treatment, however, suggests that the amount of developable land and the den-
sity of development will both be greater with sewers than without. The EIS
estimates that the Facilities Plan Proposed Action centralized wastewater
facility could have the impact of inducing 5 to 10% more population growth,
and development of 30 to 40 more acres than would occur under baseline condi-
tions. This is a modest amount of induced growth and reflects the limited
amount of vacant developable land in the EIS Service Area. As illustrated in
Figure 11-14 of the Draft EIS, the vast majority of lakeshore lots are
developed. This fact, coupled with the limited amount of public lakeshore
access (2.3%), development limitations of wetlands, steep slopes, seasonal
high water table, and a limited market demand, will significantly limit second
tier development. These limitations account for the low development potential
of the decentralized wastewater management approach for the presently
unsewered areas.
Under the decentralized approach for Nest Lake and Green Lake, developers
might wish to acquire unbuildable shoreline lots as multifamily access and
recreation sites.
D. ECONOMIC IMPACTS
Under the assumption used in the Draft EIS that collector sewers would be
80% eligible for Federal and State Construction Grants, the residents of
42
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Spicer and New London would pay approximately the same for their share of the
Facilities Plan Proposed Action ($160) as they would for their part of EIS
Alternatives 4, 5, or 6 ($180-190). As shown in Table 6, the economic impact
of these homeowners' costs for these communities are nearly the same regard-
less of alternatives.
For the shoreline communities, the decentralized alternatives have esti-
mated homeowners' costs that are 40 to 50% less than the Facilities Plan
Proposed Action.
The difference in economic impacts between the Facilities Plans Proposed
Action and the EIS recommended alternatives are relatively small as can be
seen in Table 6. However, the assumptions of 80% sewer eligibility underlying
these user charges and economic impact, figures is not valid because insuf-
ficient need for sewers has been found for the shoreline communities. The
relatively low level of problems can be solved by more cost-effective means.
43
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Table 6. Financial Burden and Displacement Pressure of the Facilities Plan
Proposed Action and Remaining EIS Alternatives.
Location *
Spicer and New London
Alternative 4 - Rapid Infiltration
Alternative 5 - Spray Irrigation
Alternative 6 - Treat and Discharge
Limited Action - Alternative 6
without sewers for the West
Shore of Green Lake
1980 Average
Annual
Homeowners '
Cost
140
150
180
130
Displacement
Pressure
4-6%
4-6%
4-6%
4-6%
Financial
Burden
12-20%
12-20%
20-25%
12-20%
jGreen and Nest Lake Shorelines
!25% Cluster, 37.5% ST/SAS Replacement 100 <4% 6-12%
150% ST/SAS Replacement 80 <4% 6-12%
Facilities Plan Proposed Action
Spicer and New London 160 4-6% 12-20%
Shorelines 170 4-6% 12-20%
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CHAPTER V
PUBLIC AND AGENCY COMMENTS
Substantive public and agency comments were received on the Draft
EIS. They have been compiled and summarized in this chapter. Comments
offered through testimony at the public hearing on the Draft EIS (4 August
1979) and through written correspondence, and that are essential to the
EIS decision-making process, are addressed herein. The comments and
appropriate responses are organized by Draft EIS subject areas, including:
Documentation of need for improved wastewater management facili-
ties (including field collection efforts)
Water quality
Development of the alternatives
Implementation
Cultural resources
Economic impacts
Recreation
Population and land use
Implementation
All substantive written comments on the Draft EIS are included in Appendix
D. Citizens who offered substantive comments on the Draft EIS at the
public hearing are listed below; numbers which follow the citizens' names
identify the comments addressed in this chapter.
Name Agency Comment
William Bigler Seasonal resident, Green 3
Lake
Samuel Claassen Rieke Carroll Muller 1, 3, 4, 5,
Associates, Inc. 11, 13, 24,
30, 31
Russell Dykema Board Member, Green Lake 32, 33
Association
W. A. Fischer, Chairman Green Lake Sanitary 3
Sewer and Water District
Roger Machmeier University of Minnesota 25, 26
Extension Agent
45
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Name Agency Comment
Douglas Noyes Noyes Engineering 3
Service
James Tiede Resident, Willmar 25
Individuals offering substantive written comments on the Draft EIS
are listed below:
Name Agency Comment
Craig Affeldt Minnesota Pollution 13, 14, 15, 16,
Control Agency 17, 18, 19, 20,
28
W. G. Emrich US Department of 34
Transportation, Federal
Highway Administration
Russell Fridley Minnesota Historical 22
Society
David Jervis U.S. Department of 22, 37
Interior
Charles Kenow Minnesota State 21
Planning Agency
Rodney Massey Minnesota Pollution 9
Control Agency
Virgil Olson Kandiyohi County 6, 7, 8, 27
Board of Commissioners
A number of other people commented finally on the EIS or participated
in the question and answer period following formal comments. This parti-
cipation and interest is appreciated. Comments not addressed in this
chapter either involved support for one alternative or another, or re-
flected differences of opinion between commentors. While interesting,
such comments are not substantive. Copies of the public hearing trans-
script can be reviewed at EPA's office in Chicago, Illinois.
NEEDS DOCUMENTATION
C. The 1977 well water analysis sponsored by the Green Lake Property
1 Owners Association was indicated by the Draft EIS to be inconclusive
in terms of documenting pollution caused by human waste. Did EPA
sample these wells to determine if human wastes were the cause of any
contamination? If not, why not? [Claassen]
R. Serious consideration was given to performing a well sampling pro-
1 gram for residences on Green and Nest Lakes. Obviously, such a study
would have increased Draft EIS preparation time significantly. In
light of GLSSWD's expressed urgency for completion and publication of
the Draft EIS, the decision was made to recommend the well sampling
program a part of the Step 2 work. We believe that this study is
necessary for detailed systems design.
46
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C. A lot of EPA conclusions rest on the scientific validity of phos-
2 phorus measurements that have been made during preparation of the
Draft EIS. The report ought to contain some reasonable range into
which the validity of this study should fall. Is it a factor of 3 or
5 or 10%? Is the Septic Leachate Detector a new device or an old one
with a well established record in measuring phosphorus flows into the
lake? [W. Johnson]
R. The Septic Leachate Detector (SLD) used during the preparation of
2 this EIS does not measure phosphorus. It locates on-site system
leachate, or "plumes", by detecting the organic and inorganic con-
stituents normally found in wastewater effluents. Groundwater sam-
ples taken from the sediments in the vicinity of plumes detected by
the septic snooper were subsequently sampled for phosphorus by con-
ventional methods. The SLD was not used in the EIS process in any
other way than to locate individual plumes.
The use of SLDs such as ENDECO's Septic Leachate Detector is still
experimental. Technical questions have yet to be fully resolved con-
cerning the universal presence of brighteners and whiteners in waste-
water from individual homes, the effects on plume strength of fluo-
rescent compound absorption by different soils, the effects of plume
configuration on plume detectability and correlations between plume
strength and nutrient breakthrough. EPA is conducting additional
research on these topics to improve both the applicability of the
equipment and interpretation of the data it generates.
Because it is possible that the groundwater samples taken from the
sediments could have missed actual plumes, thereby giving low phos-
phorus values, EPA did not apply SLD nutrient data in the calculation
of phosphorus loads from septic tank systems. The calculation of
septic tank loadings was based on assumptions developed by the Na-
tional Eutrophication Survey (EPA 1972). The NES assumes that the
phosphorus load to lakes from septic tank systems within 300 feet of
the shoreline is 0.25 pounds (0.11 kilograms) phosphorus per person
per year. By this assumption, and accounting for both permanent and
seasonal residents, the estimated annual phosphorus load to Nest Lake
from septic tank systems is 42 kg/yr. (1% of total phosphorus load).
Similarly, the annual phosphorus load to Green Lake from septic tank
systems is 208 kg/yr. (8% of the 1972-1973 total phosphorus load or
10.6% of the average year load). Estimated total phosphorus loadings
to these lakes are shown in Figure 4 of this Final EIS. Kerfoot
(1978) estimated total annual phosphorus loading from plumes identi-
fied by the SLD to be approximately 22 kg/yr. for Nest Lake and 33
kg/yr. for Green Lake. Phosphorus loads from on-site systems, based
on observed plumes, reported by Kerfoot are less than 1% of the total
phosphorus load to Nest Lake and 1.7% of the average year total
phosphorus load to Green Lake.
In response to the comment, an appropriate range in which actual
phosphorus loadings from on-site systems may fall would be derived
from both SLD and NES data. This range is: less than 1% to 1.5% for
Nest Lake, and 1.7% to 10.6% for Green Lake. Nutrient data estimated
47
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by Kerfoot would represent the low end of the range, while nutrient
loading data based on the NES assumption cited above would represent
the high end of the range. The latter data are believed to be con-
servatively high because it is assumed that phosphorus in wastewater
effluents from all on-site systems (within 300 feet of the shoreline)
moves into the lake. This assumed phenomenon is not confirmed by
soil and groundwater data collected or reviewed during the EIS pro-
cess .
EPA's detailed investigations of 17 on-site systems in three mid-
western states, reported elsewhere1, indicates that phosphorus loads
lakes from individual septic tank systems along shorelines is highly
variable, depending on soil and groundwater conditions, proximity to
the lake, size of the soil absorption system, and amount of sewage
generated. In conjunction with a Generic EIS for Wastewater Manage-
ment in Rural Lake Areas, EPA is developing methods for rapid detec-
tion and analysis of groundwater plumes before they enter lakes. It
is hoped that these methods will provide an affordable means to make
better, site-specific estimates of nutrient input to lakes from sep-
tic tank systems.
C. November was a poor time of year to conduct a sanitary survey. The
3 ground was frozen, seasonal residents were not there, and this is not
the time of year that systems pond. [Fischer, Noyes, Claassen]
R.3 November is not the optimal time. For lake areas with high seasonal
populations, the best time would be in late spring and early summer.
At the time EPA made the decision to do the survey, it was considered
more important to get data quickly than to wait eight to ten months.
Besides the Green Lake survey, EPA has conducted four other sanitary
surveys in rural lake communities. In all cases, most of the infor-
mation collected regarding system performance comes only from the
residents. In general, most residents are concerned with good sani-
tation and are willing to offer whatever knowledge they have. It
matters little what time of year this most valuable source of infor-
mation is sought. A reticent resident will be as unhelpful in
November as in July.
With the exceptions of intermittent direct discharges and seasonal
surface ponding, information collection during site inspections is
not hampered by cold weather. Lot size, elevation above a lake,
locations of wells and septic systems, proximity of neighbors, and
surface drainage patterns all contribute to the surveyor's interpre-
tations. This type of information is available upon inspection year
round.
Final Environmental Impact Statements, Case Study No. 1 - Crystal Lake
Area Sewage Disposal Authority, Benzie County, Michigan; Case Study
No. 4 - Steuben Lakes Regional Waste District, Steuben County, Indiana;
and Case Study No. 5 - Otter Tail County Board of Commissioners, Otter
Tail County, Minnesota.
48
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It was erroneously stated in the Draft EIS that only permanent (year-
round) residents were interviewed. The sanitary survey covered 75
septic systems in 63 interviews. Of the 75 systems, 30 were used
seasonally, including 8 systems in resorts. The surveyor made every
effort to find seasonal residents on weekends while they were closing
up their cabins or pulling docks out of the lake.
The survey covered 22, or 6% of the seasonal residences (non-resort)
and 45, or 30%, of the permanent residences. All were lakeside pro-
perties. Thus, while the survey is heavily biased toward residences
that are most likely to have problems, the seasonal population was
represented. In fact, 3 of the 12 problems recognized were reported
by seasonal residents: two systems with occasional back ups and one
with recurrent back ups.
C. The surveyor was a stranger to the area and probably did not get full
4 cooperation from the residents. [Claassen]
R. This is possible, but it is interesting to note that the surveyor
i\ found 12 "problems" representing 16% of the homes surveyed around
Green Lake. Information presented by Mr. W. A. Fischer at the August
1979 public hearing shows that his questionnaire to people around the
lake found problems with 14% of those surveyed. Mr. Fischer lives on
Green Lake and is known by most residents. This indicates that EPA's
surveyor did get reasonable cooperation.
C, The Septic Snooper survey was conducted at a very poor time, in
5 March. There was 3 feet of ice cover. Only permanent residences
would be contributing any kind of pollution. Cold temperatures would
inhibit bacteria growth or even kill them. Even if the effluent
plumes persist for 4 to 6 months after summer residents leave as pre-
dicted by EPA, March is 7 months after Labor Day, and summer plumes
were probably gone. [Noyes, Claassen, Tiede]
R As with the sanitary survey, the decision to proceed with the Snooper
~> survey put more emphasis on trying to get the field work done and
acquiring some information than to wait for the optimum time for the
most defensible information.
We have learned some very interesting things from both the winter and
summer Septic Snooper surveys and related studies at Green and Nest
Lakes and in the six other communities where EIS's are being done.
For instance, at Otter Tail Lake, Minnesota EPA performed a winter
Snooper survey right after the Green Lake Snooper survey. Because
nearly all of the permanent residences showed evidence of plumes
under the ice, EPA surveyed again in the summer to see if the summer
residents also generated plumes in the lake. There were far fewer
plumes in the summer than in the winter. The difference points out
the dynamic nature of effluent plumes. It also reflects the results
of several interacting factors:
During snow melt, groundwater inflow to lakes is at its highest
rate of the year. This carries effluent plumes into the lake
that otherwise may not flow directly to the lake.
49
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* The direction and rate of groundwater, and therefore plumes, can
be altered by the level of a lake. At a high lake level, the
groundwater flow will not be as fast and can even be reversed.
Seasonal or year-to-year variations in groundwater flow in the
nearshore areas can result in the ch -.appearance, then reappear-
ance, of some effluent plumes.
The strength of a plume that is entering a lake, and therefore
its detectability, x^- strongly determined by mixing with the
lake water. EPA has observed plumes during a morning calm that
were not detectable when afternoon breezes make waves on the
windward shore. During the winter, ice cover reduces mixing,
thereby magnifying plumes relative to their summer strength.
As to the 4 to 6 month duration of plumes, it is now believed that
too many variables affect the detectability of effluent plumes to
justify use of this estimate. The actual duration period for a given
system, or the average for al] systems around a lake, may vary sub-
stantially from this original estimate. It may well be that we
detected oniy plumes /rom permanent residences. The pattern of
effluent plumes, arid the presence of effluent or effluent-like sub-
stances in surface runoff remain highly significant and should be
used to guide future site analysis.
In regard to the effect of cold weather on viability of bacteria, EPA
leeis that the cold may have prevented regrowth of bacteria from sur-
face or runoff sources. These concentrations may well be lower than
what would be found in the summer. All of the "stream source" plumes
<~ound by the Snooper survey should be scrutinized for the sources of
contamination, and any significant sources should be controlled.
Based on sampling of "groundwater ' plumes here and in many other
locations, and based on many stuche-S reported in the literature, EPA
believes that effluents moving through most soils, even saturated
soils, contain very few bacteria or viruses after 10 to 20 feet of
travel. The fecal coliform counts in surface water samples collected
in the immediate vicinity of "groundwater" plumes probably represent
background conditions.
C. Will EPA be making another investigation of increased algal growth in
6 Green Lake? We have noticed considerable increase on the lake bed
along our shore since 1972. [Olson]
R. EPA will not conduct any future investigation of algal growth in
6 Green Lake. Ihe increase in algal growth along the lakefront pro-
perty noted in the comment may or may not be associated with on-site
wastewater management systems. Several investigations of algal
growth in lakes, conducted by EPA over the past three years, indicate
that such growth may be caused by the movement of nutrient-rich
on-site system effluents into surface water. Selection of off-site
treatment (holding tanks or cluster systems and other small-scale
measures) would achieve decreases in the occurrence and density of
these growths. Improvement would also occur where repair of on-site
-------
facilities (elimination of dry wells or relocation of filter fields)
reduce or eliminate effluent plumes reaching the lake. Research on
measures to change the flow and quality of effluent plumes could lead
to additional mitigation of these growths. Examples of such measures
include, but are not limited to, removing garbage grinders, flow
reduction, aerobic treatment, non-discharging toilets, capture of
effluent plumes for lawn irrigation, and Minnesota's laundry deter-
gent phosphate ban (already in effect).
C. Will the lot-by-lot survey (conducted after the EIS process) include
7 a careful investigation of septic tanks, drainfields, wells, arid
soils on each lot (not just samples) in order to detect problems
which the Septic Leachate Detector did not identify? [Olson]
R. Every existing developed, unsewered lot around Green Lake and Nest
7 Lake (eastern half only) will be subject to the Step 2 site analysis
procedure described in Section II.B.2 of the Final EIS. This analy-
sis involves a sequential investigation of problems associated with
on-site wastewater management systems, including back-ups, surface
malfunctions, inadequate separation distance to wells and lakeshore,
and suspected or known inadequacy of septic tank or drainfield size.
Not all developed lots will be subject to the same range of tests,
since some problems will be solved sooner (on the basis of fewer
tests) than others. In Appendix A of the Final EIS, EPA estimates
the frequency of need to conduct various tasks in the detailed site
analysis and presents costs associated with these tasks.
C. Does EIS Alternative 6 address the problem of nitrate-nitrogen in
8 private wells along the east shore of Green Lake? Private tests have
indicated high contents of nitrate-nitrogen (figures for SSU numbers
55 and 73) which should alert EPA to potentially serious problems.
[Olson]
R. All of the decentralized wastewater management approaches for Green
8 Lake, including EIS Alternatives 4, 5, and 6, will address the pro-
blems of elevated and excessive nitrate-nitrogen levels in private
water supplies around the lake, which were identified in the 1977
well survey sponsored by the Green Lake Property Owners Association.
Ninety-seven of the approximately 600 wells (16%) were sampled during
the survey. During Step 2 of this project, the Applicant will con-
duct a survey of 100% of the wells around Green Lake that will in-
clude an interview with homeowners to determine the suitability of
individual wells, and an inspection of each well for proper seal,
vent, drainage, and grouting to determine the extent to which ground-
water quality is protected by proper well construction. The costs
associated with this survey have been included in the site analysis
costs (Appendix B, Final EIS), which are themselves included in the
revised costs for the decentralized wastewater management approach
for Nest Lake and Green Lake. As noted in Section II.B.2 of the
Final EIS, detailed site investigations around these lakes will also
include analyses of well water samples for fecal coliform bacteria,
nitrates, and fluorescence (indicates presence of detergents in
groundwater).
51
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In requiring a survey of all wells around Green Lake, EPA has recog-
nized the need to find solutions to groundwater quality problems that
may or may not be caused by inadequate on-site wastewater treatment.
EPA's inclusion of resident interviews in the comprehensive Step 2
well survey is based on the Agency's observation that valuable infor-
mation regarding well construction comes only from residents. As
noted in an earlier response, most residents are concerned with good
sanitation and are willing to offer whatever knowledge they have
about their wells. The requirement that all wells be inspected is
based on the fact, confirmed by sanitarians across the nation, that
groundwater contamination can be caused as easily by improper well
construction (no grouting, malfunctioning vent, etc.) as by waste-
water infiltration. This does not imply that the elevated nitrate
nitrogen levels found in 2 of the 97 wells sampled in 1977 are no
cause for concern or that they are not caused in fact by malfunction-
ing on-site systems. Rather, EPA's comprehensive approach here
focuses on a step-by-step determination of the cause(s) and degree of
groundwater contamination. This information will enable citizens to
avoid future groundwater quality problems by providing information on
the suitability of their wells, and will be useful in the design of
site-specific, cost-effective solutions to existing problems.
