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XVI-B-5
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XVI-B-2
-------
B. FEDERAL WATER QUALITY IMPROVEMENT PROGRAMS IN RURAL LAKE
AREAS
This section is a guide to the financial and technical assistance
programs that are available for conducting water quality planning in rural
lake areas in U.S. EPA Region V. This information originally was compiled
under 208 funding for the Tri-County Regional Planning Commission, Lansing,
Michigan, and has been revised and updated for this document. The accompany-
ing matrix identifies Federal assistance programs, the types of assistance
available, eligible participants, and eligible activities. It is designed
primarily for use by the local governing bodies, agencies, organizations, and
individuals responsible for conducting facility planning in rural lake areas.
The matrix is keyed to the Catalog of Federal Domestic Assistance (Office of
Management and Budget, 1980), which gives details of applicant eligiblity and
procedure. Although several programs listed here pertain to issues other than
water quality, the focus is on the relevance of these programs to water
quality management.
The information about these programs is considered current as of 1980.
Programs changes, however, have been made since that time and some proposed
changes have not yet been instituted. Interested readers are advised to check
on the status of specific programs.
XVI-B-1
-------
plans for centralized systems. But eligibility of sewers depends on the
cost-effectiveness of non-sewered alternatives and their ability to meet
project needs.
In almost any unsewered community, there will be properties with
dwellings or places of business on them where standard on-site systems (septic
tank and gravity-fed soil absorption system) just will not work if loaded with
design wastewater flows. Many of these properties might be adequately served
if alternating drain fields, dosing siphon or pumps, elevated mounds, or other
design variations are added. But some of these properties may also have to
accept flow restrictions to allow the systems to work; for example, removing
garbage grinders, dishwashers or clothes washers; replacing faucets, toilets,
and showers with more efficient fixtures; or abandoning plans to expand house-
hold or business size. And some properties may have to abandon soil absorp-
tion systems altogether and use holding tanks with accompanying flow restric-
tions .
Undeveloped land, land that could be developed if sewers were available,
will remain undeveloped unless it is suited for on-site systems or unless
permits for small, effluent discharging systems are obtainable. Depending on
the stringency of regulatory programs, the suitability of sites or streams for
assimilating wastewater, and the local pressures for growth, the lack of
sewers may retard development in comparison with what would occur if sewers
were available.
The costs and the benefits of eliminating water use restrictions and of
fostering land use conversions are relative. With a program of upgrading
on-site systems and improving their management, water use restrictions would
generally increase, since this is one of the most effective means of control-
ling system failures on marginally suitable sites. However, some of the
restrictions to development might be eased if an effective management program
were instituted. But the major benefit of such an approach would be in con-
trolling water quality and public health problems.
Sewering can also control water quality and public health problems,
although some have argued that the problems are just transferred to one dis-
charge point. In terms of societal benefits, the main value of sewering
compared to upgrading on-site systems is that of avoiding water use restric-
tions and increasing community development potential. However, the added cost
to achieve these benefits in most unsewered communities is substantial.
Should the Construction Grants program subsidize this added cost? If the
expressed goals of the Clean Water Act are translated into the criteria for
"need," the answer is clearly "No."
XVI-A-3
-------
Goals and policies to achieve this objective listed in Section 101 make no
mention of improving property values or providing infrastructure for devel-
opment. The reference to public health protection related to "recreation in
and on the water" and the prohibition of "the discharge of toxic pollutants in
toxic amounts" leave little room for debate that water quality and the bene-
fits of activities that improve water quality are the focuses of the Act.
In the statements of goals and policies of the Act in Section 101 and of
the Construction Grants program in Section 201, the following references are
made to non-water quality objectives:
• "...to recognize, preserve, and protect the primary responsibilities
and rights of the States...to plan the development and use...of land
and water resources..."(Section 101(b)).
• encouraging and assisting "public participation in the development,
revision, and enforcement of any regulation, standard, effluent limi-
tation, plan, or program...under this Act..." (Section 101(e)).
• "...application of the best practicable waste treatment technology
before any discharge into receiving waters..."(Section 201(b)).
• "...construction of revenue-producing facilities providing for...
recycling of potential sewage pollutants...confined and contained
disposal of pollutants not recycled...(and) the reclamation of waste-
water..." (Section 201 (d)).
• combining waste treatment management with "open space" and recreational
considerations (Section 201(f) and 201(g)(6)).
• evaluating alternative waste management techniques (Sections
201(g)(2)(A) and 201 (g)(5)).
• reducing total energy requirements (201(i)).
The point of this review is that the Act does not mention, much less list
as goals or even benefits, the property value and community development goals
that applicants might see as their "need" for sewers. Even public-health-
related goals are limited to allowing recreation on or in surface waters and
controlling disposal of toxic substances. Relating this to determinations of
collector sewer eligibility, it is difficult to justify a documentation of
need on any basis other than water quality and public health problems closely
associated with impaired water quality.
The practical effects of this line of thinking are several. These
effects will also result from the termination in 1984 of collector sewer
eligibility. (See amendments to Section 201(g)(l) passed in 1981.)
Obviously, the financial feasibility of sewering previously unsewered
communities is greatly reduced if the collector sewers are not eligible.
Collector sewers represent up to 80 percent of the capital investment in new
centralized wastewater systems. Even when that cost is eligible for
Construction Grants, the local cost per household is burdensome. If it is not
eligible, many unsewered communities simply will not be able to implement
XVI-A-2
-------
A. EPA POLICY REGARDING CONVENTIONAL WATER USE AND POPULATION
GROWTH
In administering the Construction Grants program, EPA will repeatedly
face the issue of sewer eligibility in unsewered areas. (However, with
passage of the Municipal Construction Grants Act of 1981, collector sewers,
except ones funded under governors' discretionary powers, will be ineligible
after September 1984). Eligibility determinations will be based on documented
need, cost-effectiveness of sewers compared to non-sewer solutions, and the
"substantial human habitation" rule.
For most unsewered communities and neighborhoods, non-sewer solutions
will be found to be cost-effective as a result of preliminary cost analysis.