C. The Minnesota Pollution Control Agency and EPA have different defini-
9 tions of "need" for wastewater treatment. EPA is using performance
standards that require positive, physical evidence of failure of a
system. MPCA feels that a second group of inferred-failure criteria
should be added which include the same design factors used in permit-
ting new systems. If a system does not satisfy these design factors,
specifically:
Soil percolation rates
Slope
Setback distances from wells, property lines, waterfront
Depth to groundwater table or bedrock
Sizing of septic tanks and drainfield,
it can be determined that a particular on-site system will probably
fail in the near future, or that it is now failing without any obvi-
ous evidence of failure. [Massey]
R. EPA began this EIS and six similar EISs using the construction-ori-
9 ented approach that MPCA suggests. Because of a lack of information
concerning on-site conditions, we used available soils data and
average lot sizes to designate segments where off-site treatment
would be needed. Groups of houses on lots averaging less than one-
third acre average or on soils with high groundwater or slow perme-
ability were assumed to require off-site treatment. This was pro-
vided in our initial EIS alternatives either by various conventional
or alternative sewers in the "centralized" alternatives, or by
cluster systems in the "decentralized" alternatives, such as Alterna-
tives 4, 5, and 6 in this EIS.
52
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Selection of any centralized alternatives over the decentralized
still required some proof that existing on-site systems were causing
public health or water quality problems. The aerial photography
surveys failed to give us this proof. In August of 1978 the decision
was made to get this proof through field studies. The field studies,
although not perfectly timed, also failed to show justification for
sewers and, indeed, brought into question the "need" for any off-site
treatment at all. Hence, the Limited Action Alternative, which
assumes no need for off-site treatment, was developed.
In all of the communities studied, the discrepancy was great between
construction violations and detectable public health and water qual-
ity problems. This brings into serious question the validity of con-
struction standards as a means for predicting on-site system failure,
particularly when the systems are already in place where their actual
conditions and effects can be measured.
What then is the use of construction standards if they do not predict
system failure? EPA is not refuting the utility of construction
standards for the following purposes:
Permitting new systems
Designing system repairs or replacements where the standards
can be met on an existing property
Focusing field studies on those sites with the highest
probability of failure
Predicting future failures when a high proportion of other
systems in similar site conditions or with similar nonconfor-
ming designs are failing.
EPA does not agree with the use of the current design standards to
designate "need" in lieu of actual local performance data that are
directly correlated with design factors that the state and local
authorities believe to be significant.
MPCA and EPA have worked closely to develop policy on determining
wastewater management needs for rural communities. The policy state-
ment, "EPA Region V Guidance, Site Specific Needs Determination and
Alternative Planning for Unsewered Areas", is included as Appendix
A.
C. I have been a resident on Green Lake for 25 years. When I bought my
10 lot, I spent $950 for fill and filled my lot 4-1/2 feet. I did this
because I was not sure my septic tank system would work on the exist-
ing lot level. Since then, I have had no problem with my septic
tank. The water from my 67-foot well, which was just tested two
weeks ago, is pure. I think a lot of problems exist because lots are
not filled to the proper level for suitable septic tank usage.
[Dahl]
53
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R. Comment noted.
10
ECONOMIC IMPACTS
C. On page 163 of the Draft EIS, EPA calculated user charges are said to
11 include reserve funding equal to 20% of capital costs. Isn't this
high? Is it included in the cost-effectiveness analysis? [Claassen]
R. The reserve fund was calculated as 20% of the local share of capital
11 costs. This was not clearly stated in the Draft EIS. The reserve
fund is not included in the cost-effectiveness analysis. If it were
included, it would make the centralized alternatives, which are more
capital intensive, even less cost-effective compared to the decen-
tralized alternatives.
WATER QUALITY
C. Where is the phosphorus in the upstream portion of the Middle Fork of
12 the Crow River (above Nest Lake) coming from? [W. Johnson]
R. Phosphorus loads upstream of Nest Lake originate from point sources
12 and non-point sources. In the Draft EIS, the combined phosphorus
load from these sources was estimated to be 96% of the total phos-
phorus input to Nest Lake from a variety of sources (see Figure V-l,
Draft EIS). In the Final EIS (Figure 4), this nutrient load has been
disaggregated into its point source and non-point source constit-
uents: 567o of total phosphorus load (2,351 kg/yr.) to Nest Lake from
the Middle Fork of the Crow River and 40% (1,679 kg/yr.) from efflu-
ents discharged at the Belgrade and New London sewage treatment
plants.
On the basis of available data, it is not possible to disaggregate
further the phosphorus contribution (56%) from non-point sources into
specific constituents. In view of the fact that the major land use
throughout Nest Lake's 122 square-mile drainage area is agricultural,
it is safe to assume that the majority of these non-point sources are
associated with farming operations.
C. The executive summary of the Draft EIS asserts that none of the
13 alternatives would affect the water quality of Green Lake or Nest
Lake. This is incorrect. [Affeldt]
R. The statement should have referred specifically to the trophic status
13 of these lakes, not to the more comprehensive term, "water quality."
Upgrading the New London and Belgrade treatment plants or applying
this wastewater to the land will reduce organic, bacterial, and
nutrient inputs to Nest Lake and, indirectly, to Green Lake. Finding
and upgrading the sources of surface or runoff effluent plumes around
the lakes will abate localized water quality problems.
C. It should be clearly stated that the tributary nutrient loads to Nest
14 Lake and Green Lake include contributions from municipal wastewater
discharges in Spicer, New London, and Belgrade as well as non-point
source contributions. [Affeldt]
54
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R. This has been clarified in Figure 4 of this Final EIS.
14
C. Appendix C-10, referred to on page 53 of the Draft EIS, is missing.
15 [Affeldt]
R. The information in C-10 was presented in Figure V-l on page 150 and
15 the appendix was eliminated because it would be redundant. However,
reference to the appendix was mistakenly not taken out.
C. In the discussion of lake water quality on page 53, was a trend in
16 water quality expected to be seen in the data reported? Available
data do not appear adequate to detect a trend. [Affeldt, Tiede]
R. Residents have made stdtf,per>t'_ that the water quality in Green Lake
16 has deteriorated. Available d-it& were presented and analyzed to see
if the subjective intcrmcstj on, such as residents claims, could be
supported by objective data. The conclusion, as stated on page 53,
is that there is no definite trend and that the variations seen for
the parameter listed are within the range expected from seasonal and
annual fluctuations.
It may well be that a more extensive data base would prove or dis-
prove that water quality is changing. To the contrary, we concluded
that there is no detectable change.
C. In the Chapter II description of water resources, normalized stream
17 flow data are confused with the 1972-1973 average daily flow derived
from measurements reported in the National Eutrophication Survey
reports for Green Lake and Nest Lake. [Affeldt]
R. Table II-3 on page 48 and the discussion of tributary flow on page 49
17 present average flow data for the periods of record of several gaug-
ing stations along the Middle Fork of the Crow River. Reference to
the 1972-1973 data was unnecessary and confusing at this point.
The sampling period for the NES study was wetter and had higher
runoff than average. The EIS uses actual daily flows and nutrient
concentrations from the NES report to calculate observed conditions
in a wet year, as shown in Table V-l on page 152 of the Draft. This
was done to illustrate the possible range in annual variation due to
climatic conditions. This gives the expected improvement (based on
average or "normalized" conditions) for various alternatives some
perspective, as shown in Table V-l and the accompanying Figure V-2.
C. The ranking of nutrient sources presented on page 149 was not sup-
18 ported in earlier portions of the Draft and is in conflict with the
results of the National Eutrophication Survey. [Affeldt]
R. Some confusion has been caused by equating tributary sources of
18 nutrients with non-point sources. The tributary sources (primarily
the Middle Fork of the Crow River as it enters Nest Lake) contain
nutrients from both point and non-point sources. Green Lake receives
the majority of its nutrient loads from Nest Lake via the outlet
55
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channel of Nest Lake. Because of the complex physical, chemical, and
biological processes involved in Nest Lake, the exact breakdown of
phosphorus sources in the loading from Nest Lake to Green cannot be
determined. As a result, the loading is labeled as "outlet from Nest
Lake" instead of "non-point sources" in Figure 4. In order to demon-
strate the significance of non-point sources, a composite phosphorus
loading to the three lakes as a whole observed in 1972 through 1973
is presented in the ranking as follows:
Nonpoint sources (except immediate drainage) =2,447 kg/yr (44%)
Point sources (New London, Spicer, and Belgrade STPs)
=2,274 kg/yr
(40%)
Direct precipitation = 514 kg/yr (9%)
Septic Tanks (adjacent to Nest and Green Lakes)
= 237 kg/yr (4%)
Immediate drainage = 155 kg/yr (3%)
The ranking for individual lakes can be seen in Figure 4 which shows
that the ranking varies among the three lakes.
These figures represent a composite, or total, phosphorus budget for
Nest Lake, Green Lake, and Woodcock Lake. Therefore, non-point
source loading of these lakes via the Middle Fork of the Crow River
is counted only once--for Nest Lake (Woodcock Lake is landlocked).
The influx of phosphorus to Green Lake via the outlet of Nest Lake is
considered to be an internal loading in the estimates listed above.
C. Mean flows presented in the reports of the National Eutrophication
19 Survey are for a "normalized" or average year, not the period from
October 1972 to October 1973. Subsequent references to these stream-
flows should be corrected. [Affeldt]
R. Figure V-l of the Draft EIS is our estimate of observed conditions
19 based on 1972 through 1973 NES data. It uses actual flow data for
the tributaries, not normalized data.
C. There are apparent errors in Table V-l listing the phosphorus inputs
20 to Nest Lake and Green Lake. [Affeldt]
R. We have checked the calculations and they are not in error. Please
20 note that the 1972 through 1973 loads are based on observed tributary
flow data and the rest are based on normalized flow data.
The differences between our No-Action Alternative and NES estimates
of loads for an average year (normalized data) are slight. The
difference amounts to 3.6% for Green Lake and 0.2% for Nest Lake.
This difference for Green Lake is due to the indirect phosphorus
contribution from the Spicer sewage treatment plant, which was not
included in our phosphorus budget because the overflow from Woodcock
56
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Lake to Green Lake has not been well documented on a long-term basis.
As to Nest Lake, the 0.2% difference is insignificantly small for any
concern.
C. It makes little sense to pursue the selection of a wastewater collec-
21 tion and treatment system that will encourage growth beyond existing
services and do little to enhaiice the water quality within Green and
Nest Lakes without first developing a management plan to limit non-
point source pollution from the Crow River. This issue must be
addressed before additional Step 1 studies are commenced. [Kenow]
R. Wastewater management approaches recommended by EPA for the sewered
21 and unsewered communities in the Green Lake Study Area do not induce
growth that will overtax existing services. They are considered to
be cost-effective solutions to identified wastewater management
problems. EPA agrees that the development of a management plan to
limit non-point source pollution from the Middle Fork of the Crow
River is appropriate. Phosphorus loadings to Nest Lake from the
river are recognized in this EIS to be considerable. However, the
management of non-point source pollution cannot be funded under
provisions of EPA's Construction Grants Program.
CULTURAL RESOURCES
C. An archaeological survey should be conducted by a qualified archaeo-
22 legist on areas likely to be disturbed by the construction of new
wastewater management facilities to determine the existence of pre-
historic archaeological sites which are not yet identified.
[Fridley, Jervis] Surveys should be conducted during facilities
planning, rather than merely prior to construction, so that results
can be input to facilities planning. [Massey]
R. Comment noted. As described in Section II.B of the Final EIS, the
22 Applicant will be required to complete an archaeological survey,
along with a detailed hydrogeological investigation of potential land
application sites and any required community (cluster) treatment
sites. This requirement is made in recognition of the Green Lake
area's high archaeological value, which has been determined through
previous inventories of cultural resources. The archaeological
survey requested by the commentor is recommended by EPA only after:
1) it is determined by the Applicant (during additional Step 1
efforts) that land application is preferable to upgrading and/or
expanding the New London and Spicer STPs; and/or 2) the need for and
location of cluster systems around Green Lake and Nest Lake has been
determined by the Applicant during Step 2.
DEVELOPMENT OF ALTERNATIVES
C. I am familiar with a cluster system serving residents on Lake Wawa-
23 see, Indiana. This lake is approximately the same size as Green
Lake, but must have 10 times the population. Lots are approximately
25 to 50 feet wide. The cluster system is working fine. Individual
water wells are not polluted. I just wanted to pass on this informa-
tion to describe a system that involves less exorbitant costs than a
large sewer system around our lake. [Bigler]
57
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R. Comment noted.
23
C. Alfalfa is a poor crop to use for removal of nutrients in a spray
24 irrigation system. Flood irrigation of reeds, canary grass, or
brome-grass would be preferable for nutrient uptake, energy require-
ments, land required, and avoidance of wastewater aerosols. Costs
for the land application facility seem very high as estimated in the
EIS. [Machmeier] The design assumptions for land application in EIS
Alternatives are not stated [Classen].
R. Many design decisions would have to be made regarding land applica-
24 tion systems based upon soils, geohydrologic and other more detailed
evaluation of design parameters than was attempted for the EIS. The
two land application alternatives were developed to see if land
application is feasible in the Study Area and to estimate the cost
differential between these application methods and other wastewater
treatment techniques. This was accomplished to the level of accuracy
intended. Design assumptions are available from EPA in a separate,
unpublished contractor's report.
Flood irrigation is a viable land application method where topography
permits. While there might be suitable sites within a reasonable
distance of Spicer and New London, most of the topography is too
rolling; grading costs for flood irrigation may be prohibitive.
Again, detailed evaluations should answer concerns such as this.
C. The cluster systems seem to be considerably over-designed. The
25 prices are quite high. [Machmeier]
R. The designs are conservative as a response to the limited amount of
25 site information collected. Site information was collected to
develop a conclusion on feasibility of cluster systems. We have
concluded they are feasible around most of Green Lake. The actual
design of cluster systems should be preceded first by the establish-
ment of need for off-site treatment during the house-to-house site
analysis and secondly by geohydraulic analysis of appropriate cluster
system sites.
C. It is incorrectly stated on page 43 that the Department of Health
26 regulates on-site sewage disposal systems. [Machmeier]
R. The Kandiyohi County Zoning Administrator's Office issues permits for
26 on-site systems and inspects them during construction.
C. Do EPA calculations of cost-effectiveness for EIS Alternative 6 allow
27 for:
The willingness of farmers to allow their land to be used at
all for cluster drainfields
The price farmers are likely to ask for such land, if they
are willing
58
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The price of long-term easements which take the land out of
production, and
« The length of time farmers may take to negotiate the use of
such contracts? [Olson]
R. Calculations of cost-effectiveness for all wastewater management
27 plans evaluated in the EIS were made on the basis of the "Cost-Effec-
tiveness Analysis Guidelines", authorized under Section 212(2) (c) of
the Federal Water Pollution Control Act, Public Law 92-500. The
prices for land used in this analysis are those prevailing during
preparation of this EIS as estimated by locally knowledgeable people.
There is no way that the effects of land owner's unwillingness to
sell can be predicted or meaningfully quantified.
However, EPA is keenly aware of land owners' fears regarding waste
disposal and the taking of property for public purposes. It is for
these reasons, as well as others, that this EIS requires a showing by
the responsible wastewater management authorities that off-site
treatment is necessary before it will be considered eligible for
Federal Construction Grants funds.
C. In 1976, the Minnesota Pollution Control Agency (MPCA) limited the
28 amount of phosphorus contained in household laundry and cleaning
supplies sold in the state to 0.5%. Lawsuits and a temporary in-
junction prevented enforcement of the rule until September 1979.
Before then, most laundry products sold within Minnesota were
no-phosphate due to voluntary compliance. [Affeldt]
R. Comment noted.
28
C. Incorrect information contained in the Draft EIS, Appendix A regard-
29 ing soil suitability for cluster systems and land application systems
in the Green Lake Study Area could result in poor decisionmaking.
[Conner]
R. See Appendix C, Final EIS.
29
C. The Draft EIS (page 120) assumes that the frequency of septic tank
30 pump-outs should be once every three years. This frequency should be
increased which would, in turn, increase costs of the decentralized
alternatives. [Claassen]
R. Sanitarians across the nation recommend that septic tanks be pumped
30 out every three to five years. More frequent pumping would be re-
quired only for undersized septic tanks. The approach recommended
here would replace most undersized septic tanks.
C. On page 165, the Draft EIS reports that EPA grant funding of on-site
31 and cluster systems would be 85% of 95% of their capital costs. Why
was the 95% not used? [Claassen]
59
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R. Ninety-five percent was usedit represents that portion of the
31 capital costs associated with on-site and cluster systems that is
eligible for 85% Federal funding. EPA funds 85% of the eligible-
for-grant money costs (in this case, 95% of the total, based on
considerations of need and age of housing) for "alternative" or
"innova-tive" systems.
POPULATION AND LAND USE
C. Population and socioeconomic data as presented in the Draft EIS are
32 inaccurate. Seasonal population living on Green Lake should be 75%
of the total. [Dykema]
R. Our seasonal population estimate for the portion of the Green Lake
32 shoreline in New London Township is 73%; that for the entire Green
Lake shoreline is 80%. These estimates do not appear to be incon-
gruous with the seasonal population estimate offered above. Note
that our seasonal population estimate for the Proposed Service Area,
of 65%, is influenced by the inclusion of New London and Spicer, both
of which are concentrated permanent population centers.
C. EIS claims that 40% of the New London Township residents (along Green
33 Lake) 65 years or older are subsisting at a poverty level, and that
64% of the Study Area population have an annual income of less than
$10,000, are erroneous. [Dykema]
R. Commented noted. The EIS poverty figures derive from available data
33 on New London Township as a whole. No effort was made to break these
figures down to the shoreline residents only. In order to break
these Township figures down to segment level, a field socioeconomic
survey would be required.
LAND USE
C. Will the EIS Recommendations have effects upon existing or proposed
34 highways in the Green Lake Study Area? [Emrich]
R. Existing highways and roads, including Minnesota Route 23 and County
34 Roads 4, 10, 30, and 88 will not be severely affected by the EIS
Recommendations. Adverse impacts that may occur can be minimized.
Routes 30 and 10 would be affected by the provision of cluster system
treatment to homes around Green Lake, should it be determined by the
Applicant during Step 2 that decentralized off-site treatment is re-
quired. These impacts result from the construction of sewers that
convey wastewater from individual septic tanks on the lakeside of
these two routes to multifamily soil absorption systems in outlying
areas beyond the roads. This construction may require excavation of
Routes 10, 30, and 98 in several locations for sewer pipe installa-
tion. Adverse excavation impacts can be minimized through the con-
struction of multiple house-to-cluster treatment system connections
and through boring or tunneling house-to-cluster treatment system
connections beneath the roadway to eliminate roadcuts.
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IMPLEMENTATION
C. How do publicly-owned on-site wastewater management systems work?
35 [Tiede]
R. See Sections II.B.2.a. arid II.B.2.C. of the Final EIS.
35
C. Administration and management of the EIS Recommendations mean more
36 government intrusion in peoples' personal lives.
R. The issue of privacy was not addressed in the Draft EIS but is cer-
36 tain to be of interest to homeowners and tenants. A discussion of
privacy is presented here to stimulate consideration of means to
maximize privacy while still meeting the environmental goals of the
Recommendations.
The amount of money citizens must pay for wastewater treatment, in
whatever form, could be considered one measure of intrusion into
peoples' lives. On this basis, the EIS Recommendations are less of
intrusion than any alternative except No-Action.
For the resident whose on-site system is causing no problems and
meets current design standards, short-term intrusions will include a
one or two hour interview and site inspection during the site-speci-
fic evaluation and possibly a return visit for well water sampling.
Continuing intrusions would include periodic (one to three weeks)
site inspections by a surveyor, routine septic tank pumping every two
to five years and, for lakeshore dwellings, possible groundwater and
surface water monitoring activities along their beaches. Some of
these residents may be requested to allow well sampling at the same
time as the site inspection. As with other intrusions discussed
below, notifying the resident in some way, such as by newspaper
notices, citizen's group activities, or mail can minimize the effect
of these intrusions.
For certain of the systems needing repair, replacement, or upgrading,
continuing intrusions would also be greater than with properly de-
signed and operating systems. On-site pumping units need inspection
and maintenance perhaps once or twice per year. If water flows must
be metered for hydraulically limited systems, meter readers would
enter the premises perhaps once per quarter. However, the effect
would in these few cases be no worse than construction of the house
sewer and gravity sewer required for a centralized sewerage system.
In general, continuing intrusions will be related to the complexity
of the facilities necessary to deal with site limitations; the more
complex the facilities, the more maintenance would be required.
Intrusions will be greatest for residences required to install hold-
ing tanks. Visits by the pump truck can be embarrassing as well as
disturbing. This (as well as nuisances and costs) can be minimized
by constructing holding tanks with hopper bottoms and riser pipes
with quick-lock fittings and by installing flow reduction devices in
the home.
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RECREATION
C. Current regulations [CFR Part 35.917.1(j)] require that facility
37 planning begun after 30 September 1978 must include an analysis of
the recreation/open space potential of the project. [Jervis]
R. The EIS does not represent a facilities plan. The primary objectives
37 of the EIS process are to review and analyze the Applicant's Proposed
Action and to develop and evaluate alternative wastewater management
approaches in. view of the public issues surrounding the GLSSWD pro-
ject that were discussed in Chapter I (Final EIS). Recreation and
open space were not at issue when this EIS was undertaken in October
1977. The importance of future recreation opportunities to the
citizens of the Green Lake Study Area became increasingly apparent
during preparation of the EIS. Based upon the public interest in
maintaining recreation opportunities in the wake of improving waste-
water management in this and other EPA study areas throughout Region
V, EPA has decided to address the interaction of wastewater facili-
ties planning and potential recreation/open space opportunities in
its "Generic EIS for Wastewater Management in Rural Lake Areas." The
significance of recreation as an issue in this EIS did not warrant
EPA's quantitative assessment of recreation impacts associated with
the project. It is noted that the EIS was begun approximately one
year pior to the date noted in the comment.
62
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APPENDIX A
Region V Guidance -
Site-Specific Needs Determination and
Alternative Planning for Unsewered Areas
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REGION V GUIDANCE
SITE SPECIFIC NEEDS
DETERMINATION AND ALTERNATIVE PLANNING
FOR UNSEWERED AREAS
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
(PKM) 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 rrobiem, 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, nailed 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 colifora bacteria, or other indicators, and a.
finding of their presence in concentrations which significantly
exceed background levels in groundvaters of the. area or primary
drirking water quality standards. Demonstration of trends
toward groundwater pollution due to malfunctioning systems could
aid in concluding a problem exists.
3. 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 nay 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 Lass than 10,000 square feet in area, will be
assumed to have insufficient isolation distances. However,
before this criterion may be used as areavide evidence, a
correlation with results of Waited representative sampling
which substantiate water well contamination must be made.
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Rt3gion V Guidance A
Page 3
3. Documented gioundvater flow from a filter field toward a «ater
supply well can often override seemingly adequate separation
distances.
4. Bedrock proximity (within three feet of filter field pipe) can
be assessed by utilizing axisting SCS soils naps. If reasonable
suspicion exists that bedrock will be a site limitation and it
cannot be quantified, an on-site investigation ran/ include
representative soil borings as appropriate.
5. Slowly permeable soils with greater than 60 minutes/inch perco-
lation rate.
6. ?,apidly permeable soil with less than 0.1 minutes/inch percola-
tion rate. Soil permeability will be assessed by cvaluting
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 iirresti-
gation.
7. While holding tanks, in certain cases, can be a ccst-effective
alternative, for purposes of site-specific need.5 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 ~aps
3. Review of local perait 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-problen" 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 regaining lots where avail-
able inCorraaticn dees not substantiate their placement into either
the "obvious-problen" or "no-problem" category.
The next step is to attempt to recategorize the "inconclusive" ^\oup
into either group (a) or (b) by making reasonable assumptions baucd
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Region V Guidance A
Page 5
upon the inferred evidence criteria noted in Section III.B. The
on-site investigation would also be the source of information on
those lots where information was not previously available.
For example, on-site systems located on lots with apparent continuous
high groundwater and very tight soils could be placed in the "obvious-
problen" 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 thaf the on-site system
is adequately operating. This situation is especially prevalent in
areas with high percolation rates, where system failure is not evident
to the observer. Thus, a sampling program should consider, to some
extent, lots that exhibit no indirect evidence of need.
B. Mid-Course Review
At the end of Phase I, the results of the Phase I effort should be
presented for review and concurrence before proceeding to Phase II.
The Mid-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-effect.ive 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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Region V Guidance
Page 6
justified, where a high concentration of dwellings occur in a
aunicipality, 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 PKM 78-0 and PKM. 79-8.
2. The number of lets to be investigated during the on-site evalua-
tion should be reasonably estimated. If the original estimation
of on-site vork 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 sysuoa located on a lot with marginal soils
(i.e., a percolation rate of about 60 minutes/inch) would be con-
sidered a low rn'sk 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 en the basis of Phase I results:
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Region V Guidance
Page 7
1. Delineate areas that exhibit indirect evidence and/cr 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 grcundwater and its depth, predicted
duration and recurrence interval, groundwater flow direction
and velocity, depth to bedrock, highly permeable or imperneabls
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 aa
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 colifonn, surfactants, vhiteners, 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-problein) .
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
3. 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 slox? 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
hometo-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.3 of
this memorandum.
_Lj.;ni tat ions 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 duriag 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 select the design of individual drainfields
including on-site soil borings, percolation tests, surveying, work to
specifically identify present septic tank and soil absorption field
location and inspection is generally to.be viewed as Step 3 work. For
practical purposes, site specific design and construction should normally
proceed in tandem on a lot-by-lot and area-by-area basis. The 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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APPENDIX B
Costs
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APPENDIX B
EXISTING ON-SITE SYSTEMS
SITE ANALYSIS COSTS
Description of Work to Be Done
The first step in adopting alternatives recommending on-site systems
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, sam-
pling 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
questionnaire regarding their wastewater systems and wells, will inspect
wastewater system sites and wells, and will take samples of well water from
all homes or businesses surveyed. The well samples will be analyzed for
fecal coliform bacteria and for nitrates, and the results of the survey will
be used to plan work to be done for the remainder of the site analysis.
When the survey has been completed, septic tanks reported or likely to
be undersized will be inspected. The inspection 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, distribution boxes, bends, and obstructions).
Next, soil samples will be taken for lots with: (a) past or present
sewage system malfunctions not explained by the sanitary survey or septic
tank inspections, (b) substandard soil disposal units, and (c) soil disposal
units for which there are no records. 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 sanitarian will inspect subsur-
face disposal units of those on-site systems having recurrent backups or past
surface malfunctions not explained in prior steps. Where appropriate, the
sanitarian with the assistance of laborers will hand-excavate effluent lines,
hand-excavate test pits (to examine size, depth, and type of soil disposal
unit), and evaluate soil hydraulics (soil crusting, decomposition 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 soil disposal unit.
Finally, the impact of wastewater disposal on lake water will be inves-
tigated by examining shoreline groundwater. The direction of groundwater
-------
flow along lake shores will be determined at ^-mile intervals four times
over a one-year period. Also, emergent plumes from on-site systems will be
detected by scanning the lake shore with a septic leachate detector; sites
having plumes will be further analyzed using a shoreline transect and five
samples per plume (to be analyzed for bacteria and nutrient levels).
The results of the site analyses described above will be used to identify
specific measures than can be taken to correct malfunctioning on-site systems
and polluted wells in the Study Area.
Assumptions
Numbers + types of
systems + problems
Step 1 - sanitary
survey and well
sampling
Step 2 - septic
tank inspection
Step 3 - soil
sampling
Step 4 - soil
disposal unit
inspection
Step 5 - well
water meters
972 equivalent dwelling units (EDUs) (30% permanent,
70% seasonal)*
96% ST/SASs, 3% outhouses, 1% holding tanks (HTs)
50% possibly having undersized septic tanks
60% requiring soil sampling
10% periodically backing up or ponding.
100% (972 EDUs)
Sanitarian
Sr. Engineer
Soil Scientist
Jr. Engineer
Surveyors
W. Q. Scientist
* (4/person/day)
22 days
22 days
12 days
22 days
153 days
12 days
243 days
= 243 person-days
Well sample tests - $15/sample x 972
50% (972 EDUs)
Jr. Engineer
(6/person/day) = 81 person days
81 days
3-man crew - $450/day x 81 days
waste disposal - $10/tank x 486
60% (972 EDUs) * (4/2 persons/day)
Soil Scientist 151 days
Surveyor 141 days
292 days
= 292 person-days
10%
10%
(972 EDUs) * 3/supervisor/day = 32 person-days
(972 EDUs) * 1/2 person/day = 195 person-days
227 person-days
* *-» i-» i
Sanitarian
Laborers
32 days
195 days
227 days
10% (972 EDUs) x 6 inspections * 24/person/day = 25
Surveyor 25 days
*3 persons/permanent EDU, 6 persons/seasonal EDU.
-------
Step 6 - shallow
groundwater sampling
Step 7 - shoreline
hydrology surveys
Step 8 - supervision,
documentation,
clerical
16 miles * 4 miles/day x 2 persons = 8 person-days
40 plumes * 2 plumes/day x 2 persons = 40 person-days
48 person-days
Sanitarian 12 days
W. Q. Scientist 24 days
Surveyor 12 days
48 days
Nutrient analyses - $45/series x 5/plume x 40 plumes
2 days/survey x 2 persons x 2 surveys = 8 person-days
Sanitarian 4 days
W. Q. Scientist 1 day
Surveyor 3 days
8 days
Steps 1-7 - 30 + 30 + 75 + 32 + 15 + 12 + 4 - 200 days
Sanitarian 200 days
Sr. Engineer 25% (200) + 15 = 65 days
Secretary 200 days
B
Labor Summary
Sanitarian
Sr. Engineer
Jr. Engineer
Soil Scientist
W. Q. Scientist
Surveyors
Laborers
Secretary
Days Per Step
4567
Total:
18
18
18
10
17
162
243
81
32
151
141
195
81 292 227
25
25
12
24
12
48
GLSSWD* Costs
Salaries Sanitarian @ $25,000/year x 200 days
Surveyors @ $ll,000/year x 343 days
Laborers @ $12,000/year x 195 days
Secretary @ $12,000/year x 200 days
Subtotal
20% fringe benefits
Subtotal
Rent Office @ $300/month x 10 months
Service Well sample analyses - $15/sample x 972
Contracts Septic tank inspection - $450/day x 81
- $10/tank x 486
Well water meters - $175/meter x 97
Groundwater samples - $45 x 5 x 40
8
134
43
1
3
200
8 377
$19,230
14,510
9,000
9,230
$51,970
10,394
$62,364
$ 3,000
$14,580
36,450
4,860
16,975
9 , OOP
$81,865
Total
200
61
99
161
42
343
195
200
1,301
*Green Lake Sanitary Sewer and Water District
-------
GLSSWD Costs (continued)
Equipment Septic leachate detector - $15/day x 80
and sam- (rental)
pling Groundwater flow meter (rental)
Field sampling equipment
Paper, supplies
Cameras and film for documentation
2 vans @ ($350/mo + $120 gas-oil/mo) x 10
Summary Salaries
Rent
Contracts
Equipment and supplies
$ 1,200
350
1,500
1,500
2,000
9.400
$ 15,950
$ 62,364
3,000
81,865
15.950
$163,179
Consultant Costs
Direct
Labor
Other
Direct
Costs
Travel
Summary
Sr. Engineer @ $35,000/year x 61 days
Jr. Engineer @ $20,000/year x 99 days
Soil Scientist @ $25,000/year x 161 days
W. Q. Scientist @ $25,000/year x 42 days
Report reproduction
Communication
Graphics, report preparation
$ 8,210
7,615
15,480
4,040
$ 35,345
$ 150
800
1,500
$ 2,450
House rental for office, sleeping - 10 mos $ 5,000
Other per diem @ $20/day x 363 days 7,260
50 Rt x 200 miles x $0.20/mile 2,OOP
$ 14,260
Direct labor x 3.0
Other direct costs x
Travel x 1.2
1.2
$106,035
2,940
17,112
$126,087
Total Costs
GLSSWD Costs
Consultant Costs
TOTAL:
$163,179
126,087
$289,266
-------
B
EIS Alternatives 4, 5, 6
Present Worths, User Charges
Assumptions
ri°centralized
Treatment
rap-!t3l Costs
O&M Costs
Salvage Values
New London, Spicer, Segments 1, 2, 9, 10, 11
EDU's - 675 (year 1980), 1,254 (year 2000)
All remaining segments
EDU's - 827 (year 1980), 855 (year 2000) 25% of EDU's
to cluster systems 50% of remaining EDU's needing new
ST/SAS's.
Centralized treatment - Draft EIS costs used except
that $26,100 has been added to Appendix H figures to
bring them into agreement with Table IV-2.
Decentralized treatment -
$100/ST access pipe
$1,262/ST/SAS
$4,371/ST/cluster system (includes $968 hookup)
Centralized treatment - Draft EIS costs used except that
the Appendix H collection O&M costs for Alternatives 4
and 5 have been reduced to bring them into agreement with
Beard's original figures.
Decentralized treatment -
$60/ST pumping (70% once/5 yr., 30% once/3 yr.)
$55/yr./residence for cluster system DF's
$15/well sample (1/5 yr./well, 2/yr./cluster well)
$45/groundwater sample (20 tests, 3 samples/test)
Sanitarian @ $25,000/yr. to provide engineering,
administrative, planning - 160 days/yr.
Surveyors @ $12,000/yr. to sample wells and lake
shore groundwater - 72 days/yr.
Secretary @ $12,000/yr. - 80 days/yr. (half-time)
20% fringe benefits for sanitarian, surveyors,
secretaries
Soil Scientist @ $325/day - 1 day/yr. (^ day/permit)
Rentals - see cost pages
Centralized treatment - Draft EIS costs used except that
Appendix H figures have been changed by addition of salvage
for force main, gravity tees and hookups, and by subtraction
of salvage for engineering and contengency.
-------
Present Worth
User Charges
Decentralized treatment -
50 year useful life for ST's
20 years for drainfields
$2,122/EDU for cluster systems (includes hookup)
6-5/8, 20 years
Federal funding - 757, conventional, 85% alternative
State funding - 15% conventional, 9% alternative
Debt Retirement - 6-7/8%, 30 years, 1980 capital
Debt Reserve - 20% debt retirement
Eligibility tor funding - 0%, hookups;
80% centralized collection and treatment;
95% on-site and cluster systems
Alternative
Present Worth, User Charges
Alternative Costs
Centralized Treatment
Existing EUS's:
Collection & Conveyance Sewer
Rapid Infiltration Treatment
Subtotal
25% Engineering & Contingency
Other Capital Costs
Total 1980
Future EDU's:
Connections - 579
Capital
Costs
856.8
1,190.0
2,046.8
511.7
26.1
2,584.6
($ x 1,000)
O&M
Costs
10.6/yr.
37.5/yr.
-0-
-0-
Salvage
Value
388.4
717.3
-0-
-0-
48.1/yr. 1,105.7
Total 1980-2000
36.2*/yr. -0- 463.2
36.2/yr -0- 463.2
Decentralized Treatment
Existing EDU's:
Replace 310 ST/SAS's
Connect 207 EDU's to Clusters
Retain 310 ST/SAS's (+ access pipes)
Subtotal
Future EDU's:
Add 28 ST/SAS's
Subtotal
391.2
904.8
31.0
1,327.0
1.77/yr.
1.77/yr.
4.46/yr. 49.3
14.37/yr. 439.3
4.46/yr. 18.6
23.29/yr. 507.2
0.02/yr./yr. 5.9
0.02/yr./yr. 5.9
Including 25% engineering and contingency.
-------
($ x 1,000)
B
Capital O&M
Costs Costs
Salvage
Value
Salaries:
Sanitarian @ $25,000/yr. x 160 days
Surveyors @ $12,000/yr. x 72 days
Secretary @ $12,000/yr. x 80 days
Subtotal
20% fringe benefits
Subtotal
Retainer:
Soil scientist @ $325/day x 1
Water Sample Analyses:
Wells @ $15/sample x 174/year
Wells @ $15/sample x 0.3/yr./yr.
Shallow groundwater @ $45 x 20 x 3
Subtotal
Rent als:
Contribution to office rental
Office supplies, telephone, etc.
Van lease, gas and oil
Small motorboat - 3 weeks/yr.
subtotal
Engineering, Legal, Contingencies:
Site analysis
Cluster system design
Legal, etc. (9% construction cost)
Subtotal
Decentralized Treatment
Total Alternative Costs
Present Worths
Total 1980
Total 1980-2000
Total 1980
Total 1980-2000
-0-
-0-
-0-
-0-
-0-
15.39/yr.
3.32/yr.
3.69/yr.
22.40/yr.
4.48/yr.
26.88/yr.
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
:±
-o-
289.3
45.0
119.4
453.7
0.33/yr.
-0-
-0-
-0-
-0-
-0-
2.60/yr. -0-
0.004/yr./yrs.-O-
2.70/yr. -0-
5.30/yr. -0-
0.004/yr./yr.
-0-
-0-
-0-
-0-
-0-
2.10/yr.
1.20/yr.
3.60/yr.
0.30/yr.
7.20/yr.
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
1780.7 63.0/yr. 507.2
1.77/yr. 0.02/yr./yr. 5.9
4365.3 111.1/yr. 1612.9
38.0/yr. 0.02/yr. 469.1
($ x 1,000)
Centralized treatment P.W. = 2,584.6 + 10,9909 (48.1 + 36.2)
- 0.2772 (1105.7 + 463.2)
= 3,076.2
Decentalized treatment P.W. = 1,780.7 + 10.9909 (63.0 + 1.77)
+ 81.155 (0.024)
- 0.2772 (507.2 + 5.9)
= 2,350.4
Total P.W. = 3,076.2 + 2,350.4 = 5,426.6
-------
Local Share
Centralized treatment:
Hookups - 100% (1.25 x 140.4)
Collection Sewer - 20% (1.25)
10% (80%)
Conveyance Sewer - 10% (1.25) (337.0)
Treatment - 10% (1.25) (1,190.0 - 716.0)
6% (1.25) (716.0)*
Other - 20% (26.1)
10% (80%) (26.1)
Total 1980
Decentralized treatment:
All items - 5% (1,780.7)
- 6% (95%) (1,780.7)
Total 1980
($ x 1,000)
(856.8 - 140.4 - 337.0)
(1.25) (856.8 - 140.4 - 337.0)
.9
.1
.2
,7
175.5
94.8
37,
42.
59.
53.
5.2
2.1
470.5
89.0
101.5
190.5
Total Alternative:
User Charges
Total 1980
Centralized Treatment U.C. = [0.07958 (1.2) ($470,500) + $48,100] r 675
= $140/yr./residence (1980)
661.0
Decentralized Treatment U.C. = [0.07958 (1.2) ($190,500) + $63,000]
= $100/yr./residence (1980)
827
Total Alternative U.C. = [0.07958 (1.2) ($661,000) + $111,100]
= $120/yr./residence (1980)
1,502
Alternative 5
Present Worth Analysis
Alternative Costs
($ x 1,000)
Centralized Treatment
Existing EDU's :
Collection and Conveyance Sewer
Spray Irrigation Treatment
Subtotal
25% Engineering & Contingency
Other Capital Costs
Total 1980
Future EDU's:
Connections - 579
Capital
Costs
856.8
1,402.0
2,258.8
564.7
26.1
O&M
Costs
10.6/yr.
42.9/yr.
-0-
-0-
Salvage
Value
388.4
711.3
-0-
-0-
2,849.6
Total 1980-2000
36.2/yr.
36.2/yr.
53.5/yr.