Where the comparison with sewers is closer, the determination as to cost-
effectiveness may have to wait for detailed cost analysis (see Technical
Reference Document IV.A., Cost Variability Study), and the only remaining
determinant will be whether documented needs can be satisfied by non-sewer
solutions. The substantial human habitation rule will not be a determinant in
such situations, since its effect is only to rule out sewers that meet the
other tests.
The question of whether non-sewer solutions can satisfy documented needs
is, of course, open to policy regarding what is, and what is not, a "need."
The broadest definition of "need" could be based on the whole range of goals
that communities might be pursuing. Technical Reference Document IX.A. dis-
cusses five major community goals:
protecting public health
improving surface water or groundwater quality
abating and preventing nuisances
improving property values
providing infrastructure for development.
In addition, obtaining specific benefits associated with a government-funded
program might also be listed. Examples are recreational benefits of property
acquisition and improved water quality, and jobs created by the expenditure.
Federal support for any and all of these goals and benefits can be found
in ongoing or relatively recent grant and loan programs. (See Technical
Reference Document XVI. B., Federal Water Quality Improvement Programs in
Rural Lake Areas.) Indeed, most of the small communities receiving Construc-
tion Grants funds since the beginning of the program have built collector
sewers with part of their grants. And they have realized the benefits listed
above to one degree or another.
But the issue is not whether sewers are good or bad. The issue is:
Which benefits are considered, within the law authorizing and regulations
implementing the Construction Grants program, to be primary goals of the
program and, therefore, determinants of need?
The best current guide for addressing this issue is the Clean Water Act
of 1977, as amended by the Municipal Construction Grants Act of 1981. Section
101 (a) of the Act reads: "The objective of this Act is to restore and main-
tain the chemical, physical, and biological integrity of the Nation's waters."
XVI-A-1
-------
CHAPTER XVI
FEDERAL PROGRAMS
-------
7. CONSEQUENCES OF ESTABLISHING SEPARATE SMALL WASTE FLOWS
PRIORITY LISTS
Utilization of separate small waste flows priority lists will potentially
result in the following:
• Rural areas that need small waste flows management systems will be able
to receive EPA Construction Grants Program funding (if available)
according to a priority ranking system based on criteria that consider
the true needs of rural communities and the possible accomplishments of
small waste flows facilities.
• Monies allocated by states for funding of small waste flows programs
will be spent efficiently, cost-effectively, and for projects that will
do the most good for rural areas of the states within EPA Region V.
• Small waste flows management systems typically do not cause abnormal
secondary growth. As a result, utilization of separate priority lists
and the subsequent funding of small waste flows facilities will enable
small rural communities to retain small-town characteristics.
• Groundwater pollution and public health problems will be recognized and
subsequently reduced or eliminated through use of separate priority
lists that identify these problem areas by virtue of the new criteria
to be utilized.
• Applicants will be encouraged to base their proposed projects on the
true nature of their wastewater-related problems, not undocumented
problems that result in the highest priority.
XV-D-11
-------
state-specific public health problems and other small community concerns.
Use of separate small waste flows priority lists would enable the various
states within Region V to utilize grant funds specifically set aside for
alternative small waste flows systems in a cost-effective, environmentally
sound manner that is also responsive to small community needs and is
consistent with EPA regulations.
6. EXAMPLE CRITERIA FOR SEPARATE SMALL WASTE FLOWS PRIORITY
LISTS
A review of Tables XV-D-1 through XV-D-6 will show that several rating
criteria currently used within Region V are favorable to the concept of small
waste flows programs. These criteria, and several additional ones, are
suggested herein for consideration by the various states, particularly those
with a rural population of 25% or more. The criteria are offered as
suggestions only, and should not be construed or interpreted as requirements
of EPA Region V. Development and consideration of other criteria that address
state-specific needs, problems, and interests, are encouraged. The suggested
criteria (in random order) for which priority points might be given include:
• Correction of failing on-site systems that are causing or contribution
to public health problems.
• Reduction or elimination of systems adversely affecting groundwater
uses.
• Reduction in the number of stream segments polluted by failing systems.
• Projects in designated national priority basins.
• Per capita cost of the project. Projects with the lowest cost per
capita should receive priority, since this will result in serving the
most persons possible per dollar of grant funds expended. If a project
is so expensive that it causes a financial burden for citizens, then
additional funding potentially should be made available from other
federal agencies (e.g., HUD or FHA), and not from EPA.
• Low per capita income.
• Bonded indebtedness of the grantee per dollars of assessed value.
Cities with lowest debts should receive priority. If a community is
heavily in debt, it potentially cannot pay for proper system 0 & M
(which is not federally subsidized).
• Communities with a large percentage of residents served by on-site
systems.
• Elimination of ponding or surface runoff from failing on-site systems.
• Number of persons to be served by proposed small waste flows systems
that currently have on-site systems.
In addition, state-specific criteria addressing the needs and desires of
the public should be included in the priority ranking system.
XV-D-10
-------
A review of Tables XV-D-1 through 6 reveals that an overwhelming number
of criteria currently used by various states to develop funding priority lists
place small waste flows management systems at a distinct disadvantage when
competing with centralized treatment systems. This does not mean that the
existing criteria being utilized are wrong or bad; in fact, existing criteria
appear to follow closely the four general criteria established by 40 CFR
35.915(a)(1). Nonetheless, small waste flows management systems do not sur-
vive well when subjected to current state criteria established in response to
the Clean Water Act. Perhaps more recent legislation will enable changes to
be made, as discussed in the next section.
4. REGULATIONS ASSOCIATED WITH THE MUNICIPAL WASTEWATER
TREATMENT CONSTRUCTION GRANTS AMENDMENTS OF 1981
Regulations have been promulgated by EPA in response to the Municipal
Wastewater Treatment Construction Grants Amendments of 1981 (Public Law
97-117). These regulations comprise a new subpart I to 40 CFR 35. They were
published in the Federal Register on May 12, 1982. Among other changes from
the earlier regulations, the use of existing population as a criterion is
optional under the new regulations. The mandatory criteria emphasize restora-
tion of groundwater as well as surface water uses. And, significantly for
unsewered communities, public health improvements are included in the
mandatory criteria.
How the revised criteria actually impact the distribution of funds to
small communities will depend on how the states modify specific provisions of
their priority lists. As is evident from their earlier priority criteria
analyzed here, the states vary in their concern for small community wastewater
problems. As suggested above, the form of the states' priority criteria is
likely to influence how communities present their projects to be rated.