-0-
-0-
1,099.7
463.2
463.2
* Pre-treatment, storage, treatment,
-------
($ x 1,000)
Capital O&M Salvage
Costs Costs Value
Decentralized Treatment*
Total 1980 1,780.7 63.0/yr. 507.2
Total 1980-2000 1.77/yr. 0.02/yr. 5.9
Total Alternative
Total 1980 4,630.3 116.5/yr. 1,606.9
Total 1980-2000 38.0/yr. 0.02/yr./yr. 469.1
Present Worths
($ x 1,000)
Centralized Treatment P.W. = 2,849.6 + 10.9909 (53.5 + 36.2)
- 0.2772 (1,099.7 + 463.2)
= 3,402.5
Decentralized Treatment P.W. = 2,350.4 (Same as Alternative 4)
Total P.W. = 3,402.5 + 2,350.4 = 5,752.9
Local Share
Centralized Treatment:
Hookups - 100% (1.25) (140.4) 175.5
Collection Sewer - 20% (1.25) (856.8 - 140.4 - 337.0) 94.8
- 10% (80%) (1.25) (337.0) 37.9
Conveyance Sewer - 10% 10% (1.25) (337.0) 42.1
Treatment - 10% (1.25) (1,402.0 - 893.0) 63.6
- 6% (1.25) (893.0) 67.0
Other - 20% (26.1) 5.2
10% (80%) (26.1) 2.1
Total 1980 488.2
Decentralized Treatment (Alternative 4):
Total 1980 190.5
Total Alternative: Total 1980 678.7
User Charges
Centralized Treatment U.C. = [0.07958 (1.2) ($488,200) + $53,500] T675
= $120/yr./residence (1980)
* Same as for Alternative 4.
-------
Alternative 6
Present Worth Analysis
Alternative Costs
Centralized Treatment
Existing EDU's:
Collection and Conveyance Sewer
Upgrade of Existing STP's
Subtotal
25% Engineering and Contingency
Other Capital Costs
Total 1980
Capital
Costs
($ x 1,000)
O&M
Costs
Future EDU's:
Connections - 579
Total 1980-2000
Decentralized Treatment*
Total Alternative
Total 1980
Total 1980-2000
Total 1980
Total 1980-2000
1,780.7 63.0/yr.
1.77/yr. 0.02/yrs.
Present Worths
3,240.8
38.0
($ x 1,000)
147.52/yr.
0.02/yr.
Centralized Treatment P.W. = 1,460.1 + 10.9909 (84.52 + 36.2)
- 0.2772 (479.4 + 463.2)
= 2,525.6
Decentralized Treatment P.W. = 2,350.4 (Same as Alternative 4)
Total P.W. = 2,525.6 + 2,350.4 = 4,876.0
Local Share
Centralized Treatment:
Hookups - 100% (1.25) (140.4)
Collection Sewer - 20% (1.25) (495.2 - 140.4 - 36.0)
- 10% (80%) (1.25) (495.2 - 140.4 - 36.0)
Conveyance Sewer - 10% (1.25) (36.0)
Treatment - 10% (1.25) (652.0)
Other - 20% (26.1)
- 10% (80%) (26.1)
Total 1980
Salvage
Value
495.2
652.0
1,147.2
286.8
26.1
1,460.1
36.2/yr.
36.2/yr.
6.02/yr.
78.50/yr.
-0-
-0-
84.52/yr.
-0-
-0-
283.4
196.0
-0-
-0-
479.4
463.2
463.2
507.2
5.9
986.6
469.1
($ x 1,000)
175.5
79.7
31.9
4.5
81.5
5.2
2.1
380.4
* Same as for Alternative 4.
-------
Decentralized Treatment (Alternative 4):
Total 1980 190.5
Total Alternative Total 1980 570.9
User Charges
Centralized Treatment U.C. = [0.07958 (1.2) ($380,400) + $84,520] * 675
- $l80/yr./residence (1980)
Decentralized Treatment U.C. = $100/yr/residence (Alternative 4)
Total Alternative U.C. = [0.07958 (1.2) ($570,900) + $147,520] * 1,502
= $130/yr./residence (1980)
-------
Limited Action Alternative
Present Worths, User Charges
Assumptions
Centralized
Treatment
Decentralized
Treatment
Capital Costs
O&M Costs
Salvage Values
Present Worth
User Charges
New London, Spicer
EDU's - 530 (year 1980), 977 (year 2000)
Numbered segments
EDU's - 972 (year 1980), 1,112 (year 2000)
50% (972) needing new ST/SAS's
Centralized Treatment - Draft EIS STP Costs, $26,100
added to recreate Table IV-2 capital
Decentralized Treatment -
$1,262/ST/SAS, $100/ST access pipe
Centralized Treatment - Draft EIS STP Costs
Decentralized Treatment -
$60/ST pumping (70% once/5 years, 30% once/3 years)
15/well sample (l/well/5 years)
45/groundwater sample (20 tests, 3 samples/test)
Sanitarian @ $25,000/yr. - 200 days
Surveyors @ $12,000/yr. - 100 days
Secretary @ $12,000/yr. - 100 days
20% fringe benefits for sanitarian, surveyors,
secretaries
Soil Scientist @ $325/day - 4 days (% day/permit)
Rentals - see cost calculations
Centralized Treatment - Draft EIS STP tiosts
Decentalized Treatment - 50 yr. life for ST's
6-5/8%, 20 years
Eligibility - STP's, 80%; ST/SAS's, 95%
Federal funding - STP's 75%; ST/SAS's 85%
State funding - STP's, 15%; ST/SAS's, 9%
Debt retirement - 6-7/8%, 30 years, 1980 capital
Debt reserve - 20% of debt retirement
Alternative Costs
Capital
Costs
($ x 1,000)
O&M
Costs
Salvage
Value
Centralized Treatment
Existing EDU's:
Upgrade of STP's
25% Engineering and
Other Capital Costs
Contingencies
Total 1980
553.0
138.2
26.1
717.3
62.6/yr.
-0-
-0-
62.6/yr.
166.0
-0-
-0-
166.0
-------
($ x 1,000)
B
Capital O&M
Costs Costs
Salvage
Value
Future EDU's:
Connections - 467
Decentralized Treatment
Total 1980-2000
29.2/yr. -0-
29.2/yr. -0-
373.6
373.6
Existing EDU's:
Replace 486 ST/SAS's
Retain 486 ST/SAS's (+ access's)
Subtotal
Future EDU's:
Add 140 ST/SAS
Salaries:
Sanitarian - $25,000/yr. - 200 days
Surveyors - $12,000/yr. - 100/days
Secretary - $12,000/yr. - 100 days
Subtotal
20% fringe benefits
Subtotal
Retainer:
Soil Scientist - $325/day - 4 days
Water Sample Analyses:
Wells - $15/sample - 194/yr.
Wells - $15/sample - 7/yr./yr.
Shallow groundwater - $45 x 20 x 3
Subtotal
Rentals:
Contribution to office rental
Office supplies, telephone, etc.
Van lease, gas and oil
Small motorboat - 3 weeks/yr.
Subtotal
Engineering, Legal Contingencies:
Site Analysis
Legal, etc. (9% construction cost)
Subtotal
Total Alternative Costs
Total 1980
Total 1980-2000
Total 1980
Total 1980-2000
613.3
48.6
661.9
7.00/yr.
7.00/yr.
14.0/yr.
77.3
29.2
106.5
8.83/yr.
-0-
-0-
-0-
-0-
-0-
-0-
289.3
59.6
348.9
1,010.8
8.83/yr.
1,728.1
38.0/yr.
O.lO/yr./yr. 29.7
19.23/yr.
4.62/yr.
4.62/yr.
28.47/yr.
5.69/vr.
34.16/yr.
1.3/yr.
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
2.91/yr.
O.lO/yr./yr.
2.70/yr.
5.61/yr.
O.lO/yr./yr.
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
2.70/yr.
1.40/yr.
4.21/yr.
0.30/yr.
8.61/yr.
-0-
-0-
-0-
-0-
-0-
-0- -0-
-0- -0-
-0- -0-
63.68/yr. 106.5
0.20/yr./yr. 29.7
126.3/yr. 272.5
0.20/yr./yr. 403.3
-------
Present Worths ($ x 1>(X)0)
Centralized Treatment P.W. = 717.3 + 10.9909 (62.6 + 29.2)
- 0.2772 (166.0 + 373.6)
= 1,576.7
Decentralized Treatment P.W. = 1,010.8 + 10.9909 (63.68 + 8.83)
+ 81.155 (0.20)
- 0.2772 (106.5 + 29.7)
= 1,786.1
Total Alternative P.W. - 1,576.7 + 1,786.1 = 3,362.8
Local Share
Centralized Treatment: ($ x 1,000)
Treatment - 10% (1.25) (553.0) 69.1
Other - 20% (26.1) 5.2
10% (80%) (26.1) 2.1
Total 1980 76.4
Decentralized Treatment:
All items - 5% (1,010.8) 50.5
6% (95%) (1,010.8) 57.6
Total 1980 108.1
Total Alternative: Total 1980 184.5
User Charges
Centralized Treatment U.C. = [0.07958 (1.2) ($76,400) + $62,600] * 530
s $130/yr./residence (1980)
Decentralized Treatment U.C. = [0.07958 (1.2) ($108,100) + $63,680] £ 972
= $80/yr./residence (1980)
Total Alternative U.C. = [0.07958 (1.2) ($184,500) + $126,300} : 1,502
= $100/yr./residence (1980)
-------
PRELIMINARY ELIGIBILITY DETERMINATION FOR
ALTERNATIVES IN GREEN LAKE EIS - JUNE 1979
Assumptions
1. Needs - We have assumed that a need exists in all alternatives. This
was necessary since present versus future needs policy issues are, as
yet, unresolved. We have assumed that the EIS consultant's assumptions
related to these alternatives are valid.
2. On-site systems along Green Lake will be publicly owned and will be
95% eligible for 85% Federal funding. Cluster systems will be 95%
eligible for 85% Federal funding. State funding will be 60% of the
eligible cost.
3. Typical gravity sewer collection systems (not interceptors) will be
80% eligible for 75% Federal funding. Pressure sewers collection
systems will be 80% eligible for 85% Federal funding. State funding
will be 80% of the total share of eligible costs.
4. Hook-up costs for gravity and pressure systems are ineligible costs.
-------
No-Action Alternative Present Worth Analysis
Centralized
treatment
Decentralized
treatment
New London, Spicer
EDUs - 530 (Year 1980), 997 (Year 2000)
Upgrade to meet state's effluent requirements without Federal
or state funding
Numbered segments
EDUs - 972 (Year 1980), 1,112 (Year 2000)
1% (972)/year needing new ST/SASs
1% (972)/year needing new ST/SM
Capital costs
O&M costs
Salvage
values
Present
worths
User charges
Centralized treatment - Draft EIS STP costs, $26,100 added
to recreate Table IV-2 capital
Decentralized treatment:
$1,262/(ST/SAS)
$8,850/(ST/SM)
$8.65/hr/sanitarian x 12 hrs/new system permit
$8.65/hr/sanitarian x 16 hrs/replacement permit
Centralized treatment - Draft EIS STP costs
Decentralized treatment:
$60/ST pumping (once/10 years)
$55/yr/residence for ST/SM dose pump
Centralized treatment - Draft EIS STP costs
Decentralized treatment - 50 year life for STs
6-5/8%, 20 years
0% Federal and state funding
Debt retirement - 30-year bond, 6-7/8%, 20% reserve
Alternative Costs:
Capital
Costs
($ x 1,000)
O&M
Costs
Salvage
Value
Centralized Treatment:
Existing EDUs:
Upgrade of STPs 553.0 62.6/yr 166.0
25% Engineering & Contingencies 138.2 -0- -0-
Other Capital Costs 26.1 -0- -0-
TOTAL 1980 717.3 62.6/yr 166.0
-------
Centralized Treatment (continued)
($ x 1,000)
Future EDUs:
Connections - 467
TOTAL 1980 - 2000
Decentralized Treatment
Existing and Future EDUs:
Replace 10 (ST/SASs)/yr w/(ST/SASs)
Replace 10 (ST/SASs)/yr w/(ST/SMs)
Pump each ST once/10 years
Add 140 new ST/SASs (inc. pumping)
TOTAL 1980-2000
Capital
Costs
29.2/yr
29.2/yr
12.64/yr
88.50/yr
-0-
8.83/yr
109.95/yr
O&M
Costs
-0-
-0-
-0-
0.55/yr/yr
5.82/yr
0.004/yr/yr
5.82/yr
0.554/yr/yr
Salvage
Value
373.6
373.6
42.4
42.4
-0-
29.7
114.5
Total Alternative Cost
TOTAL 1980
TOTAL 1980-2000
717.3 68.42/yr 166.0
139.15/yr 0.554/yr/yr 488.1
Present Worths:
($ x 1,000)
Centralized treatment P.W. = 717.3 + 10.9909 (62.6 + 29.2)
- 0.2772 (166.0 + 373.6)
= 1,576.7
Decentralized treatment P.W. = 10.9909 (109.95 + 5.82)
+ 81.155 (0.554/yr/yr)
- 0.2772 (114.5)
= 1,285.6
Total P.W. = 1,576.7 + 1,285.6 = 2,862.3
User Charges; (Estimated 1980 User Charges)
Centralized treatment U.C. = [0.07958 (1.2) ($717,300) + $62,600] * 530
= $250/yr/residence (1980)
-------
APPENDIX C
Letter Response to Mr. F. W. Conner,
USDA, SCS, Regarding Soil Data
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATtON SERVICE
209 W. Mulberry St., St. Peter, MN 56082
March 20, 1980
Mr. Eric Hediger
WAPORA Inc.
6900 Wisconsin Ave. N.W.
Washington, D.C. 20015
Dear Mr. Hediger:
I am writing to you to express concern in regard to the draft of the
Environmental Impact Statement "Alternative Waste Treatment Systems
for Rural Lake Projects, Case Study No. 2, Green Lake Sanitary Sewer
and Water District, Kandiyohi County, Minnesota". If you recall, two
soil scientists of the Soil Conservation Service, Richard Paulson and
Allan Giencke, soil mapped the requested sites and provided soil inter-
pretation sheets and maps for the soils found to your company. Various
members of the field staff have reviewed the above document and have
noted significant errors in the Appendices, Section A. The errors are
as follows:
1. The map scale in Appendices A, figures 1, 2, 3, 4 and 6 is 1 inch
equals 1320 feet and not the 1 inch equals 2000 feet. The inter-
pretive maps in these figures fit perfectly over our 4 inch equals
1 mile (1:1584) soil maps. We do not know what scale figure 5 is
because we are unable to locate the soil survey area that resembles
the interpretive map.
2. The acreage figures given for each site in Table 1 are not correct
if the size is based on the area shown in figures 1 through 6.
Consequently, the percent of soils listed as slight, moderate or
severe are also incorrect. The correct acreage figures are approxi-
mately 20 percent of those listed in Table 1.
WAPORA's Corrected
S jte Acres Acres
A 270 52
B 232 45
C 274 60
D 306 62
£ 248 51
F 378 86
G 82 16
li 208 38
I 262 49
-------
WAPORA's Corrected
Site Acres Acres
J 74 15
K 82 16
L 146 20
M 170 30 ,
Rapid Infiltration 1184 240 -
Spray Irrigation 1606 325
_!_/ This is the total acres that was soil mapped in the area
identified in figure 5.
x
It appears from Guide Sheet No. 3, Soil limitation ratings for septic
tank absorption fields, that soil features wetness and permeability
were the only features used in evaluating the sites. Slope was briefly
mentioned in the narrative but it was not used for the interpretive
maps in figures 1 through 6. For example, most of the sites on the
north side of Green Lake have "E" slopes, which are greater than 18
percent. They also have "D" slopes of 12 to 18 percent. Even though
the guide sheet has the break at 15 percent, we rate "D" slopes as
severe in Minnesota. We are concerned because even the "E" slopes were
rated as moderate without further explanation.
The Soil Conservation Service does not have guide sheets which rate
the soils as slight, moderate or severe for spray irrigation or rapid
infiltration, we have an Irrigation Guide and a Minnesota Hydrology
Guide which place soils in groups where each group has similar proper-
ties. Using the Guide Sheet No. 3, Soil limitation ratings for septic
tank absorption fields, distorts the information given. For example,
Estherville is a major soil in the Irrigation Site. This soil is in
Irrigation Group 8 which has an intake rate of 1.5 inches per hour.
If you applied 4 inches of effluent per acre, it could be put on at
1.65 inches per hour on "A" slopes (0 to 2 percent). However, it would
be reduced to 0.8 inches per hour on "C" slopes if runoff is not wanted.
There are substantial areas of soils which have "C", "D" and "E" slopes
in this site.
The statements on soils for the Rapid Infiltration Site are contra-
dictory. The dominant soils are Salida and Estherville which are sandy
and gravelly. However, it was described as: "The soils on this site
are primarily comprised of glacial till with scattered pockets of
sand and gravel.
-------
I feel, hr. Hediger, that a corrected amendment to the draft of this
£nvironmental Impact Statement is justified. The mis-information contained
in the Appendices, Section A, Soil, could result in poor decision making.
It also does not reflect the established technical quality of work performed
by the respective soil scientists of the Soil Conservation Service.
Sincerely,
F. tf. ConlYer
Area Conservationist
cc: Harry M. Major, State Conservationist, SCS, St. Paul, HN
Raymond Diedrick, State Soil Scientist, SCS, St. Paul, MN
Gregory A. Vanderlaan, iiPA, Chicago, IL
Richard Paulson, Area Soil Scientist, SCS, St. Peter, MN
Allan Giencke, Party Leader, SCS, Willmar, MN
Lester Swanson, District Conservationist, SCS, Willmar, MN
-------
WAPORA,
Proiect 662-E
Environmental /Energy Studies
esoo WISCONSIN AVENUE N.W., WASHINGTON, o. c. 20015
PHONE - (301) 652-9520
22 May 1980
Mr. F. W. Conner
Area Conservationist
US Department of Agriculture
Soil Conservation Service
209 West Mulberry Street
St. Peter, Minnesota 56082
Re: Soil data presented in Draft Environmental Impact Statement
"Alternative Waste Treatment Systems for Rural Lake Projects,
Case Study No. 2, Green Lake Sanitary Sewer and Water District,
Kandiyohi County, Minnesota"
Dear Mr. Conner:
Thank you for your letter of 20 March 1980 in which you expressed
concern over selected soil data presented in the referenced EIS. Your
comments, including those of your colleagues within the Soil Conserva-
tion Service, will enhance our ability to prepare a Final EIS that is
both a factual and an objective decision-making tool. I would agree
with you that several serious errors were apparent in Appendix A-l
(Land Application, Spray Irrigation, and Cluster System Sites) . This
unfortunate fact reflects poor proofreading of the material presented
in this section. Let me hasten to add, however, that these errors,
some of which were corrected prior to receipt of your letter, in no way
reflect on the invaluable assistance received by Messrs. Allan Giencke,
Richard Paulson, Lester Swanson, Harry Major, and yourself during prep-
aration of the Draft Green Lake EIS. These errors do not reflect on
our client, the US Environmental Protection Agency, either.
I will respond to your comments in the order in which they are
listed in your letter.
1. Your first comment is duly noted. The map scale in Appendix
A, Figures 1, 2, 3, 4, and 6 is 1 inch = 1,320 feet and not
1 inch = 2,000 feet. The "trial" soils map of the Green Lake
area sent to us by Mr. Swanson in November 1977 contained no
scale; it was, therefore, erroneously assumed during the
preparation of the "potential cluster system treatment site
maps" that the scale of the soils map was 1 inch = 2,000 feet.
However, inspection of the cover letter to Mr. Swanson's
November 1977 package shortly after the Draft EIS was published
revealed the proper scale. The scale for Figure 5 is also
1 inch = 1,320 feet.
AIR
SOLID WASTE
WATER
-------
c
Mr. F. W. Conner -2- 22 May 1980
2. Comment is noted. The acreage figures in Table 1, Appendix A-l
are overstated by one order of magnitude. This error was also
detected shortly after the Draft EIS was published. The area
of the potential cluster system treatment sites was renieasured
by planimeter and is included in the attached table along with
your revised estimates of acreage for the same sites.