The proposed regulations still require that 4% of a state's allotment be
reserved for funding alternative systems for small communities. Therefore,
monies are provided for construction of eligible small waste flows projects.
5. Concept of Separate Small Waste Flows Priority Lists
One way to promote fair consideration of small waste flows management
systems within EPA Region V, and still maintain the integrity of current
priority methodologies, is to develop separate priority criteria and a
separate priority ranking list for utilization with small community projects.
It has been shown that the rating criteria currently used by states within EPA
Region V do fulfill the intent of EPA's general criteria as developed in
response to the Clean Water Act. Continued use of the same rating criteria
also should fulfill the intent of the first criteria of the new 1981 amend-
ments (i.e., correction of municipal wastewater discharges which impair water
uses), and should provide continued successful construction or rehabilitation
of centralized municipal treatment systems, which serve a majority of the
nation's population.
In a like manner, separate small waste flows priority lists could be
developed, using new rating criteria that are directed toward helping small
and rural communities comply with the second criteria of the new 1981 amend-
ments (i.e., restoring groundwater uses and improving public health). New
rating procedures or formulas also could contain criteria developed to address
XV-D-9
-------
TABLE XV-D-6. EVALUATION OF PRIORITY RANKING CRITERIA USED FOR EPA'S
CONSTRUCTION GRANTS PROGRAM IN WISCONSIN
Ranking Criteria Developed by: WISCONSIN DEPARTMENT OF NATURAL RESOURCES
Effect on SWF Systems
DESCRIPTION OF CRITERIA Pro Neutral Con
• Basin priority X
• Eliminating groundwater pollution X
• Eliminating discharges of raw sewage X
• Eliminating ponding or runoff of effluent from X
septic tank systems
• Eliminating bypasses in sewage treatment plants X
• Eliminating backups of sewage into basements X
• Assimilative capacity of receiving stream X
• Elimination of discharges of phosphorus X
• Population affected (priority to large citiess) X
• Project category (priority for new plants, new X
sewers, and eliminating on-site systems)
COMMENTS:
(1) Procedures state that "It is the position of the DNR that correction of
malfunctioning septic systems is not...central to achievement of...
water quality goals....Unsewered community projects are not needed to
meet enforceable requirements of the Clean Water Act....Elimination of
...points for unsewered communities will put those projects on the
bottom of the priority list...."
XV-D-8
-------
TABLE XV-D-5. EVALUATION OF PRIORITY RANKING CRITERIA USED FOR EPA'S
CONSTRUCTION GRANTS PROGRAM IN OHIO
Ranking Criteria Developed by: OHIO ENVIRONMENTAL PROTECTION AGENCY
Effect on SWF Systems
DESCRIPTION OF CRITERIA Pro Neutral Con
Severity of pollution (priority if effluent X
is more than stream flow)
Priority for many industrial dischargers in a X
basin
Priority for discharge to cold water fisheries, X
wild and scenic rivers, or recreational waters
Designated federal priority basins X
Population affected (weighted to large cities) X
Protection of existing water uses (priority for X
discharges to surface drinking water supplies
and recreational waters)
Public health hazards (priority for groundwater X
contamination, public health problems, and
fish kills)
Project type (priority for existing centralized X
systems)
COMMENTS:
(1) Procedures allow unsewered areas with population problems to receive
funding, but projects are ranked using the above priority criteria and
placed on one priority list.
XV-D-7
-------
TABLE XV-D-4. EVALUATION OF PRIORITY RANKING CRITERIA USED FOR EPA'S
CONSTRUCTION GRANTS PROGRAM IN MINNESOTA
Ranking Criteria Developed by: MINNESOTA POLLUTION CONTROL AGENCY
Effect on SWF Systems
DESCRIPTION OF CRITERIA Pro Neutral Con
• Population affected (weighted to large cities) X
• Segment ranking X
• Category of project (SWF projects are not listed) X
• Per capita cost of project (high cost gets priority) X
• Bond debt (City more in debt gets priority) X
• Per-capita income (low income gets priority) X
COMMENTS:
(1) Unsewered communities may get on the priority list only by demonstrating
the need for a project. This is done by submitting data on: (a) soil
type; (b) lot size; (c) depth to high groundwater; and (d) age of
existing system. These criteria demonstrate the need for centralized
projects; SWF systems apparently are not considered.
(2) Grant funds are allocated for metropolitan and non-metropolitan projects
according to the ratio of sewered metropolitan population to sewered non-
metropolitan population. Unsewered populations apparently are not
considered.
(3) Small waste flow funding (4%) is set aside.
XV-D-6
-------
TABLE XV-D-3. EVALUATION OF PRIORITY RANKING CRITERIA USED FOR EPA'S
CONSTRUCTION GRANTS PROGRAM IN MICHIGAN
Ranking Criteria Developed by: MICHIGAN DEPARTMENT OF NATURAL RESOURCES
Effect on SW Systems
DESCRIPTION OF CRITERIA Pro Neutral Con
Population to be served (weighted to big cities) X
Designated water use (on-site systems are X
considered as discharging to groundwater,
and get extra points)
Drought flow ration (groundwater considered X
infinite)
High quality effluent X
Discharge directly to Great Lakes X
Amount discharged to groundwater X
Elimination of point source discharge to X
an inland lake
Stream segment ranking X
Extra weight given to projects which eliminate X
a public health problem
COMMENTS:
(1) Michigan procedures call for spending all of the state's available SWF
funding on SWF projects in the order in which the projects fall on the
priority list. In addition, SWF projects also are funded with regular
grant funds.
XV-D-5
-------
TABLE XV-D-2. EVALUATION OF PRIORITY RANKING CRITERIA USED FOR EPA'S
CONSTRUCTION GRANTS PROGRAM IN INDIANA
Ranking Criteria Developed by: INDIANA STREAM POLLUTION CONTROL BOARD
DESCRIPTION OF CRITERIA
Dilution by streamflow per 1,000 persons
Ranking of stream segment
Population per square mile of basin
Assimilative capacity of receiving stream
Basin designated by EPA or plant expansion of
existing system
Major need for new conventional system or plant
expansion of existing system
New regional plants or proposed conventional plants
in Steps 1, 2, or 3
Effect on SWF Systems
Pro Neutral Con
X
X
X
X
X
X
COMMENTS:
(1) Municipalities without existing plants can be added to the priority
list.