3. The percentages of slight, moderate, and severe limitations for
the 13 cluster system sites and two land application sites have
been revised in observance of your severe ratings for "D" slopes.
However, we believe that cluster system drainfields are feasible
on "D" slopes provided certain special engineering steps are
taken. These include terracing the drainfield site and placing
the drainfield laterals further apart than would be the case on
slopes of less than 12%. It is our further contention that
detailed investigation of each candidate site be conducted by a
soil scientist and an engineer during the detailed design stage
of the project, no matter what slopes, depth to water table, or
permeability are indicated by planning-level data.
Slope along with permeability and depth of water table was incor-
porated into the cluster system development process during prep-
aration of the Draft EIS. We were most fortunate to have Mr.
Paulson's assistance in this connection; where slopes are limiting,
he so indicated in his report. This report was the narrative you
refer to in your letter.
The revision of limitation percentages does not alter the poten-
tial for cluster system treatment on each site (except site K
which was rated in the Draft EIS as having severe limitations
over its entirety). Out of the approximately 566 acres of poten-
tial cluster system treatment area, 244 acres or 43% have either
moderate or slight limitations for the intended use. There is
a minimum of 4 acres of soil with moderate limitations on every
site, except site K. This should be sufficient to satisfy area
requirements in the Green Lake area.
In short, we agree that cluster system suitability as presented
in Appendix A-l is misleading, given the fact that certain "E"
slopes are classified as having moderate limitations. We don't
believe that all "D" slopes should categorically be classified
as "severe" when selected site modifications are possible.
Limiting slope, as reported by Mr. Paulson, was a key factor
in the preliminary design of the cluster system.
4. Our use of SCS "soil limitation ratings for septic tank absorp-
tion fields" in presenting soil suitability information for
spray irrigation and rapid infiltration was for purposes of
rough acreage quantification only. It is assumed on a general
basis that soils which are suitable/unsuitable for septic tank
absorption fields are suitable/unsuitable for spray irrigation
-------
Mr. F. W. Conner -3- 22 May 1980
fields, and possibly, for rapid infiltration basins. The extent
to which these sites really are feasible for wastewater disposal
and treatment can only be determined through detailed site inves-
tigation. While we utilized Guide Sheet No. 3 to present rough
indexes of land application feasibility, we emphasized soil
characteristics. This knowledge of soil characteristics on the
rapid infiltration site as described in the Appendix A-l narrative
was only possible through Mr. Giencke's preliminary site inves-
tigative efforts.
5. On the surface, the two statements on soils at the rapid infiltra-
tion site appear contradictory, as you have noted. The statement
describing the dominant soils as Salida and Estherville is con-
firmed by Mr. Giencke's preliminary assessment of the site as
having soils which are "very sandy and quite deep to water" (in
his letter dated 16 June 1978). The description of soils
"comprised of glacial till with scattered pockets of sand and
gravel" may, in fact, be more appropriate to the Green Lake Study
Area. It is not inconceivable, however, that glacial till could
be present on the site given that the Salida and Estherville soils
may form part of the sand and gravel lenses in glacial till in the'
northwestern portion of the Study Area. We thank you for pointing
out the contradiction in preliminary soils classification.
In sum, we appreciate your taking the time to review the Green Lake
Draft EIS in detail and furthermore, your identification of errors in the
document's presentation of technical data. These errors will be presented
in the Final EIS, along with our corrections and explanation. I would
like to emphasize that despite the errors and discrepancies discussed above,
the conclusions of the Draft EIS have not changed.
If you have any questions, please feel free to contact me.
Sincerely yours,
Eric M. Hediger, M.E.M.
Project Manager
cc: Gregory A. Vanderlaan, EPA, Chicago, IL
Harry M. Major, State Conservationist, SCS, St. Paul, MN
Raymond Diedrick, State Soil Scientist, SCS, St. Paul, MN
Richard Paulson, Area Soil Scientist, SCS, St. Peter, MN
Allan Giencke, Party Leader, SCS, Willmar, MN
Lester Swanson, District Conservationist, SCS, Willmar, MN
-------
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-------
APPENDIX D
Letters of Comment on the Draft EIS
-------
RltKf CARROLL MULLER ASSOCIATES INC
August 9, 1979
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, IL 60604
ATTENTION: EIS SECTION
RE: DRAFT ENVIRONMENTAL IMPACT STATEMENT
ALTERNATIVE WASTEWATER TREATMENT SYSTEMS FOR
RURAL LAKE PROJECTS
CASE STUDY NUMBER 2
GREEN LAKE SANITARY SEWER AND WATER DISTRICT
KANDIYOHI COUNTY, MINNESOTA
EPA NO. C271377-01
Gentlemen:
This is a summary of oral comments RCM made at the public
hearing on the referenced project August 4, 1979 in New
London, Minnesota. These comments are submitted for con-
sideration and inclusion in the final Environmental Impact
Statement (EIS). The comments made herein are referenced
by the page in the draft EIS.
Page v The third paragraph under Surface Water Resources
says bacterial levels along shore areas are below
Minnesota State Health Department and Minnesota
Pollution Control Agency (MPCA) standards for
recreational waters. Further in the paragraph
reference is made to the Kerfoot (1979) study
that reported low levels of fecal coliforms near
septic leachate plumes. It should be noted that
the Kerfoot study was done in March at a time
water temperatures would be very low and the life
expectancy of fecal col iform bacteria would be
very short. Also in March, only permanent resi-
dents would be living on the lake and since the
septic snooper used by Kerfoot also detects dormant
leachate plumes, fecal coliforms would be expected
to be very low. This data would mean that the low
levels of fecal coliforms found during Kerfoot's
study would have little meaning.
architects
land surveyors
mailing
post office box 130
hapkms, minnesots b:j,"S4':'
1011 first streu sou m
hopkins, miimeioi.) fih
612935-6901
hopkms, minnesota
gayiord
fairmont
<>t- cloud
mankalo
-------
U.S. Environmental Protection Agency
Page 2
August 9, 1979
Page vi Under Additional Studies, Item 1. The aerial survey
was conducted in August 1978. This survey was con-
ducted to detect septic system surface malfunctions.
It should be noted that the vegetative cover is
heaviest at this time of year and interference would
therefore be greatest for surface malfunction detec-
tion by these methods. Three marginally failing
systems were detected on Green Lake and one currently
failing and one marginally failing systems were
detected on Nest Lake. In conversations with Mr.
Wally Fischer, Chairman, Green Lake Sanitary Sewer
and Water District, he has said that he can show
several failing systems during on-the-ground inspec-
tions.
Page vi Under Additional Studies, Item 2. The sanitary
survey was done in November 1978 at a time when few
people would be at the lake. In the EIS appendix,
one comment under the sanitary survey is that most
residents felt that this was a poor time of year
to do the survey. It should also be pointed out
that the investigator may not have received full
cooperation from the people being interviewed since
they did not know who he was and possibly would
not want to say that their system was failing or
that they had experienced problems with their system.
Page vi Under Additional Studies, Item 3. Kerfoot's study
was done in March 1979. It is my understanding
that there was three feet of ice, sixteen inches
of snow and one foot of water on the ice at that
time. Samples were taken every one hundred feet
around the lake. It seems with intermittent
samples that several leachate plumes could have
been missed. Also at this time of year, only
permanent residents live at the lake. It seems
that leachate plumes that may have been present
in the late fall after seasonal use by residents
may not have been detected. Most of the leachate
plumes that were discovered on Green Lake during
Kerfoot's survey were located on the north shore
of Green Lake. This is the area of the lake
where there are the most permanent residences.
-------
U.S. Environmental Protection Agency
Page 3
August 9, 1979
Page viii Surface Water. This section of the EIS says that
surface water quality will not improve much under
any alternative. It would seem that upgrading
the Spicer and New London discharges would eliminate
much of the pollution from the Crow River.
Page ix The last paragraph mentions that an additional 30
to 40 acres of lakeshore will be developed with a
centralized sewer system. In observations of
Green Lake, it is hard to determine where these
30 to 40 acres exist if they do exist. Also it
would seem that these 30 to 40 acres of lakeshore
would be developed one way or another under any
of the alternatives not just the alternatives that
include a sanitary sewer system. ;
Page 16 The first paragraph says that only two cases of
possible health hazards associated with septic ;
tanks have been documented. These two cases were
wells with high nitrate levels. There are several
instances of backups and wastewater being discharged
to road ditches and these represent health hazards.
Page 45 The last paragraph states that the well water
analyses conducted in 1979 were not complete :
enough to implicate human waste as the source of
pollution in the water of some of the wells. Did
EPA conduct studies to further determine if human
waste were the source of this pollution? If not,
why not?
Page 53 The last paragraph indicates that total and fecal ;
coliform levels near shore were acceptable by
Minnesota Health Department and MPCA standards,
yet the levels in the inlet and outlet of Green ,
Lake are unacceptable. How does EPA account ;
for unacceptable levels in the outlet since Green \
Lake has a detention time of 3.7 years and this i
would be significantly more than the life
expectancy of fecal coliform bacteria?
Page 55 Summary of Existing Data. Again the comment
should be made that the timing for the aerial .
survey, the sanitary survey and Kerfoot's septic ; --.-,, -,
snooper survey was poor, and impacted the results. j )«-', ' i.^i,>*'
i ^^}- *'0-i
-------
U.S. Environmental Protection Agency
Page 4
August 9, 1979
Page 67 At the top of the page it says that Kerfoot found
very low fecal coliform levels in the surface water
located at the discharge of septic plumes. This
should be expected since a dormant plume or even
an erupting plume in March with very cold water
temperatures would not be expected to contain high
levels of fecal coliform bacteria.
Page 71 The last paragraph expresses concerns over disturbing
wetlands. One of the concerns is that dewatering
for a centralized sewer system would lower the
water level in wetlands. This would also be a problem
for the EIS alternatives since cluster systems would
require at least some sanitary sewer collection lines.
Also, the location of several of the cluster sites
may require the construction of a forcemain directly
through wetland areas.
Page 110 The last paragraph describes the spray irrigation
system and mentions a design application rate of
2 inches per week. This is the maximum allowable
application rate according to MPCA guidelines. How
many weeks would this wastewater be applied? It
has been ROM's experience that acceptable application
rates in agricultural areas similar to Green Lake
are usually in the range of 18 inches per year or
less.
Page 111 The description of the rapid infiltration system
does not give an application rate or number of
days storage required.
Page 114 The last paragraph shows 25 percent of the residences
going to cluster systems. After reviewing the area
around Green Lake, this seems like a low percentage
based on Kandiyohi County and state standards
and requirements. An increase in this percentage
may affect the cost-effective analysis presented
in the EIS.
Page 120 At the top of the page, it says that the facilities
plan does not address sludge disposal from lagoons
in detail. This would imply that the facilities
plan is not complete in this respect, yet it has
been RCM's experience that sludge disposal, other
than hauling grit and screenings to a sanitary
-------
U.S. Environmental Protection Agency
Page 5
August 9, 1979
landfill, is not required for stabilization ponds
during the 20-year planning period. The EIS states
that sludge disposal would be by contract hauling
and that farm lands are typical disposal sites for
septic tank pumpings. The information in the EIS
is insufficient for public comment and does not
adequately discuss sludge disposal per MPCA guide-
lines.
Page 120 The third paragraph says it was assumed that septic
tanks have to be pumped every three years. Is
this adequate and regular maintenance? It would
seem that the tanks should be pumped more frequently.
Page 135 Under the description of EIS Alternative 3. Why
weren't stabilization ponds with alternative dis-
charge points considered without land application?
It has been RCM's experience that stabilization
ponds, where adequate, are more cost-effective
than land application alternatives.
Page 141 Under the description of EIS Alternative 4. The
same questions apply to this alternative as to
Alternative 3.
Page 141 Under the description of EIS Alternative 5. Again,
what would be the application rate for this alter-
native? The description of this alternative shows
15 weeks of storage; it should be noted that MPCA
guidelines require at least 210 days storage.
What type of application method is anticipated
under this alternative? The recommended area
for siting the spray irrigation alternative is
a wooded area and would probably require fixed
irrigation equipment. Why weren't stabilization
ponds with alternative discharge points considered
without land application for this alternative?
Again, it is noted that stabilization ponds alone,
where adequate, are often more cost effective
than land application alternatives.
Page 141 Under the description of EIS Alternative 6. Why
weren't stabilization ponds or land application
for Spicer and New London considered? It would
seem that additional alternatives should be
considered here since tertiary treatment and its
-------
U.S. Environmental Protection Agency
Page 6
August 9, 1979
inherent chemical costs could place substantial
financial burdens on these communities. The
chemical treatment experiences at Ely, Minnesota
are apparently being overlooked by EPA.
Page 144 Under the description of the EIS Limited Action
Alternative. This alternative includes upgrading
50 percent of the on-site systems, but does not
include anything for upgrading the 25 percent
of the systems that were clustered under EIS
Alternatives 3, 4, 5 and 6. Shouldn't the 25
percent that was clustered under other alternatives
receive some type of upgrading under the limited
action alternative? It is questionable whether
this alternative is responsive to the needs at
Green Lake.
Page 161 Mentions that a survey of archaeological and
historical sites needs to be done as part of
Step 2. MPCA requires that these surveys be
done prior to the completion of Step 1.
Page 163 Under the section describing user charges, the
EIS mentions that a reserve fund equaling 20
percent of capital cost is included in the
user charges shown. Is this 20 percent of all
capital costs? Is this included in the cost-
effective analysis? More detail should be shown
either in the EIS or its appendix regarding the
cost-effective analysis. It is not possible
from the information shown to determine the
adequacy of the cost-effective analysis. Detailed
cost breakdowns should be shown in the EIS for
all elements of the cost estimates and the cost-
effective analysis.
Page 165 The first paragraph says that EPA grant funding
would be 85 percent of 95 percent of the capital
cost of on-site/cluster systems. Why is 95
percent used rather than 100 percent?
The implementability of the EIS alternatives in regards to
on-site/cluster systems may be very difficult. Land may not
be available for cluster site systems without condemnation.
Development of an equitable user charge system will be difficult.
The risks involved and the difficulty in implementability
should receive further consideration in the development of
the EIS.
-------
U.S. Environmental Protection Agency
Page 7
August 9, 1979
It is noted that the recommended alternatives in the EIS require
further study. The further studies that are required may to
some extent modify costs presented in the EIS and therefore the
EIS conclusions and recommendation could be affected. It should
be noted that this study is not complete at this time and that
final conclusions will be made and presented after additional
studies have been completed.
The EIS states that 8 percent of the pollution based on phosphorus
loading going into Green Lake comes from septic tanks. The EIS
seems to indicate that 8 percent is not significant and therefore
the sewering of Green Lake is not plausible to EPA. It should
be noted that 8 percent pollution is not a regulatory level
below which funding cannot be made. In the case of small
communities located on the Mississippi River or other rivers
throughout the state and country, if they were to discharge
raw sewage their contribution to the total pollution would still
be significantly below 8 percent. Comments that refer to this
8 percent phosphorus contribution by septic tanks as being in-
significant to the water quality of Green Lake would seem to
be irrelevant and misleading, and consideration should be given
to modifying these comments in the EIS.
If you have any questions concerning these comments, please
contact me.
Yours very truly,
RIEKE CARROLL MULLER ASSOCIATES, INC.
Sam L. Claassen, P.E.
SLC:mt
cc: Wally Fischer, Chairman, Green Lake Sanitary Sewer & Water Dist
Wally Gustafson, Attorney
Doug Noyes, Noyes Engineering
Greg Vanderlaan, EPA
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Route 1, Box 76
Spicer, Minnesota 56288
August 11, 1979
Ret EIS, Case Study No« 2,
Green Lake, Kandiyohi County,
Minnesota, June 1979
Mr. Gene Wojcik
Chief, EIS Section
U. So Environmental Protection Agency
Region V Environmental Engineering Branch
230 South Dearborn Street
Chicago, Illinois 60604
Dear Nr. Wojcik:
A oo nsiderable number of us who are Green Lake property owners are disturbed by
the draft of the EIS submitted to us this summer,, As we move from segment to seg-
ment of the report, we are struck by the apparent superficiality of your studyj
e.g., your conclusions regarding algal growth in Green Lake, your summary of
faulty c-eptic tanks around the lake, your recommendation of duster systems with-
out an on-site examination of potential availability of land for drain fields, and
your apparent indifference to nitrate-nitrogen content in wells along the east
shore, to name just a fewe At the hearing on August 4, Engineer Clauson raised
26 point-by-point issues; we hope that his questions are part of your record. Be-
sause we are also disturbed by the apparent reluctance of a group of self-declared
spokesmen for property owners to report to you any questions that take issue with
your recommendation of Alternatives 4, 5, and 6, especially 6.
Therefore, my wife and I, who are permanent residents on theteeuth shore of Green
Lake, wish to raise these questions with you:
1) Will you be making another examination of increased algal growth in Green Lake?
Yfa hpve noticed a considerable increase on the lake bed along our shore, and our
observations on this location date from 1972. Our summer living OB Green Lake
dates back to Mrs. Olson's childhood in 1930.
2) Will your lot-by-lot survey take a good hard look at septic tanks, wells,
drain fields, and soils on each lot (not just samples) in order 4.c detect problems
which your Septic Snooper did not detect, nor your questioner in November 1978?
3) Do your calculations of cost-effectiveness for Alternative 6 allow forj
a
b
c
d)
the willingness of farmers to allow their land to be used at all for
cluster drain fields,
the price farmers are likely to ask for such land, if they are willing,
the price of long-term easemant; which take the land out of production,
the length of time farmers may take to negotiate the use of such tracts?
4) Does Alternative 6 address the problem of nitrate-nitrogen in water wells
along the east shore? Private tests have indicated high contents, and in Appen-
dix C-l, the figures of SSU numbers 55 and 73, for example, should alert you to
the problem, which could be serious.
We appreciate your efforts to determine cost-effective solutions to our problems,
but we hope that such calculations will include all potential costs and not just
write some of them off as "a local problem," as one of your spokesmen has dismissed
them. We sincerely hope that from here on, your surveys and examinations will be
made on the spot by persons who care to become familiar with the terrain and will
not treat the situation just theoretically.
Spokesmen for your office who treat the situation superficially do not reflect
well on you or on a federal office. Neither do their casual attitudes toward the
passage of time. May we suggest that they have already used up their quota of un-
conscionable delays in this matter.
-------
As a final comment, it is too bad that the EPA oan't recommend to states and
counties the establishment of water management districts, adtthere are in northern
Texas, for instance. If it is true that the State of Minnesota owns all the water
in the state, then why shouldn't a countywide or regional management district cope
with water quality problems through authority to advise and "manage" lakeshore and
riverbank residents, municipalities, farms, industries, and all sources which im-
pact on watsr?
Thank you for your attention. We beg you to rememberwe shall likely have to live
with your decisions for the rest of our lives.
Respectfully yours,
(Mr. and Mrs. L. W, Olson)
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Minnesota Pollution Control Agency
Mr. Gene Wojcik AUG 1 * 1979
Chief, EIS Section
Region V
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Re: Draft Environmental Impact Statement
Green Lake Sanitary Sewer and Water District
Kandiyohi County, Minnesota
Dear Mr. Wojcik:
The Minnesota Pollution Control Agency has completed review of the
Alternative Waste Treatment Systems for Rural Lake Projects: Case
Study Number 2, Green Lake Sewer and Water District, Kandiyohi
County, Minnesota.
In general, we concur with most of the conclusions of the report.
Specifically, we agree that:
1) Improved maintenance and/or upgrading of inadequate existing
on-site systems will substantially reduce the problems caused
by them.
2) That the centralized treatment alternatives (Facilities Plan
Proposed Action EIS alternatives 1, 2, and 3) are not cost
effective solutions to the wastewater treatment problem currently
existing in the study area.
3) EIS Decentralized treatment alternatives 4, 5, and 6, can all
be considered cost-effective solutions.