(2) Municipalities that do not have point source discharges and that have
enforceable pollution problems (e.g., failing on-site system) can be
removed from the priority list.
(3) The narrative accompanying the description of the rating system states
that "compliance with I/A technology rules is difficult." Procedures
for spending funds for small community systems are not established;
however, it is noted that 4% of the state's allotment is set aside
for small community systems.
(4) Procedures allow municipalities with on-site systems to get on the
priority list by "documenting substantial pollution problems from raw
sewage discharge or inadequate septic systems." No mention is made of
public health problems.
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TABLE XV-D-1. EVALUATION OF PRIORITY RANKING CRITERIA USED FOR EPA'S
CONSTRUCTION GRANTS PROGRAM IN ILLINOIS
Ranking Criteria Developed by: ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Effect on SWF Systems
DESCRIPTION OF CRITERIA Pro Neutral Con
Discharge of large amounts of BOD to stream X
Adequacy of existing facilities in meeting X
permit limitations
Ranking of stream segments according to X
effluents to discharged
Types of additional facilities required X
Types of existing facilities which are overloaded X
Discharge does not comply with 30/30 (BOD/TSS) X
Number of 600-feet downstream segments X
polluted by the municipality's activities
Number of 600-feet downstream segments X
polluted by drainage tile fields
Number of 600-feet downstream segments that X
have unbalanced aquatic environments due to
the municipality's activities
Severity of public health hazards resulting X
from inadequate or malfunctioning private
sewage disposal systems
Multiplying factor biased to favor large X
municipalities
COMMENTS:
(1) Points given for inadequate existing centralized facilities appear to
greatly overshadow points available for on-site systems.
(2) The narrative associated with the ranking criteria states that the trend
in Illinois is to support and encourage innovative/alternative technology
in 1982.
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Water Act, EPA promulgated changes in its regulations involving establishments
of priority rating systems and funding reserves relating to the Construction
Grants Program. Of relevance to this discussion are the provisions of 40 CFR
35.915(a)(1), which established criteria to be used in state priority systems.
These regulations required states to establish project rating systems for
determining priorities for grant funding based on the following criteria:
• severity of the pollution problem;
• existing population;
• need for preservation of water quality; and
• specific categories of need, to be addressed on a state basis.
The first of the above-stated criteria is not particularly well suited
for application to rural communities with proposed small waste flows projects,
because failing on-site systems often result in significant public health
problems without causing significant pollution problems. The second criteria
increases priority according to the number of persons affected by (i.e.,
benefiting from) a proposed project—a situation which obviously places rural
communities at a disadvantage when they compete for funding with large
metropolitan areas. The third criteria also is not advantageous to small
waste flows systems, since water quality degradation does not always occur
with failing on-site systems. Advantages or disadvantages of the fourth
criteria are dependent upon the specific category selected by the state, if
any. It is noteworthy that neither the Clean Water Act nor the regulations
suggest a specific category for non-sewered technologies, despite the fact
that the Act made individual systems eligible for Construction Grants funding.
Additional provisions are given in 40 CFR 35.915(a)(1)(iv), which speci-
fies that other additional criteria consistent with those listed above may be
considered, including the special needs of small and rural communities.
Furthermore, 40 CFR 35.915-1(a), dealing with required reserves related to
priority lists and federal funding allotments to the various states, specifies
that "each state with a rural population of 25% or more shall set aside 4% of
the prescribed state allotment to fund alternative systems for small communi-
ties." These additional provisions, which allow states to establish ranking
criteria specifically geared to small communities, and which require monies to
be set aside for funding alternative small waste flows management programs,
provided the means for states to recognize and satisfy the need for improved
small waste flows systems in unsewered communities. The following section
presents the results of an analysis conducted to determine how proposed small
waste flows management programs are affected by the state priority ranking
systems within EPA Region V.
3. EVALUATION OF STATE PRIORITY SYSTEMS
Tables XV-D-1 through XV-D-6 summarize the results of evaluations of the
priority ranking systems used by Illinois, Indiana, Michigan, Minnesota, Ohio,
and Wisconsin, respectively. Each table lists the major rating criteria used,
and designates whether the criteria are advantageous to small waste flows
systems (pro); do not affect small waste flows systems (neutral); or place
small waste flows systems at a substantial disadvantage (con) when compared
with large municipal projects.
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D. BENEFITS OF SEPARATE STATE PRIORITY LISTS FOR SMALL WASTE
FLOW AREAS
Wastewater management problems in unsewered communities are seldom
similar to those of sewered communities. This chapter explores the proposi-
tion that criteria used to rank sewered communities for grant funding are not,
therefore, appropriate for the ranking of unsewered communities. It is
suggested here that states consider adoption of separate priority lists to be
used for communities where public health and groundwater protection goals are
as significant as surface water quality goals.
1. GOALS
Of the municipal wastewater management problems faced by local, state,
and federal governments at the beginning of the Construction Grants program,
inadequately treated discharges of wastewater to surface waters, primarily by
large, centralized systems, were the most obvious and the most amenable to
solution by known technologies. It is thus not surprising that Section 216 of
the Federal Water Pollution Control Act of 1972 (Public Law 92-500) lists only
elements of centralized wastewater systems as mandatory categories for state
priority lists. Billions of dollars have now been spent on thousands of
centralized treatment systems to address the worst of these surface water
pollution problems.
But there remain on state priority lists many projects for which surface
water quality goals are not as urgent as are public health and groundwater
protection goals related to operation of on-site systems. Increasingly,
communities with limited or no collection facilities are rising on the
priority lists.
The priority lists, however, were established to rank centralized
projects, the dominant goals of which are surface water pollution abatement.
As a result, upcoming projects for unsewered communities, many of which have
real public health or groundwater problems, have to compete with wholly
dissimilar projects. The response of many applicants appears to be to tailor
their proposed projects to get as many points in the priority rating as
possible. The resulting project may be as inappropriate for the community as
were the priority criteria. Such projects are typically the most expensive
means of abating the actual public health and groundwater problems at hand,
requiring installation of new collection and treatment systems with new
discharges to surface waters. Misapplication of priority criteria can
actually be counter-productive, in addition to being expensive.