4) Additional Step 1 work should be completed to develop a detailed
cost-effective analysis of EIS alternatives 4, 5, and 6, and
arrive at a specific recommended alternative.
In spite of our general concurrence with the report, there are
several areas that we feel require further attention. Some of these
concerns could be addressed in the final EIS and the others could be
handled in the amended Step 1 Facilities Plan.
The Agency feels that the following general concerns should be
(612) 296-7208
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Mr. Gene Woj c ik
Page Two
AUb I .] 1979
addressed in the final EIS:
1) The most important point of discrepancy seems to be between
this Agency's definition of "need" and that of the Environmental
Protection Agency's. "Need" for wastewater treatment, as
defined in the Environmental Impact Statement, is proven only
if there is positive, physical evidence of failure of a system.
This includes violation of water quality standards, obvious
physical failures, such as sewage on the ground surface, and
public health hazards. These criteria are performance standards,
If we can see and prove that the system is not working, it is
determined that there exists a wastewater treatment need.
The MPCA, however, feels that there is a second group of criteria
that can be used to determine a need. We believe that along
with the performance-failure criteria described above, a set of
inferred-failure criteria can be applied. This set of criteria
is based on research and experience with on-site systems.
Guidelines have been determined and are being used as local and
state regulations applying to on-site systems. These guidelines
include ranges and limitations for such factors as:
A) soil percolation rates
B) slope
C) setback distances from wells, property lines, waterfront
D) depth to groundwater table or bedrock
E) sizing of septic tanks and drainfields.
Using these criteria, it can be determined that a particular
on-site system will probably fail in the near future, or that
it is now failing without any obvious evidence of failure.
For example:
a) A drainfield is installed in the groundwater, con-
taminating it, but this hasn't shown up yet, because
movement of the groundwater is away from the lake and
the well.
b) A conscientious homeowner is limiting use of water in
an effort to avoid problems with a system in an area
where failures are common. Normal use would result
in a failure, but the system is defined as "no need"
because failure is not apparant. The result is that
the homeowner must replace the system when it fails
in a few years at his/her cost. Local state, and
county standards for on-site wastewater treatment
systems are design oriented. The design standards in
these regulations can be used both to install a
system "to code" and be relatively sure of success,
and to determine if an existing system is probably
failing or likely to fail in the near future.
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Mr. Gene Wojcik
Page Three
AUG i 4 1979
EPA standards (NPDES permit, H20 quality criteria) are based on
performance.
The variability of soils, groundwater hydrology, and the large
number and vast dispersion of on-site systems makes monitoring
economically unfeasible.
This particular EIS is part of a case study, and therefore will
set a precedent for future EIS's and Facilities Plans, for
Alternative Wastewater Systems for Rural Lake Projects. There-
fore, we feel that it is very important for this conflict in
definitions of "need" between the MFCA and the EPA to be
resolved. General assessment techniques must be consistent
from agency to agency for the construction grants program to be
valid and workable.
By allowing "working" systems a variance if they do not meet
state/local regulations, existing state and local programs will
be weakened.
Of course, minor violations of certain criteria, such as set-
back distances from the house or property line, could be allowed,
This could be left to the discretion of the consulting engineer
and the city, and would vary.
It is the MPCA's recommendation that the definition of "waste-
water treatment need" be changed in the final EIS, and that
additional Step 1 work document current and potential problems
using WPC 40 as a guideline. Kandiyohi could adopt V7PC 40, and
then issue variances only for horizontal setback distances from
buildings and property lines on use by use basis.
2) The draft EIS does not sufficiently assess the issues of second
tier development, inducted development or conversion pressure.
The statement that 30 - 40 acres might be developed does not
provide sufficient detail. In future such EIS's, the location
of developable platted lots and unplatted acreage should be
shown in map form, and various constraints on development
indicated (zoning, lot limitations). Differential impacts of
each alternative could thus be assessed. Location of sensitive
areas should also be indicated on such a map.
3) It is further recommended that the Generic EIS include a review
of historical data (building permits) in similar lake areas
which have been sewered (i.e. Alexandria, Minnesota), and those
which have not. Such a comparative review, if adequately
performed, will provide information - which may be applied to
all such projects.
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Mr. Gene Wojcik
Page Four
AU6 1 4 1979
4) In view of the fact that extensive construction is expected
along the entire shoreline of Green and Nest Lakes, it is
recommeded that the archeological survey be performed during
subsequent facilities planning, rather than merely prior to
construction, so that those survey results can be input to
facilites planning. This is contrary to the recommendation in
the Draft EIS.
5) We are somewhat concerned with the population estimates and
projections. The occupancy rate for seasonal dwelling units
appears to be six persons per household. Was this in fact
enumerated in the Directory and does it in fact, reflect actual
occupancy or simply size of the owning family. (Not all of
whom may be present.) It is also not apparent in the draft how
these populations impact engineering design. How would pro-
jections change if shift-shares methodology or housing stock
methodology were used?
6) It is recommended that future EIS related populations in geo-
politically indiscrete planning areas be estimated by housing
count in conjunction with a 20% sample census (which could be
performed during the summer season by an already trained U.S.
census ennumerator). Projections of population should be based
on housing stock methodology.
7) Performance of a census will also enable reasonably accurate
determination of socioeconomic data relating to seasonal
residents, which was not addressed in the draft EIS.
8) The soil maps in appendix A-l, figures 5 and 6, indicate
limitations, but do not identify whether those limitations are
for on-site systems, rapid infiltration, or land applications.
It would be preferrable to indicate soils types along with the
degree of limitation. This is easily obtainable from the Soil
Conservation Service.
9) On what basis was the selection of the potential land applica-
tion sites made?
10) In the course of documenting malfunctioning systems, three
surveys were performed. It would be desirable to correlate
these data on a house to house basis in future similar EIS's.
It would also be desirable to present such information on a
map of sufficient scale.
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Mr. Gene Wojcik
Page Five
AUG 1 4 1979
11) Use of a multiplier of 1.0 to account for day use and seasonal
visitors should be clarified.
12) More detailed justification, such as historical experience, or
numbers of permits, should be provided for assuming a 50%
construction rate for on-site systems (p. 114).
13) Figure III-l, P. 105, depicts both a forcemain and a pressure
sewer in a common trench. Only one pressure main is needed.
The following comments, along with a detailed lot by lot survey to
determine need, and other tasks, should be addressed in subsequent
Step 1 facilities planning work:
1) The draft EIS discusses a minimum vertical separation between
treatment system and groundwater table of four feet. WPC-40
stipulates three feet. While the county has every authority to
retain the obsolete standard, the three foot standard should
apply in construction grants projects within the state of
Minnesota.
2) Limiting factors such as steep slopes, high groundwater, and
rapid or slow permeability are limiting factors for standard
below grade septic tank/soil absorption system(st/sas). Systems
can be installed on slopes with drop boxes and the other limiting
factors can be compensated for by the construction of mound
systems. This fact should be recognized in subsequent facilities
planning.
3) The role of the managing agency relative to st/sas and cluster
system maintenance should reflect PRM 79-8 and Region 5 EPA
policy. This also applies to user cost and eligibility
estimates.
4) The costs for the collection system in the EIS are the result
of some conservative and contradictory assumptions. It is
assumed that the average depth for a gravity sewer will be 15
feet. However, it is also assumed that the area is generally
flat, therefore, a large number of lift stations will be
required, and the maximum depth will be 16 feet. We recommend
that the average gravity sewer depth be assumed to be 12
feet = (8 + 16) t 2. Also, USGS topographic maps should be
used to estimate relief. A 1/2 - 2/3 reduction in the number
of pumping stations may result.
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Mr. Gene Wojcik
Page Six
AUG 1 4 1379
5) A more detailed and documented cost breakdown for both on-site
and cluster systems should be provided. The Arthur Beard
Engineers, Inc. report "Green Lake, Minnesota" dated October 2,
1978, may be used as a resource and expanded upon. In the
report, $1262/system is used as a cost for and individual
system. We feel that $1500 - $2000/system is a more likely
cost, considering that some sites may require more costly mound
systems.
6) Maintenance costs estimated in the EIS seem high, but uniformly
so for all systems.
The overall result of the above comments is a lowering of Facilites
Plan proposed alternative and EIS alternatives 1 and 2 costs by up
to $1.5 million and a raising of EIS alternatives 4, 5, and 6, by
$300,000. However, the conclusions and recommendations of the EIS
would remain unchanged. EIS alternatives 4, 5, and 6, would still
be most cost-effective.
In summary, our main concern is with the method of assessment and
definition of need. We recommend that the basic approach to assess-
ment criteria be redefined in the EIS, and that these revised criteria
be acted upon in the Facilities Plan.
If there are any questions, please do not hesitate to call.
(i*4ej
' V /Y sT
Rodney Ev Massey, P.EJJ
Facilities Section ^
Division of Water Quality
REM/DLT:pa
cc: Sam Claassen, RCM
Green Lake Sanitary Sewer and Water District
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Minnesota Pollution Control Agency
'" r "- " ' AGENCY
December-4, 1979
Mr. Greg Vanderlaan
Water Division
Region V
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Vanderlaan:
Accompanying this letter you will find additional comments on the Draft Environ-
mental Impact Statement for Alternative Waste Treatment Systems for Rural Lake
Projects, Case Study Number 2, Green Lake Sanitary Sewer and Water District,
Kandiyohi County, Minnesota.
These comments relate primarily to the assessment of point source vs. non-point
source phosphorus contributions in the Nest Lake and Green Lake watershed.
Please let me know if you have any questions.
Sincerely,
Craig N. Affeldt, Head
Lake Studies Unit
Surface and Groundwaters Section
Division of Water Quality
CNA-.jw
Enclosure
(612) 296-7256
1935 West County Road B2, Roseville, Minnesota 55113
Regional Offices Duluth / Bramerd / Detroit Lakes / Marshall / Rochester / Roseville
Equal Opportunity Employer
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Comments on Draft EIS - Green Lake Sanitary Sewer and Water District
p. i., para. 2:
This paragraph is incorrect. The assertion that "neither the Facilities
Plan Proposed Action nor the EIS Alternatives are (sic) expected to either
adversely or benefically affect the water quality of the open bodies of
Green Lake or Nest Lake" is without foundation. The statement that non-
point source loading associated with the Middle Fork Crow River constitutes
73% and 96% of the phosphorus input to Green and Nest Lakes, respectively,
is also incorrect. It should be clearly stated that this loading includes
contributions from Spicer, New London, and Belgrade point sources. (Ref.
National Eutrophication Survey Working Papers on Nest Lake and Green Lake).
p. viii., "Surface Water"
Conclusions concerning impacts on Nest and Green lakes should be reviewed
in light of the above comment.
p. 46, no. 5, para. 1, line 11:
Change eastern to northwest
p. 48. footnote to Table II-3:
Footnote should read average flow for a "normalized" or average year.
p. 53:
Appendix C-10, referred to in para. 1, appears to be missing from the Draft
Appendices. This appendix was intended to illustrate nutrient contributions
to Nest Lake, Green Lake and Woodcock Lake, in terms of percentage of phos-
phorus load from individual sources.
p. 53. sec, b, para. 2:
Uas a trend in the water quality of these lakes expected to appear? In
Appendix C-3, 1977 Secchi disc values for Nest Lake and Green Lake are
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- 2 -
plotted incorrectly. Available data do not aopear adequate to detect the
presence or absence of a trend.
p. 49, sec, b, para. 3:
Mean flows presented in the reports of the National Eutrophication Survey
are for a "normalized" or average year, not the period from October, 1972
to October, 1973. Subsequent references to these streamflows should be
corrected.
p. 102, sec, b, para. 2:
Suggest that this paragraph be replaced with the following: In 1976,
the Minnesota Pollution Control Agency (MPCA) limited the amount of
phosphorus contained in household laundry and cleaning supplies sold in
the state to 0.5%. Lawsuits and a temporary injunction prevented enforce-
ment of the rule until September, 1979. Before then, most laundry products
sold within Minnesota were no-phosphate due to voluntary compliance.
p. 103, para. 1, 1i ne 5:
Change 1974 to 1977.
p. 103, para. 2:
Delete last sentence.
p. 144, para. 1:
Do treatment plant improvements at New London include upgrading to meet
MPCA standards of 5 mg/1 BOD and TSS, as well as 1 mg/1 phosphorus?
p. 149, A.I.a., para. 2:
The ranking of nutrient sources presented in this paragraph was not supported
in earlier portions of the report and is in conflict with results of the
National Eutrophication Survey. Figure V-l on page 150 appears to be an in-
accurate portrayal of the NES results which should have been included as
Appendix C-10.
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- 3 -
p. 152, Table V-l:
No information is provided on the derivation of these numbers. The phos-
phorus inputs listed for 1972-1973 conditions actually appear to be the
phosphorus loading for an average year as reported by the National
Eutrophication Survey. The "no action" loadings conflict with the NES
results. These apparent errors would have a substantial impact on Figure
V-2, page 153 as well as the conclusions stated in "Future Trophic Con-
ditions" on page 151.
p. 169, sec. VF:
Impact descriptions for surface water quality should be revised in light
of the foregoing comments.
p. 173. Table VI-1:
Same Comment
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Minnesota State Planning Agency
101 Capitol Square Building
550 Cedar Street
St. Paul, Minnesota 55101
Phone 296-8254
August 3, 1979
Mr. Gene Wojcik
EIS Section
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, IL 60604
RE: Draft EIS/Alternative Waste Treatment Systems for Rural Areas - Case
Study Number 2 Green Lake Sanitary Sewer and Water District Kandiyohi
County, Minnesota.
Dear Mr. Wojcik:
Me have reviewed the Green Lake Sanitary Sewer and Water District draft
EIS and agree that septic systems are not significantly contributing to
water quality and health problems within Green and Nest Lakes.
The selection of any wastewater collection and treatment alternative will
have a minimal impact upon the overall water quality of the lakes because
of the amount of phosphorus entering from the Crow River. The selection
of alternative 6 would upgrade the inadequate Spicer and New London sewage
facilities while alternatives 4 and 5 would also be cost effective, but
encourage additional development in the shore! and areas.
It makes little sense to pursue the selection of a v/astewater collection
and treatment system that will encourage growth beyond existing services
and do little to enhance the water quality within Green and Nest Lakes
without first developing a management plan to limit non-point source
pollution from the Crow River. This issue must be addressed before addi-
tional step 1 studies are commenced.
Sincerely,
Charles R. Kenow, Acting Manager
Program Review and Project Evaluation
CK:RK/pb
cc: Joe Sizer, Director, Environmental Planning
Terry Hoffman, Executive Director, MPCA
AN EQUAL OPPORTUNITY EMPLOYER
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GREEN LAKE SEPTIC TANK QUESTIONNAIRE \ >
f ' \ * "'
1. Do you know the exact location of your septic tank? Yes No ;V *
2. How old is your septic tank? \ N
3. How many times have you had your septic tank pumped?
1977 ' 1978 1979 -'-x '
4. Why was it necessary to have your septic tank pumped?
Regular maintenance
Septic Tank Backup
Have you observed any evidence that the effluent from your
septic tank is overflowing, seeping to the surface or that
your septic tank is not functioning properly? Yes _ No
Name of property owner *'
Fire Number ^
r~
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AGRICULTURAL EXTENSION SERVICE
Ill I UNIVERSITY OP MINNESOTA j Department of Agricultural Engineering
I | 201 Agricultural InglfieWrtig feteilding
1 390 Eckles Avenue >..,.
St. Paul, Minnesota 55108- "*-"*~'
, ,v,
'
. i -. >;,,_.,
August 9, 1979
Mr. Greg Vanderlaan, Project Officer
United States Environmental Protection Agency r
Region IV X,
230 South Deerborn Street
Chicago, IL 60604
Subject: Green Lake Environmental Impact Statement
Dear Greg:
It was a pleasure to meet you and hear your comments concerning the
Green Lake EIS. Apparently there has been alot of local controversy
concerning the sewer plan. The public reaction voiced to me at previous
meetings on the issue was certainly reinforced by the reactions at
the public meeting on August 4. It is quite apparent to me that the
Green Lake Sanitary Sewer Board is not reflecting the majority opinion
of the people involved in the proposed project.
I also was advised of a television program which apparently portrayed
Green Lake as a sea of floating algae and weeds. I enclose for your
information an article by Ken Erickson who serves as a writer for the
publication Outdoor News. I certainly deplore the use of news reporting
tactics which were apparently used in this situation.
I have a number of comments on the EIS and the appendices.
It is extremely difficult to evaluate costs or to compare alternatives.
A cost breakdown would be extremely helpful to evaluate alternatives
four and five. For example, how many onsite systems are being served
by a 25% cluster and how many are being served by a 50% cluster system?
There is no quantity specified so it is virtually impossible to evaluate
whether the costs are reasonable.
In regard to the spray irrigation system for alternative five, it seems
to me that $450,000 is extremely high for an irrigation system. I learned
at the meeting on Friday night that 165 acres was suggested because
of a 1.8 inch per week application based on nitrogen uptake for alfalfa.
Alfalfa is a very poor crop to use for removal of nutrients. First of
all it is legume which has root nodules formed by bacteria which fix
nitrogen from the soil air and transform it into nitrates which are
-
UNIVERSITY OF MINNESOTA, U.S. DEPARTMENT OF AGRICULTURE, AND MINNESOTA COUNTIES COOPERATING
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Mr. Greg Vanderlaan
August 9, 1979
Pa-.e 2
used by the legume. While some yield increases have been shown by adding
commercial nitrogen fertilizers to alfalfa, the plant certainly is not
one that should be used to remove nitrogen from wastewater effluent.
I simply do not understand the statement referring to a "high rate of
application and because the plant is a perennial." The rate of infil-
tration will be dependent upon the soil texture and the plant cover.
Alfalfa has no higher rate of infiltration than any grass cover such
as Reeds canary grass or bromegrass. Also, both of these grasses are
perennials. I recall having read research to the effect that Reeds
canary grass can remove up to 300 pounds of nitrogen per acre per year.
Also, Reeds canary grass flourishes under wet soil conditions such
that considerably more than two inches per week could be applied.
Any supplemental nitrogen to grow and is extremely responsive to add-
itions of nitrogen fertilizer, Consequently, the ideal crop is one
of the grasses and certainly not alfalfa. The statement on Page 141
of the EIS indicates wastewater storage of 15 weeks. Apparently this
is an error since we certainly cannot apply wastewater for the other
37 weeks in Minnesota.
I strongly favor the wastewater treatment by surface application rather
than the rapid infiltration method suggested. If the wastewater flows
through a coarse soil with a limited amount of phosphorous fixing capacity,
it will not be very long before the water percolating downward has the
same phosphorous concentration as that which is applied. Rapid infil-
tration would not remove any of the nitrates as these are water soluable
and will move with the percolating water. Consequently, about all
the rapid infiltration will do is a small polishing of suspended solids
or BOD. As far as the nutrients are concerned, the wastewater might
as well be pumped directly into the receiving stream without going
through the expense of constructing a rapid infiltration system.
I suspect that the local citizens are in favor of rapid infiltration
because of the adverse reaction by farmers to spray irrigation. However,
there has recently been some excellent publicity on the use of wastewater
from the Paynesville, Minnesota sewage treatment facility. Perhaps
this publicity will help to offset some of the bad publicity circulating
in the Spicer-New London area.
Should the spray irrigation method of treatment receive adverse acceptance
by the public, I would offer a third alternative which I believe is
superior to both the spray irrigation and certainly vastly superior
to the rapid infiltration. This would be surface spreading of waste-
water effluent by gravity over basins upon which Reed canary grass or
some other grass is growing. The effluent would be spread over the
area by gravity rather than into the air under pressure so there would
be no aerosol problem. Pumping costs would be minimal since the only
head required would be elevation and friction loss in the pipe necessary
to transport the effluent to the field. As I indicated above, Reeds
canary grass will accept effluent applications far in access of two
inches per week and effectively utilize all of the nitrogen and phos-
phorous. I do not recall seeing any statements made concerning the
concentrations of phosphorous and nitrogen in the secondary effluent
but certainly the amount of acreage required would be considerably
less than the 165 acres proposed for the spray irrigation system.