Several reasons for having separate state small waste flows priority
lists are presented herein. The following paragraphs discuss the basis of
current grant funding priority lists, evaluate ranking criteria used by states
within EPA Region V, discuss the need for separate funding lists, and mention
some of the anticipated consequences of establishing separate priority lists
for funding small waste flows management programs.
2. REGULATIONS ASSOCIATED WITH THE CLEAN WATER ACT OF 1977
The Clean Water Act of 1977 (Public Law 95-217) provided for several
modifications to EPA's Construction Grants Program. As a result of the Clean
XV-D-1
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Wisconsin
John Cain
Department of Natural Resources
P. 0. Box 450
Madison, WI 53701
Lyman Wible
S.E. Wisconsin Regional
Planning Commission
916 South East Avenue
Waukesha, WI 53186
William Lane
Dane County Regional
Planning Commission
City-County Building, Room 312
Madison, WI 53709
John Laumer
Fox Valley Water Quality
Planning Agency
1919 American Court
Neenah, WI 54956
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Minnesota
Paul Davis, Chief Planner
Pollution Control Agency
1935 West County Road B2
Roseville, MN 55113
John Harrington, Environmental Planner
Metropolitan Council
300 Metro Square Building
7th and Robert Streets
St. Paul, MN 55101
Ohio
Edward Armstrong, Office of
Planning Coordinator
Environmental Protection Agency
361 East Broad Street
P. 0. Box 1049
Columbus, OH
Jim King, Environmental Engineer
Northeast Ohio Four County
Coordinating Organization
137 South Main Street
Delaware Building, Suite 300
Akron, OH 44308
John Becker, 208 Director
Northeast Ohio Areawide
Coordinating Agency
1501 Euclid Avenue
Cleveland, OH
Dorey Montezumi, 208 Director
Ohio-Kentucky-Indiana Regional
Council of Governments
426 East Fourth Street
Cincinnati, OH
Dick Roberson, 208 Planner
Miami Valley Regional Planning
Commission
333 West First Street, Suite 500
Dayton, OH 45402
John Getchey, 208 Director
Eastgate Development and
Transportation Agency
1616 Covington Street
Youngstown, OH 45402
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Angela Preston, Water Quality Coordinator
Indiana Heartland Coordinating Commission
7212 North Shadeland, Suite 120
Indianapolis, IN 46250
Larry Koepfle, Water Quality Planner
Michigan Area Council of Governments
County-City Building, llth Floor
South Bend, IN 46601
Rosemary Harvey, Environmental Planner
Region VI Planning and Development
Commission
207 North Talley
Muncie, IN 47303
Michigan
Ron Wilson
Department of Natural Resources
Stevens T. Mason Building, 8th Floor
Box 30028
Lansing, MI 48909
Chuck Grant, 208 Coordinator
Northwest Michigan Regional Planning
and Development Commission
2334 Aero Par Court
Traverse City, MI 49684
Marty Skoglund, 208 Coordinator
Central Upper Peninsula Planning
and Development District
2415 14th Avenue South
Escanaba, MI 29829
Ron Karwowski, 208 Director
Genesee, Lapeer and Shiawassee
Region V Planning and Development
Commission
100 Phoenix Building
Flint, MI 48502
James Sygo, 208 Director
East Central Michigan Regional Planning
Commission
500 Federal Avenue
Castle Building, Second Floor
Saginaw, MI 48607
John Koches
West Michigan Shoreline Regional
Development Commission
315 West Webster Avenue
Muskegon, MI 49440
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AGENCIES AND PERSONNEL CONTACTED
U.S. EPA
Mark Alderson
Mike Philips
U.S. EPA Region V
230 South Dearborn St.
Chicago, IL 60604
Illinois
William Sullivan
Terri Zeal
Illinois Environmental Protection Agency
220 Churchill Road
Springfield, IL 62706
Angela Kazakevicius
Greater Egypt Regional Planning and
Development Commission
P. 0. Box 3160
608 East College Street
Carbondale, IL 62901
Jacqueline Bruemmer, 208 Program Manager
Southwestern Illinois Metropolitan and
Regional Planning Commission
203 West Main Street
Collinsville, IL 62234
Thomas Trybus
Northeastern Illinois Planning and
Development Commission
400 West Madison Street
Chicago, IL 60606
Indiana
Steve Kim
Ron Weiss
Stream Pollution Control Board
Board of Health
1330 West Michigan Street
Indianapolis, IN 46206
Mose McNeese, 208 Planner
Northwestern Indiana Regional
Planning Commission
8149 Kennedy Avenue
Highland, IN 46322
XV-C-11
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REFERENCES
Environmental Protection Agency 1978. Grants for construction of treatment
works - Clean Water Act (40 CFR 35 Part E): Rules and regulations. 43FE
44022, 27 September 1978.
Greater Egypt Regional Planning and Development Commission. 1980. Areawide
waste treatment and water quality management planning - facilities
planning for small communities. Publication No. 1 GERPDC-80-552.
Carbondale IL.
Illinois Environmental Protection Agency. 1979. Illinois water quality
management plan, volume 4. Springfield IL.
Indiana Heartland Coordinating Commission. Variously dated. Hendricks County
sewage treatment management study. Indianapolis IN.
Northeastern Illinois Planning and Development Commission. 1979. Areawide
water quality management plan, volume 1. Chicago IL.
Southwestern Illinois Metropolitan and Regional Planning Commission. 1979.
Feasibility study of alternative wastewater treatment systems.
Collinsville IL.
XV-C-10
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could also become involved in providing technical assistance to local com-
munities in the use of small waste flows technologies and management. Where
the 208 agency did not possess the necessary expertise in-house to provide the
assistance, it could function as a clearinghouse and obtain assistance from
other agencies.
e. Preparing Manpower Inventories for Local Small Waste Flows
Programs
A wide range of types of expertise may be required by a local community
in operation of a small waste flows program. Many communities may find that
they have deficiencies in certain expertise levels among existing personnel.
A 208 agency could assist these communities on a regional basis, by preparing
inventories of the types of expertise available to the community from private
organizations and other public agencies. A 208 agency, with its familiarity
with public and private agencies, could provide new sources of assistance to
local communities. A feasible method of solving the manpower needs of many
small communities with limited resources would be the identification of expert
personnel who could be shared by more than one community.
f. Assisting Local Communities in Grant Application and
Administration
The application for, and administration of, Construction Grants funds to
be utilized for decentralized systems may involve more expertise, time, and
effort than rural communities have at their disposal. Additional requirements
for individual systems as provided in Section 35.918-1 of the Construction
Grants Regulations (EPA, 1978) provide an example of the greater regulations
governing grants for individual systems. Many 208 agencies have provided
grants assistance to local communities under the Construction Grants program
and other Federal programs. With staff expertise in the construction grants
program and requirements, the 208 agencies would be ideally suited to provide
assistance to local communities. The 208 agencies also could provide ongoing
assistance in the administration of the grants. Such activities as providing
assistance to communities in contracting for services, hiring of personnel,
budget preparation, and others could all be feasibly performed under a 208
agency assistance program.
XV-C-9
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• serve as a repository for performance data on the utilization of
alternative wastewater technology.
All of these measures comprise preliminary planning efforts that would be
valuable to local communities in identifying the feasibility of utilizing
small waste flows technology and management. The activities would require a
greater involvement by the 208 agencies in recognition and identification of
the needs of rural areas and planning for these areas. However, 208 agencies
should benefit from familiarity with the local communities and availability of
necessary planning tools, and possess necessary expertise to perform such
studies.
c. Reviewing and Making Recommendations for Upgrading of Local
and State Regulations
Many local and state regulations inhibit the utilization of small waste
flows technology and the management of decentralized systems. In many states
this is done prudently because the feasibility of the utilization of small
waste flows technology has not been proven in a given area and the mechanisms
for the proper management of these systems have not been developed. However,
as the use of decentralized systems proves feasible, cost-effective, and in
harmony with environmental objectives, the need for amendments to existing
local and state regulations becomes apparent. Similarly, as the utilization
of small waste flows technologies becomes a reality, the development of
appropriate management capabilities will in many cases require revision of
local and/or state regulations.
The 208 agencies should be familiar with existing regulatory controls
within a community as well as with regulatory techniques used in other com-
munities. The 208 agencies can review local codes and recommend amendments to
communities that lack sufficient expertise to initiate such changes on their
own. A 208 agency with available staff and expertise would also be more able
to lobby state agencies for necesary amendments than would a rural community.
d. Disseminating Information on Small Waste Flows Technology
and Management
The dissemination of information on small waste flows technology and
management is an activity that most existing 208 agencies perform in some
manner. The level and types of information disseminated vary widely, however.
There are three main methods of information dissemination: educational pro-
grams, training programs, and provision of technical assistance. A 208 agency
would be an ideal agency for providing these services because it posseses the
necessary expertise and can provide assistance over a wide area.
Educational programs consist of a variety of activities that may be
utilized to educate the general public in small waste flows technology and
management. Examples might include holding public meetings, and workshops;
preparation of brochures and pamphlets describing small waste flows manage-
ment; and similar activities. Most 208 agencies will have already attained
expertise in these activities through other 208 programs. Training programs
that may be coordinated through a 208 agency include programs for regulatory
personnel, system installers, designers, and evaluators. The 208 agency
personnel could develop the programs and bring in necessary expertise for
these programs to supplement agency personnel as needed. The 208 agencies
XV-C-8
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• a mailed questionnaire regarding each resident's knowledge of the
on-site system and its performance,
• review of soils maps,
• review of local permit records,
• lot elevations to estimate depth to water table (lakeshore areas),
• calculation of lot sizes,
• remote photo imagery, and
• leachate detection of ground or surface water in the area.
Following such a needs determination, the condition of existing on-site
systems within the community may be categorized into one of three groups:
1. those with obvious problems,
2. those with no problems, and
3. those requiring more investigation for evaluation.
This type of initial screening indicates to a community the severity of its
wastewater needs. It also indicates the level of effort required for comple-
tion of the needs analysis based on the number and type of properties
requiring more investigation for evaluation.
Performance of this type of needs analysis could feasibly be conducted by
existing 208 agencies. The 208 agencies represent the only personnel with
expertise in wastewater planning in many rural areas, and this expertise
should be fully utilized. In addition, 208 agencies may have already con-
ducted studies providing some of the data needs and may have available or have
ready access to and familiarity with soils maps, topographic maps, lot line
maps, and other data. These agencies would also have staff available who are
capable of assimilating and interpreting the necessary data.
b. Identifying Local Feasibility of Small Waste Flows Technology
and Management
The identification of the local feasibility of small waste flows tech-
nology and management includes a wide range of activities that could be per-
formed by 208 agencies. Many existing 208 agencies are already performing a
number of these activities. The list of potential activities includes:
• prepare soil and other studies indicating the feasibility of on-site
disposal techniques throughout the community,
• identify local measures for septage treatment,
• conduct institutional analyses of local communities for the management
of decentralized systems,
• Prepare site-specific cost benefit analysis for the use of decen-
tralized systems vs. centralized collection and disposal, and
XV-C-7
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3. POTENTIAL 208 PROGRAM ACTIVITIES
The 208 agencies represent the only body concerned with wastewater plan-
ning in many rural areas. As such, they can have a tremendous impact on the
utilization of small waste flows technology and management to serve the waste-
water needs of rural areas by providing assistance to local communities. Many
208 programs have already been active in promoting the use of small waste
flows technology and management. Ongoing activities include conducting Muni-
cipal Needs Analysis for rural communities, studying the use of alternative
technology, managing decentralized facilities, etc. The purpose of this sec-
tion will be to identify the expanded role that 208 agencies can fulfill in
providing assistance to local communities. While it is recognized that
funding limitations may affect any expansion of 208 programs, the purpose here
is to assess the potential for 208 involvement in small waste flows programs.