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Mr. Greg Vanderlaan
August 9, 1979
Page 3
It was indicated to me that some type of 3-way valve is suggested for
the drainfield systems to be used for the proposed cluster systems.
I am not sure what valve was in mind, but the proper way to design the
drainfield for the cluster system is to utilize drop box distribution.
With drop box distribution only that part of the soil absorption system
which is required is actually utilized. It is particularly applicable
for varying flows such as from seasonal businesses such as resorts or
for cluster systems, such as those proposed. There should be no need
whatsoever for any type of valve in the soil absorption system.
In general, 1 believe that the prices proposed for the cluster systems
are quite high. I have not had the opportunity to review the booklet
from Beard Engineers which you loaned to Mike Hansel. However, as I
understand it their frost bury depths are exceptionally deep and prob-
ably not at all necessary according to our experience in Minnesota.
Appendix H-l states some design assumptions. I believe that the flow
of 60 GPCD is reasonable but I have difficulty following the reason
for the peak flow rate of 45 GPM. I seem to recall somewhere in the
appendix that it was stated the peak flow from a home was approximately
25% of one days sewage flow. In the pages entitled "Suggested Procedures
and Criteria For Designing Collector Sewage Systems" taken from my 1978
Home Sewage Treatment Workshop Workbook we suggest that the pump should
be capable of handling 25% of the total estimated daily sewage flow
in a one hour period. With 3.5 persons per three-bedroom home as
stated in Appendix H-l, there is a generated wastewater flow of 210
gallons per day. To pump 25% of this in a one hour period requires
a flow rate of 52.5 gallons per hour. The design peak flow of 45
gallons per minute is equivalent to 2,700 gallons per hour or would
handle a total of 51 of the above homes. This seems to be a considerable
over design which would be reflected both in pump size and in size of
pressure line from the pump to the drainfield trench area. It is diffi-
cult to make a thorough analysis of the design specifications because
of the decided lack of information presented by the engineers. This
is also quite true in the other areas which I pointed out above.
On Page 12 of the EIS it is stated that an estimated 55% of the on-site
wastewater disposal systems around Green Lake cannot comply with the
four foot separation. I wonder if a more accurate statement would be
that the homes do not comply.
As an interesting sidelight to this discussioa, after the hearing on
Saturday, Mike Hansel, Dick Flisrand and I drove to the home of Mr.
Leo Halliday at his request. His sewage treatment system had recently
been added to by a local plumbing agency with both the septic tank and
drainfield located under his driveway. Also, apparently the trench
rock was not protected by hay or straw and untreated building paper
prior to backfill. Mr. Halliday's system certainly did not conform
to the four foot separation or to the size requirements of WPC-40.
However, he had sufficient area of suitable soil on his lot to install
a system which would easily comply with the provisions of WPC-40.
In complying with these provisions, his sewage treatment system will
provide excellent sewage treatment.
-------
Mr. Greg Vanderlaan
August 9, 1979
Page 4
On Page 43 it is incorrectly stated that the Department of Health reviews
plans of public water and sewer improvements and regulates on-site
sewage disposal systems. It is my understanding that both the sewer
and the on-site systems are reviewed and regulated by the Minnesota
Pollution Control Agency. On Page 63 it is stated that the size of
the septic tank and the soil absorption system must meet the criteria
outlined in Appendix C-7. First of all, I believe that the proper
appendix number is C-8. However, this is not the important point which
is that the Kandiyohi County sanitary code does not provide any criteria
for sizing the soil absorption system.
It is my observation that Kandiyohi County has provided minimal assistance
to the residents of Green Lake concerning the proper design, installation
and maintenance of their on-site sewage treatment systems. Much of the
information contained in the Kandiyohi sanitary code is copied directly
from the model ordinace proposed by the Minnesota Department of Natural
Resources. This is basically the reason for four foot separation which
is included in the code and seems to be such a point of great discussion.
If Kandiyohi County copied the current Department of Natural Resource's
regulations the number would read three feet.
On Page 63 some reference is made to undersized septic tanks with no
particular reference as to the actual tank volume. The initial volume
of a septic tank is based on storage for sludge at the bottom and scum
floating at the top. If the septic tank is so small that the daily
sewage flow passes rapidly through it, then some of the solids can be
washed through the tank. If, however, there is approximately one days
detention time in the tank, the solids will settle out and the septic
action will take place. However, for the smaller tanks removal of
solids will be required at more frequent intervals. As an example,
a 750-gallon septic tank may be completely adequate for a three bed-
room home if the tank is cleaned at the proper intervals. On the other
hand, a 1,200-gallon septic tank may not be adequate for another three
bedroom home if the tank is not cleaned as necessary. Therefore, a
maintenance schedule must be considered with any septic tank which is
of adequate size to reduce flow velocity and to provide separation of
sewage solids.
On Page 122 the statement is made that sand mounds "do not always provide
satisfactory service." Properly designed mounds have the same treatment
capability as properly designed drainfield trenches. Pressure distribution
over the rockbed of the mound provides for adequate removal of pathogens.
Soil with phosphorous fixing capabilities under the mound provide for
removal of that nutrient. While the cost of a mound may vary consider-
ably around the state depending on local contractors and haul distances
for materials the price ranges between $2,000 and $3,000 for the mound
itself. Added to this must be the cost of a septic tank and a small
lift station.
On Page 112, I would hope that evapotranspiration systems are not being
suggested for use under Minnesota climatic conditions. In an area where
-------
Mr. Greg Vanderlaan
August 9, 1979
"age b
the rainfall and evaporation are approximately equal there is little chance
for a total evapotranspiration system to work unless considerable extra
energy is supplied.
On Page 113 I would again caution the use of hydrogen peroxide as a
"treatment" to remove the organic mat from an underlesigned or over-
used sewage treatment system in sandy soil. If the hydraulic capacity
of an underdesigned soil system is maintained by the use of hydrogen
peroxide, the result will be inadequate sewage treatment. Surface pond-
ing of sewage tank effluent usually means that more sewage is being generated
than the system was designed to treat. The system may be structurally
sound but inadequate in size so that ponding occurs. If the use of
hydrogen peroxide on such a system eliminates the surface ponding, such
use also eliminates sewage treatment.
Greg, as I stated at the meeting on August 4, I am very happy to see
that the EPA is indeed taking a hard look at all sewage treatment systems,
including on-site systems. While there are some deficiencies in the
reporting of the cost figures, I don't really think it would make much
difference in the outcome as far as which alternative is the most cost
effective.
I hope that my above comments will be helpful to you in evaluating EIS.
If you have any questions concerning my comments, please do not hesitate
to contact me. Again, it was a pleasure meeting you and Gene in Wilmar
and I look forward to future associations.
Sincerely,
Roger_ E. Machmeier
Extension Agricultural Engineer
REM/bjf
Enc;
-------
P*
-------
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION 5
182O9 DIXIE HIGHWAY
''77777*" HOME WOOD ILLINOIS 8O43O
August 30, 1979
IN REPLY REFER TO
HED-05
Mr. Gene Wojcik
Chief, EIS Section
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
The draft EIS prepared for the Alternative Treatment Systems for Rural
Lakes Projects, Kandiyohi County, Minnesota, has been reviewed. It is
difficult to determine from the exhibits if the proposed action will
have an effect upon any existing or proposed highways in the area.
The draft EIS does not specifically address this issue. It is therefore
recommended that the final EIS address whether or not any highway impacts
are anticipated. If they are anticipated, the final should specifically
address the impacts and proposed mitigation measures.
Sincerely yours,
.-) Donald E. Trull
J Regional Administrator
-"y r/ '-s'
d- 'Z
By:
W. G. Emrich, Director
Office of Environment and Design
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
NORTH CENTRAL REGION
175 WEST JACKSON BOULEVARD
CHICAGO, ILLINOIS 60604
ER-7y/6c4
August 16, 1979
Mr. John McGuire, Regional Administrator
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. McGuire:
The Department of the Interior has reviewed the Draft Environmental Impact
Statement for Alternative Waste Treatment Systems for Rural Lake Projects,
Case Study No. 2, Green Lake Sanitary Sewer and Water District, Kandiyohi
County, Minnesota. The draft document was found to be inadequate with re-
spect to its description of project-related impacts to fish and wildlife
resources, archeology and recreation.
Section 201(f) of the Clean Water Act encourages "waste treatment management
which combines 'open space1 and recreational considerations with such manage-
ment." Current regulations (CFR Part 35.917-1(j)) require that facility
planning begun after September 30, 1978, must include an analysis of the
recreation/open space potential of the project. Since additional Step I
planning will be performed, we urge the project sponsor to consider potential
recreation benefits and to consult and coordinate with local recreation
agencies. Recent recreation survey results published in the 1979 Minnesota
State Comprehensive Outdoor Recreation Plan show that residents of Region
6E, including Kandiyohi County, most frequently requested increased oppor-
tunities for snowmobiling, hunting, cross-country skiing, camping, fishing,
bicycling, swimming, tennis and hiking.
Because of the high probability of locating archeological sites in the pro-
ject area, a survey to locate such sites should be undertaken so that the
alternatives may be considered as to their impact on these resources. Once
this survey has been performed, you should coordinate with the State Historic
Preservation Officer with regard to the significance of the sites, and whether
any may be eligible for the National Register of Historic Places.
-------
- 2 -
Of major concern are potential impacts to state and federal wildlife areas,
game refuges and other areas such as wetland and woodland complexes. The
final document should discuss site-specific impacts to these areas and the
measures taken to avoid, minimize and/or compensate for losses to fish and
wildlife resources. Attempts should also be made to include those impacts
caused by project-induced development. In addition, Executive Orders 11990
(Protection of Wetlands) and 11988 (Floodplain Management) emphasize the
need for careful planning to avoid or minimize adverse impacts. Since
federal funds are involved, this project must comply with these two Executive
Orders.
Summary Comments
We feel that we cannot adequately assess the impacts of the proposed project
due to lack of the site-specific information cited above. We favor the con-
tinued use of existing on-site treatment facilities since the DEIS indicated
their present use has little effect on lake water quality. We also support
the concept of on-land effluent disposal provided that areas of high wild-
life value are avoided where practical.
These comments do not in any way preclude additional comments pursuant to
the Fish and Wildlife Coordination Act or review of possible federal permits.
Further coordination on fish and wildlife impacts and related aspects may
be initiated by contacting the Regional Director, U.S. Fish and Wildife
Service, Federal Building, Fort Snelling, Twin Cities, Minnesota 55111
(Staff Contact Mr. Larry Sisk - FTS 725-3536).
Sincerely,
David L. Jervis
Regional Environmental Officer
-------
-------
August 20, 1979
Mr. Gene Woj c ik
Environmental Protection Agency
230 South Dearborn
Chicago, IL 60604
Re: Environmental Impact Statement
re Green Lake Sanitary Sewer and
Water Dist., Kandiyohi County, MN
Dear Mr. Wojcik:
I have examined in detail the Environmental Impact Statement with reference
to the above named project. I live in New London Township on Green Lake and am
writing this letter in response to the EIS Statement. I was distressed to learn
of the inaccuracies in your population and socio-economic data presented in your
document. Your statistics were garnered from the permanent population in the
entire township, but 75% of the residents on Green Lake including the residents
of Green Lake in New London Township are seasonal and claim their residence in
other areas of Minnesota and the United States. More particularly, the EIS notes
that 40% of New London Township residents 65 years or older are subsisting at a
poverty level and that 64% in the study area have an annual income of less than
$10,000. These statistics, insofar as the residents of Green Lake are concerned
and the affected area that might be assessed for the project, are simply incorrect
and the conclusions drawn from the study are erroneous.
An interested committee of people who live on Green Lake in New London
Township and who are eminently acquainted with the residents on Green Lake in the
New London Township portion made a careful and exhaustive study of the incomes and
financial worth of those Green Lake property owners.
There are 47 permanent homes on Green Lake in New London Township. There
are a total of 176 lakeshore residents on Green Lake in New London Township, and
of that total only nine, or approximately 5%, would be adversely affected by a
sewer system, either because of their low fixed net income or their minimum net
worth. It is also the opinion of our committee that the same percentages and
observations would prevail around the entire lake in addition to that portion of
the lake which is located in New London Township.
The writer and our committee that made the study respectfully request that
your final EIS Statement should adopt the statistics which are cited in this letter
or conduct your own independent inquiry which I am sure will confirm the data
contained in this letter.
Respectfully Submitted,
,<-Russell Dy,#et!ia
Property, owner on Green Lake
and in New London Township
-------
ZONINQ ADMINISTRATOR
Kandiyohi County
Courthouse
Willmar, Minnesota 56201
Telephone: 235-3917
August 17, 1979
Mr. ₯a31y Fischer
Spicer, MN £6288
RE: A general aralysis of the on-site sewage treatment systems located along
a line from New London Village to the Old Mill Inn on Green Lake.
Dear Uallyr
The analysis begins by designating a corridor between I'few London Village and
Green Lake on township one-half section maps. The corridor follows state highway
# 23 and county road # 131, with several of the platted areas included. The
residences were then designated as to the known st^tis of the on-site sewage
treatment systems. Of the approximate £9 sites reviewed., it was found that 28
sites have installed on-site sewage treatment systems since 1972, which are in
compliance with the minimum reouirements as outlined under Kandiyohi County
Zoning Regulations. Thirty-one sites were existing previous to Knndiyohi County
reaniring permits and inspections.
The existing sewer systems may or may not be in compliance with the minimum
requirements . Sanitation regulations permit existing sewer systems to remain
until such time as they would create a niusance or be in need of repair. If
either of these occur, the system must be updated to comply with the minimum
standards ,
The incidence of known failure for existing sewer systems in this area has been
smoJl. Generally, most all the sites are of adequate size, thus providing suitable
areas in which to install a new system or modify and repair an existing one»
Nearness to ground water table and problem soil types do rot create serious limita-
tions with a very small percentage of exceptions . Water wells in this area are
generally over 5>'0 feet in depth.
In conclusion, I would say on-site sewer systems are providing an adequate means
of sewage disposal in this area without creating pollution problems. This con-
clusion is arrived at because there are adequate lot sir^cs, acceptable permeable
soils with adequate elevation above the ground water tables are present, limitations
on sewer installations are few, congestion of dwellings are not a problem, and the
record of systems which are known to have failed are few<>
Steve Peterson
Assistant Zoning Administrator
Plat attached
enc.
SPrdz
-------
NOYES ENGINEERING SERVICE
P. O. BOX 1314
Phon* 235-2403
WIU.MAR, MINN. 56201
August 2, 1979
li. b. Environmental Protection Agency
Ki.::jinn U
23C South Dearborn Street
Chicago, Illinois 6C16CK*
Green Lake Sanitary Geuer find Water Pibtrint
handiyohi County, Minnesota
F.T.A. No. C271377-01
Environmental Impact Statement
GE-tlemen;
Aflur review of the rnvirnnmentnl rmpnct St.itt Tu:nt Dr.ift, ue submit
heic,uitn data fur your consideration prior tt. finalizing the EIS
Statement.
At th
May
in
17, 1979 conference with FPA officials
LJ.ishingtcm, D.C., UJG indicated Lhnt rev/i
treatment facilities favored mtchnnical
ponds, and because of serious objections
in r-enator Goschuitz's
ULI! c'l.it estimates uf
trBntrnent over stab-
to ponds by area
ilization
formers, me uert; amunding our rBcnnmiundat inn in th& F in i 1 i t ies Plan tn
use of the mechanical facility rather than stabilization pnnds. Thin
was not considered in the Draft of thu EI!J !itatt?mLnt .
Attached are the following:
Revised cost estimate for stnbiJ izrition pnnds
Revised cost estimate for mtchanica] trentment facility
[ Estimated annual C1RM cnsts fnr treatment facilities
Estimated Total Equivalent Annual Costs for each
Revised cost estimate for Colluction (South Shore r.reen L.)
Hevised cost estimate for Hnllbction (Worth Shore Green L.)
Cost estimate for gravity collection sewers for Nest Lake
Cost estimate for on-site R clusters for Nest Lake
Summary of estimated costs for neu Alternates 7 and 8
Summary of all alternatives considered
Description of Proposed Alternatives 7 and fl
Very truly yours,
GREEN LAKE SANITARY SElilER AND UATER DISTRICT
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
Table
I
II
II
IV
X
XI
A
B
C
D
F
Fiscner, Chairman
cc: Minn. Pollution Control Agency
Reike: Carroll duller Associates, Inc.
end/
-------
TABLE I
ESTIMATED CAPITAL COSTS FOR WASTE STABILIZATION
LAGOON WATER POLLUTION CONTROL FACILITY
GREEN LAKE SANITARY SEWER AND WATER DISTRICT
ITEM
Main Lift Station
Portable Pump
Forcemain
Control Manholes
Internal Piping
Concrete Splash Pads
Earthwork
Seepage Control
Erosion Control
Ojtfall Sewer
Flow Metering
Control Building
Pond Prefill
Seeding
fence
Tractor
Electrical
Subtotal
Contingencies (10")
Engineering, Legal & Administration
Operation & Maintenance Manual
Land
UNITS
1 each
1 each
19,200 L.F.
10 each
6,200 L.F.
16 each
110,200 c.y.
276,000 s.y.
27,900 s.y.
5,000 L.F.
2 each
2h. s.f.
L.S.
12 acres
8,000 L.F.
1 each
L.S.
SALVAGE VALUE
$ 50,000
10,000
307,200
25,000
111,600
8,000
137,800
372,600
232,500
90,000
16,000
12,800
5,700
8,000
24,000
20,000
$1,456,200
145,600
240,300
10,000
76,000
--
--
$153,600
12,500
55,800
4,000
68,900
186,300
116,200
45,000
--
6,400
--
--
76,000
Total Estimated Initial Capital Costs
$1,928,100
$724,700
File No. 741001-2
May 16, 1979
-------
TABLE II
ESTIMATED COSTS FOR MECHANICAL
WATER POLLUTION CONTROL FACILITY
GREEN LAKE SANITARY SEWER AND WATER DISTRICT
ITEM
Bar Screen & Flow
Measuring Station
Main Lift Station
Portable Pump
Forcemain
Grit Chamber
Oxidation Ditch
Final Clarifiers
Tertiary Filters
Chlorination Facility
Internal Piping
Outfall Flow Measuring Station
Outfall Sewer
Office Building
Standby Power
Sludge Storage Lagoon
Sludge Truck
Site Grading
Seeding
Fence
Electrical (includes meters)
Subtotal
Contingencies (10%)
Engineering, Legal & Administr
Operation & Maintenance Manual
Land
UNITS
ESTIMATED COSTS
SALVAGE VALUE
1 each
1 each
1 each
12,600 L.F.
1 each
1 each
2 each
2 each
1 each
420 L.F.
1 each
1,000 L.F.
360 s.f.
1 each
1 each
1 each
L.S.
L.S.
1,900 L.F.