The range of potential 208 activities that will be discussed includes:
• preparing of community needs analysis,
• identifying local feasibility of small waste flows technology and
management,
• reviewing and making recommendations for upgrading of local and state
regulations,
• disseminating information on small waste flows technology and manage-
ment,
• preparing manpower inventories for local small waste flows programs,
and
• assisting local communities in grant application and administration.
a. Preparing of a Community Needs Analysis
The State of Illinois provides an excellent example of what existing 208
agencies have accomplished in identifying community needs. As previously
discussed under current programs, the state and designated 208 agencies pre-
pared Municipal Needs Analyses (MNA) for those communities that had not
applied for construction grants and had not, therefore prepared a facility
plan. These MNAs are essentially the same as facilities plans although their
recommendations are not necessarily readily implementable as are the recom-
mendations of facilities plans. Through these MNAs, the state and designated
208 agencies have appraised the wastewater needs of rural communities and
identified approaches to meeting these needs.
Needs analysis assistance to local communities does not have to be as
extensive as has been done in Illinois to be of value. Needs documentation
based on easily obtainable data, such as Phase I studies described in Region V
Guidance on Site Specific Needs Determination and Alternative Planning for
Unsewered Areas may be performed. The needs documentation is based on data
such as:
XV-C-6
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discussed setting up a program to manage on-site systems and another subplan
that dealt with the environmental problems associated with leachate from
on-site systems. According to agency personnel, both of these subplans were
general and have been improved upon by more recent and expansive literature.
The Ohio-Kentucky-Indiana Regional Council of Governments prepared a separate
report on alternative methods of on-site disposal. The Eastgate Development
and Transportation Agency is currently preparing a study dealing with on-site
systems. The study entitled Operation and Maintenance Standards for On-Site
Systems is looking at current regulatory practices regarding system operation
and maintenance and making recommendations for changes.
g. Wisconsin
The Wisconsin Department of Natural Resources (DNR) prepared a statewide
208 plan that did not go into extensive discussion of alternative wastewater
technology. The plan did make recommendations that alternative technology
should be considered as part of the facilities planning process. The DNR has
been funded for fiscal year 1981 to prepare a study entitled Implication of
Small and Alternative Technology. This study will look at the ramifications
of applying small waste flows and alternative technology to rural communities.
They hope from this study to encourage extensive use of new alternative tech-
nology when community conditions warrant its use.
The Southeast Wisconsin Regional Planning Commission members have been
very active in exploring the issue of alternative technology to serve rural
areas. Their 208 plan discussed the feasibility of the use of alternative
technology and particularly the Wisconsin mound system. They also developed,
in 1976, a technical report entitled State of the Art of Wastewater Manage-
ment . Their 208 plan developed sewer service areas surrounding existing urban
centers and looked at alternatives for sewering these areas where conventional
sewerage did not appear feasible. They intend to conduct a detailed study to
look at alternative methods to service these areas.
The Dane County Regional Planning Commission's 208 plan primarily con-
centrated on the control of non-point source pollution problems. Outside of
readily sewerable areas, the Commission did discuss the need to address a
variety of alternatives in considering the sewer service. However, the agency
is not encouraging the use of alternative technology because it is attempting
to channel future development into areas already served by conventional
sewerage. The agency intends to undertake a study this year (1981) of systems
for requiring homeowner operation and maintenance of all existing on-site
systems, monitored by the issuance of yearly operating permits.
The remaining designated 208 agency, the Fox Valley Water Quality Plan-
ning Agency, did not extensively cover the use of alternative technology
within its 208 plan. The planning area contains very poor soils, high water
tables, and floodplains that preclude the use of on-site systems in many
areas. Much of the district is so environmentally sensitive that any type of
sewerage and development is disadvantageous. The agency plans to review the
sewer service areas to identify the environmentally sensitive areas as being
unsuitable for any type of development.
XV-C-5
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The plans have at least provided a starting point from which further use of
alternative technology may be considered. The statewide 208 plan that has
been recently funded will primarily focus on point source pollution problems.
Several of the 208 agencies have conducted or are becoming involved in
special studies and activities related to small waste flows management. The
West Michigan Shoreline Regional Development Commission prepared a report in
1977 entitled Sewerless Methods of Household Waste Disposal. This report
looked at the state-of-the-art in on-site and alternative wastewater disposal
as it existed in 1977. This 208 agency has been actively promoting the use of
alternative technology, but local counties are reluctant to change from the
status quo of conventional technology. The Genesee, Lapeer, and Shiawasse
Planning Development Commission prepared a report in 1978 entitled The Impact
of Unsewered Development on Water Quality. This agency worked with one county
in attempting to establish a small waste flows management district but ran
into numerous bureaucratic problems. These problems were attributed to a lack
of designation and approval on the state level of the appropriate administra-
tive mechanisms. The Northwest Michigan Regional Planning and Development
Commission has recently been funded by the Northwest Michigan Human Services
Agency to investigate starting an inspection and pump-out program for septic
tanks in a small community. They will be exploring and developing management
strategy and options.
e. Minnesota
Minnesota has only one designated 208 agency serving the Minneapolis-St.
Paul area. The Metropolitan Council, which is the designated 208 agency serv-
ing this area, has been very active indirectly in looking at alternative
wastewater technology to service their area. The Metropolitan Waste Control
Commission (MWCC), which received funds from the Metropolitan Council and the
201 program, completed an alternative wastewater management study that identi-
fied wastewater problem areas in the region and recommended generic solutions
to these problems. The MWCC is currently being funded for Phase II of this
project, which involves performing site-specific needs analysis of each
dwelling unit. The MWCC has adopted a policy of not extending sewers beyond
the present urban areas, and this will increase the likely use of alternative
technology to serve these areas. Two townships and counties have already
prepared facilities plans considering the use of alternative technologies.