L.S.
ation (15%)
$ 23,300
50,000
10,000
201,600
32,100
162,200
102,000
224,300
36,100
42,000
4,000
18,000
11,000
25,000
28,000
56,100
40,000
6,000
19,000
128,600
$1,219,300
121,900
201,200
15,000
5,000
$ 11,600
--
100,800
4,600
57,100
31,000
5,000
12,000
21,000
2,000
9,000
5,500
--
14,000
--
20,000
--
__
--
5,000
Total Estimated Initial Capital Costs
$1,562,400
$298,600
File No. 741001-2
May 16, 1979
-------
TABLE III
ESTIMATED ANNUAL OPERATION AND MAINTENANCE
COSTS FOR PROPOSED WATER POLLUTION CONTROL FACILITIES
ITEM
Salaries
Power
Chemicals
Supplies & Fuel
Scheduled Replacement
(2^ of Equipment)
Independent Lab Testing
Total Estimated Annual O&M Cost, $/yr
MECHANICAL
FACILITY
$21,000
6,200
1,000
5,000
12,900
$46,100
WASTE STABILIZATION
LAGOON FACILITY,,
$ 7,000
1,300
2,000
1,700
1,500
$13,500
File No. 741001-2
May 16, 1979
-------
TABLE IV
ESTIMATED TOTAL EQUIVALENT ANNUAL COSTS
FOR WATER POLLUTION CONTROL ALTERNATIVES
ITEM
1. Total Estimated Initial
Capital Cost
2. Estimated Salvage Value
3. Estimated Equivalent Annual
Cost, $/yr
4. Estimated Equivalent Annual
Salvage Value, $/yr
5. Estimated Equivalent O&M
Cost, $/yr (Refer to Table III)
6. Estimated Total Equivalent
Annual Cost, $/yr
(Line 3 + Line 5-Line 4)
MECHANICAL
FACILITY
$1,562,400
298,600
146,100
7,400
46,100
184,800
WASTE STABILIZATION
LAGOON FACILITY
$1,928,100
724,700
180,200
17,900
13,500
$175,800
File No. 741001-2
May 16, 1979
-------
TABLE X
ESTIMATED CAPITAL COSTS FDR SANITARY
PROPOSED FOR THF: .SPUTH SHORI
SEUER COLLECTION SYSTEM
' fIF GREEN LAKE
ITEM
B" Seuer Pipe ( 0- 81)
11 ( 8-10')
11 (10-12')
(12-14')
(14-16')
11 (16-18 ')
" (18-20')
" (20-22 ')
10" GBLILT Pipe ( 0- 8' )
11 ( 3-10')
(10-12-)
11 (12-14')
(14-16')
" (16-18')
" (18-20')
Standard Manhole, (0-B1)
Extra Dupth Manhole (over 8'
3" Drop Section
Service Dyes
6" Service Pipe
Rock Bedding
L if't Station
6" Forccmain
Cnnnect to Terminal Manhole
Air Release
Channel Crossing
Clear and Grub
.Street Restoration
QUANTITY
205 LF «
2236 LF
4024 LE
5268 LF
2786 LF
1371 LF
1015 LF
829 LE
400 LF
825 LF
1796 LF
614 LF
I860 LE
277 LF
228 LF
75 Each
) 453 LE
35 LF
307 Each
9115 LF
43DO Ton
6 Each
5235 LF
1 Each
1 Fnch
1 Each
12 Tree
Lump Gum
Plus
TOTAL ESTIMATED
UNIT PRICE
^ 12. DO
13.20
14.40
16.00
19.20
21. 6D
24.00
27.60
13.20
14.40
15.60
18.00
20.40
22.80
26.40
660.00
i . 00
120.00
6D.OD
12. OD
4.20
3 0000. DO
9.00
120.00
12 00. [JO
/ 4 00. 00
150.00
2 /GOOD. 00
SUB-TOTAL
25%
COST
Tf'TML
3 2,^60.00
29,515.20
57,945.60
88,502.40
53,491.20
29,613.60
24,360.00
22,880.40
5,2GG.UU
11, HBO. DO
28,017.60
11,052.00
37,944.00
6,315.60
6,019.20
49,500.00
27,100.00
4,200.00
10,420.00
109, 300. OU
18,060.00
180, 000. QU
47,115.00
iro.oLi
1,200.01!
2,4 GO. GO
1,000.00
; 76,000.00
* 1,150,651.00
207,662.90
S 1,430,314.70
Dated August 1, 1979
-------
TABLE: xi
ESTIMATED CAPITAL COSTS FGR SANITARY l^CLJER U ,i LF CT [UIY
IKl'ii.Lir_Q FC'R THE MONTH TjUf^'L OF [jF
13
14
16
19
13
14
15
16
19
14
15
16
19
21
24
27
30
33
1'J
7 2 u
'+00
fj- 1
6
300UU
3
'»
suB-Tr-
;:,
.00
.20
. 40
.00
.?{}
.20
.40
.60
.80
.20
.40
.60
.no
. 2U
.60
.00
.60
.00
.LQ
.nu
. 00
.00
.(JO
.GO
.CD
.60
.00
!- I
j 1L
52
18
13
11
3c;
29
10
n
6
12
36
53
53
38
19
0
4
5
117
59
149
6
k
10 LI
165
1*6
1,175
2 J3
,560.
,536.
,000.
,060.
,n<,n.
,9Ju.
,448 .
,720.
, l+OO.
,520.
,600.
, 114 .
,424 .
, 4 71-. .
,016.
,320.
,280.
,500.
,060.
,F,DO.
,040.
,760.
,240.
, OGij.
, DOG .
,600.
,320.
,974.
,993.
00
00
00
00
00
00
00
00
00
00
00
00
00
GO
OG
00
00
00
00
00
00
OG
Oil
00
00
00
00
00
70
GRANT TOTAL
August 1, 1979
-------
TAOLF A
GREEN LAKE WAT' R AND SF.ldlK DISTRICT
FOLLLHiJlNG IS AN UP-DATED COST ESTIMATE F PR CPLl FCTIOIV ,'iEiJFRS C'N NEST LAKE
(Prifjinal estim.itt" i:pnlflineM in tin; Fu.n, llii 1 i ly flHpnrt nf Due. 197*i)
l\!Cr-.TH SHORE:
ITEM LJUANTITY UNIT PRICE TOTAL
8" Seuer Pipe (10-12')
11 (12-1*4')
" (1*4-16')
11 db-ld')
11 (1M-2U1)
ConL-truct Mranhnlu, cumplute
Construct Riser Aisc
Highujay Crossing
Pumping Station
Forcemain
Construct Service Rr.anch
Restore Bituminous Surface
3100 L F
900 LF
noo LF
750 LF
'4 "HI LF
1C FA
2*> FA
90 LF
50 LF
3 EA
*4^nu LF
60 FA
11QQU SY
SUB -TOTAL
Plus 25%
S 1*4.00
16.00
19.00
21.50
2.'..UU
050.00
70.00
80.00
90.00
30000.00
12.00
*45a.OQ
*+.DO
* «,*40Q
1*4,*4QQ
15,200
IF,, 125
liJ.tlUD
13,600
1,680
7,200
*4 , 500
90,000
52,800
27,000
*4*+,OOrJ
t. 3*40,705
85,175
TGTAl LSTIMMTEO CAPITAL COST $ *425,880
MOTE: Approximate 75% increase yince 197*+.
SLUTri SHORE:
THF AFTROXIMATE CAI ITAL CPST FPR SI ilTH SHPRE IJOl LECT THN
USING THE SAME BASIC UNIT COSTS AS FOR THE NPRTH SHORE IS $ 363,<475
:\GTE: C! ST hSTlr.ATf Q!\! SUMMARY riiFF.T Rl.llfJ[,'Fn IFF Til S BQQ.DGQ.QU.
(USED WITH PM'I [IHFD ALTFR,rJ/iTF 7)
-------
TABLE D
GREETJ LAKE nJATER AI\JG 3EUFR DISTRICT
SLII PORTING DATA FPR PRilt'OSED AL TFRrOATF H FfiR iMC'jT LAKE [ EUFRG.:
BY II\)Si F(JTID!\i Pr THF MCITTH Sl'dRf , IT ]H ESTIMATED THAT /u F'Rf XIMATELY, 20
OUELLRGS UIULO ACCi >"'L'LATE [lIM-^iTE GvBTF^i) l\Ki\ AR! JT ^Q UCULD F3E CCUERED
Il\i 2 CLUGT^Hfl.
:i;;if\!G THE AS; i/r :
?[J fn-sitt: pysti.'ms ,^:J, DOG uarh j' i(;i,Li,JU
^ clustbrs at ,"; 35,QOG each 7U.UQC
i ur;ip£ and collection system 15,ODD
TiTAL rJTIMATEO COST-WORTH S'TOF i; 120,UDD
'-/ UTH GriPRF
Fstimeted 20 an-site systems ;' 3rfOOD each S ^U.UDD
ID Grinder pumps dfitimated C< C1,5DO ear:h 15.GGO
Cnll.cticn cnstb 15, DOG
^P,B larijt! nr 2 n^dller clustpr I'ii.lit: 5u,LJUD
TLTAL :! STl MAT EL CI bT - LuUTh LirlL^C I 12U,ULJa
SUQ-T,:TAL TT NEST LAKF ;,. .7^5,01.10
Add land, Fees, cnntingenciRE 513, QDG
TCTAL r:"JTlf-,ATED COST TU WEST LAI.F Z 3GD,GDD
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TAEL.F C
GREEN LAKE WATER AIYQ L.EIJER nir:TRiCT
fJUMMARY [IF COSTS FOR PROPOSED ALTERNATE 7: Aurjunt 1, 1979
(No grants allowed ?5% Overhead included)
ESTIMATED CCST OF COLLECTION (Worth Shore Green Lake) I 1,^69,966.50
ESTIMATED COST L'F COLLECTION (Snuth Sjliore Green Lake) 1,<+3B, 31**.7Q
GriGER, NEU LLMDOIM S LLlRRIDDR BFTlilEFIM ^96,636.80
iiUE'-Tl'TAL , RHUIMAL C1L.TR1CT Cdl. LFCT J DIM H 3 , ttu^t, 9^0. UL1
ESTIMATED :;;:ST or COLLECTION (NE^T LAKE) (Gravity) $
ESTIMATED COST E.'fl COMBINED MECHANICAL TREATMfNT & 1,562,^00.00
TOTAL ESTIMATED CAilFAL COSTS (ALTERNATE 7) ,; 5,767,320.00
SOMMARY OF COSTS FIR PROPOSED ALTERNATE 8;
(IMa grants allowed '21% overhand included)
ESTIMATED COST OF COLLECTION (North Shore Cretin Laku) $ 1,^69,968.50
ESTir^!ATEO COST OF Cf I LECTION (Suuth ShorR Green Lukn) 1,^38,31^.70
GPlCEf?, NEJ LONDON K, CORRIDOR BETL1EEN i+96,636.80
SOD-TOTAL ORIGINA1 DISTRICT CFLLECTION ^ 3
ESTIMATL., CCST CF OG-lilTE & CLUSTERSWEST LAKE 300,000.00
EGTIKATEO Ct 5T FCR COMBINED MFCHANICAL TREATMENT '" 1, 56? , t+DD. DO
TOTAL EL-TIMATED C'V ITAL COSTS (AITERNATE 8) £ 5,267,320.00
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TAGLF D
GRFErj LAKE [J/'iirn /V"J!J .'iFinFR HIO
SUMMARY OF ALTERNATING 1M F . I . S
.M TTR JATTVE
CAPITAL C, y
[ISM tJ['.';T f'"'-; f Ef? 2U YE/'.HG
Fici]ities I l^n
I l''li t<_!! ."iU t i LT!
All t riV'tu Mo . 1
r\ l i L.I i its3 ",rj. 2
tl Lern i LL Mo . 3
iii/?.br,'. clusters
,\] r,.,i n;jtc Ijn 3
L;/5J1.';', t:lusters
M! Lc.rna te Wo .
u/,:5% clu
;JtE-",-jte i\
l.GuG.GO
i\ (it F e. i r, i 111 LJ
'':ct FsacjiL.lB
3,613, nfjO.cn
4,6Gl,Oi]U.GG
5, 3G7,l]t,U.G!J
3,931,000.00
4,649,000.GO
4, 191 , UGG. Jll
4,9G9,OGu.UG
2,804,GOD.Ou
l,'i22 , niill.LU!
l''M,7UG
1 i'.-f-'JJ
83,100
111, 4 [It,
;, 1,S22,GOU
-',174, DUG
..:,71b,GGG
1,662,000
-5,fJ>(J,OUO
1,770,000
/,14L,GuG
2,228,Qi]G
\LTCH'. JF l\i ;. 7
( Rfeuis inn of F l.in
' t cj, rr.munded in
F "'L I 1 it irs [ l;in )
Hul lt:rt i on G . I r-jke
Cnl.U:nt icn rj.Lakt
,iLTru\:.TF r^D. H
Grc;uitv cull. R. L;ike
On ,jite y, CluKters
fur p.'e;
1,562,400.
'aOOJOGG.
DU )
GO )
5,767,320.
3,404,520.
ast Lake 300,000.
i.n-.icjl TreatmLiit 1,562,400.
5,267,320.
GG
GO
00
no
00
5M,LJUD
'-t .lull )
9G.1GO
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TABLE E
GREEN LAKE WATER AND ^FiilER DISTRICT
[If ;;L'Rli'TlL[\; IIF I'Rril ITiF P CULLTCI IUN AI'J'J iiM,, FEuJAir R FRL :\Ti r NT i I AN
AS DUR RECOMMFNLirU REVISION HF PLAN IN 8-16-76 F'ACIL ITIEC r;LAI\..
Llith the serious objections iu the propun-il fur use of stabilization
ponds for wastbuater treatment East nf Green Lake, trie proposed use
of this method tins been abandoned . However, the cost estimates for
buth stabilization ponds and aeration channel mechanical treatment
contained in tht Facilities I Ian have been amended tn reflect current
cnots and are dtLddied and identified as Tnblbs I and II.
Tht; Facilitibb rj^n did not include any ^eiv/icr; frjr Nest LaKe (uihich
uas nut a part of the Green Lakt Water an.1 cjeujLT Histrict), but pru-
wisicn UHS .'..ariu in thb dLSign of the trunk sewer nn the North side of
Green Lake to accommodate future inclusion of Nest Lake loads.
ALTERNATE 7, submitted for ynur cnnsiriurat iun, propnst.i inclusion uf
ijpiccr, Neiu London, the Spicer-Neu L cmrion curridnr, rj!-:at Lake us inn
' gravity collbction system and all nf Green Lnke i-ii th rjravity seuibrs
leading tn a central uasteuater treatment facility ur., ing the mechanical
up Lien which uuuld be lacatei! Gouth and E'ust nf Lake Calrioun with dis-
charge to the Middle Fork of the Crnw River at a point Fast of Lake
Halnoun. Farriers in that area have indicated nn objection to such a
facility .
ALTERNATE B proposes the same nenenl plan as Alternate 7 except that
in place of gravity collection sewers for Nest Lake, thnt area would
be taken care nf by use of nn-njte anti cluster q round tlinpfcrna] syn terns
di' necessary. Generally, Nest I ike properties are ninre adaptable to
use of this typi1 nf Ryrtems-i than nn:en iaku. | imititinn;; by lot, C.i7f;,
density of occupancy, elevations and tupeyrnphy nre nuTe severe on
Green Lake than on Nest Lake.
As it will be necessary to amend the Facilities I 1, -i upon completion
nf the Fnvironmuntril Impact fltuily ami Report, r:nrj cpun completion of
tht- additional field studies under a proposed ijnnt :;r,u'no'ment tn
determine tl~J potential fnr nn-site and cluster ci.nci'pt ; , these uJ Li "-
n.atives not,e;i abjv/e will be cnvE/red c.,fiip] etely at L:,il. time in th.e
F R c i 1 i t i e s F ' ] -j n .
Tiiese data aiu submitted for [preliminary cr.ri:.; J der.i t inn hy tht,
( Dilution Control Agency, Environmental Frutectir.n Agency and tneir
contractors for prehoring the rnv Ironi^ental Impact [] ta Lernrn L ,
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MINNESOTA HISTORICAL SOCIETY
690 Cedar Street, St. Paul, Minnesota 55707 672-296-2747
July 31, 1979
EIS Preparation Section
Planning Branch
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Dear Sir or Madam:
RE: Green Lake Sanitary Sewer and Water
District for the villages of Spicer
and New London, Kandiyohi County
MHS Referral File Number B99
In September, 1976, our office reviewed the above referenced project
and determined that there was a high probability that prehistoric
archaeological sites (not yet identified) may exist within the proposed
project area. Consequently, we requested that an archaeological survey
be conducted. To date, we have not received any indication that this
work was completed. Therefore, we wish at this time to reiterate our
original request. A copy of our original letter is enclosed for your
information.
Sincerely,
Russell W. Fridley
"Estate Historic Preservation Officer
RWF/cjb
Enclosure
Founded 1849 The oldest institution in the state
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£ ff
30 September 1976
Mr. William G. Kendrickson, P.E.
RIEKE CARROLL MULLER ASSOCIATES, INC.
Post Office Box 130
Hopkins, Minnesota 55343
Dear Mr. Hendrickson:
RE: Historical/Cultural Significance of Proposed
Pollution Control Facility Sites
Green Lake Sanitary Sewer and Water District
File No. 741001-2
We have researched the town site and Sioux Indian Village to which you
refer in vour letter of August 30, 1976. The town site of Irving was
established in 1856 in section 3D, T121-33, and was abandoned in 1862 during
the Sioux Uorisinc. None of the proposed locations will affect the site,
which now appears to be built up in lake cabins. The Sioux Indian Village
appears to be located somewhere in Section 19. T121-33, well away from the
proposed facilities creas. Our records also show prehistoric sites to be
located at the outlet cf Green Lake and on the east shore of Calhoun Lake.
Neither site will be Affected.
Examination of the pertinent tonorraohic nnps indicates that the proposed
facilities will be located within a complex of imrshes adjacent to lakes
Green and Calhoun. Although we do not have sufficiently detailed soil
maps to be certain, it is possible that the marsh areas represent silted
lake basins. Prehistoric sites are frequently encountered along the
shorelines of new-extinct bodies of water; the probability of prehistoric
archaeological sites occuring in any of the proposed facilities locations
is greater than chance. We would therefore request an on-site inspection
of the location you select by a qualified archaeologist. You indicate
that the four locations are now under cultivation, which means that any
prehistoric sites that may be present will be evident on the surface. A
simple walkover survey would be entirely adequate for our purposes, and
would require a very srn^ll expenditure of time and money.
Sincerely,
Russell W. F:idley
State Historic Preservation Officer
RWF/fr
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KANDIYOHI COUNTY BOARD OF COMMISSIONERS
Kandiyohi County Courthouse
Willmar, Minnesota 56201
Ralph M. Demgen
1st District
Virgil M. Olson
2nd District
Earl Larson
3rd District
Mr. -John C. McGuire
Regional Administrator
U. 3. Environmental Protection Agency
230 South Dearborn
Chicago. Illinois 60604
Elroy Lovander
4th District
Richard Post
5th District
Decemb
Wayne Thompson
Adjrjtjiistrative Assistant
CO __
10, 1979 70
rn
' i
_c
rs:
ro
Dear Mr. McGuire:
Re; QREEN
Kgndiyohi County, ift.
O
Recently, it was brought to the attention of the County Board that
the County's septic tank regulations would have to be relaxed for purposes
of implementing the proposed on-site sewage systems as recommended in
alternative 5 and 6 of the EIS. The County Boerd believes that to relax
standards, that are designed to protect the health, safety and welfare of the
public, is a mistake.
It is the opinion of the County Board that the lakes, rivers find streams
of the county are valuable resources that deserve protection above and beyond
those septic tank standards called for in the EI3. In as much as there are no
performance standards on which to judge the effectiveness of on-site systems,
we believe that the present standards must continue to apply. Relaxing the
standards, may in fact, cause unknown damages to the health, safety and welfare
of the community.
The County Board realizes that in many cases on-site systems probably
do not conform to our standards. We also realize that these systems, such as
those around Green Lake, were installed during a period of time when standards
did not exist. It is for that reason that the Kandiyohi County Board supports
a lot-by-lot survey to determine where there are septic systems th;,t do not
meet standards on Green Lake.
V/e fuily roi-liKo tlv-t El" A is net inclined to assist or approve P. central
se.. age system around ^reun Lake. In thn spirit of cooperation it is the County
Board's intention to implement the on-site and cluster system recommendation.
However, at the same time, we would expect that the county's present septic
tank standards be adhered to in the evaluation und design of any on-site system.
Enclosed is a copy of the Kandlyohi County standards for home sewage
systems.
Sincerely,
US GOVERNMENT PRINTING OFFICE 1980750-628
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