The Minnesota Pollution Control Agency has prepared a 208 plan for the
non-designated areas of the state. The plan did not specifically address the
needs of rural planning areas or discuss the use of small waste flows tech-
nology to serve rural areas. The plan focused on the control of non-point
source pollution problems within the state.
f. Ohio
The statewide 208 plan prepared by the Ohio EPA and the 208 plans pre-
pared by the designated 208 agencies contacted did not consider extensively
the use of small waste flows technology beyond recognition of the need for its
consideration during the facilities planning stage. Generally, the 208 plans
emphasized urban and non-point source pollution problems. The Northeast Ohio
Areawide Coordinating Agency did include a subplan within their 208 plan that
XV-C-4
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All three of the designated 208 agencies have begun to consider the needs
of rural areas and the utilization of small waste flows technologies to serve
these areas in their respective 208 planning. The Southwestern Illinois
Metropolitan Regional Planning Commission has reassessed area 201 plans where
conventional sewering was not conisdered cost-effective for the feasibile use
of small waste flows technology. They have also prepared a feasibility study
on the utilization of alternative wastewater technology for their entire
region (Southwestern Illinois Metropolitan and Regional Planning Commission,
1979). Greater Egypt Regional Planning and Development Commission has been
very progressive in looking at the wastewater needs of rural areas. A report
entitled Facilities Planning for Small Communities (Greater Egypt Regional
Planning and Development Commission, 1980) has been prepared, which describes
ten unsewered communities and the types of factors to be considered in making
facilities planning decisions. The Northeastern Illinois Planning and Devel-
opment Commission assessed the use of land application of treated wastewater
as part of its Areawide Water Quality Management Plan (Northeastern Illinois
Planning and Development Commission, 1979). As a result of poor soils, the
high cost of available land, variability and nature of the region's climate,
and adverse public opinion, land application of wastewater was considered in
the plan as ill-suited to most areas of northeastern Illinois.
c. Indiana
The statewide 208 plan developed by the Indiana State Board of Health,
Division of Water Pollution Control, considered the use of alternative techno-
logy and the special needs of rural areas only in a general manner by men-
tioning that alternative technologies must be considered during the facilities
planning stage. Because of poor soil conditions and high water tables
throughout much of the state, the agency is currently skeptical of the use of
alternative on-site systems versus centralized collection and treatment
systems. Also cited as a problem with the use of alternative systems is the
present lack of effective community management mechanisms.
The 208 plans prepared by the four designated 208 agencies only generally
addressed the use of small waste flows technology to serve rural communities.
The Indiana Heartland Coordinating Commission is currently the most active in
looking at alternative wastewater technology. The Commission has prepared the
Hendricks County Sewage Treatment Management Study, which looked at the insti-
tutional options in this county for managing small package treatment plants
(Indiana Heartland Coordinating Commission, variously dated). The Commission
is also working with Hancock County on a similar study for the management of
mound systems.
d. Michigan
The entire state of Michigan is divided into designated 208 planning
regions. All fourteen of the designated 208 agencies considered and dis-
cussed, in some manner, the issue of the use of alternative technology to
service rural areas in development of their 208 plans. About one-half of the
208 plans contained extensive discussion of the use of alternative technology
and made recommendations for its usage. None of the 208 plans specifically
addressed the issue of setting up management agencies beyond the designation
of the county as the management agency. There has been minimal follow through
to date with the use of alternative technology recommended in the 208 plans.
XV-C-3
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be incapable or unwilling to manage small waste flows facilities. In this
event, a new management agency would have to be designated. None of the
agencies felt that there would be any difficulties encountered in changing the
designated management agency as long as the 208 plan was updated. However,
they did state that compliance with the 208 plan recommendations and local
support of the change in management agency designation were of major impor-
tance.
Almost all of the 208 agencies in the region professed that they had
staff available who were knowledgeable in small waste flows technology and
management. The level of knowledge varied widely from agency to agency,
depending upon the particular agencies' needs and programs relative to small
waste flows management. On the whole, agencies considered that their greatest
staff expertise remained in the use of conventional wastewater technology,
with expertise in the control of non-point source pollutants being secondary.
Potential funding support for small waste flows programs was not seen as
feasible by any of the agencies under the current 208 program funding levels.
Many agencies felt that they have not been able to maintain existing programs
because of funding limitations and cutbacks, and some agencies indicated that
they would become more involved in small waste flows management if additional
funding became available. The 201 Construction Grants program is a possible
source of funding for small waste flows programs.
The assessment of current 208 programs' consideration of small waste
flows technology and management is given on a state-by-state basis, with the
U.S. EPA Region V personnel comments provided first.
a, U.S. EPA Region V Personnel
U.S. EPA personnel contacted felt that most 208 plans in the region had
not incorporated the potential utilization of small waste flows technology or
the particular wastewater needs of rural areas in their plans. Their percep-
tion was that the current plans generally concentrated on the control of
pollution problems in urban areas with emphasis currently being shifted to the
control of non-point source pollution problems. The problems and needs of
rural wastewater areas were only beginning to be addressed with the new incen-
tives for the use of innovative and alternative technology.
b. Illinois
Illinois EPA prepared a 208 plan for the non-designated areas of the
state, which encompass more than 75% of the state (Illinois EPA, 1979). This
plan and the plans developed by the three designated 208 agencies included
Municipal Needs Analysis (MNA) for all communities with populations above 200
that had not prepared a facilties plan. The Municipal Needs Analyses identi-
fied the present wastewater-related needs of the community in relation to the
state's strategy for point source control and projected these needs over a
20-year planning period. Alternative strategies for meeting the needs were
determined, and the most cost-effective solution was identified. An environ-
mental assessment was then performed, and recommendations for action were made
for the individual communities. In many instances, the recommended actions
include upgrading or continued use of existing on-site systems.
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C. POTENTIAL 208 PROGRAM ROLES IN SMALL WASTE FLOWS AREAS
1. INTRODUCTION
Rural communities wishing to utilize small waste flows technology and
management may not possess the expertise, manpower, and/or capital that are
needed for the design, implementation, and operation of a small waste flows
program. Such communities will require assistance from other public agencies
or private contractors who can provide necessary expertise and services.
Existing state and regional agencies, primarily 208 agencies, involved in
wastewater planning can provide valuable assistance to these communities.
Advantages to utilization of these existing agencies are many, including:
• the agencies' familiarity with the communities' and areas' needs,
resources, people, and other characteristics,
• economies of scale in costs and personnel that can be gained by a
centralized agency performing region-wide studies serving a number of
communities,
• the agencies' access to and familiarity with existing planning tools
and their utilization, and
• the expertise within the agencies that may not be present in rural
communities.
The intent of this report will be first to assess current 208 program
activities in relation to small waste flows management and secondly to assess
activities related to small waste flows management that potentially could be
performed by regional and statewide 208 agencies.
2. CURRENT 208 PROGRAMS
In assessing the involvement that existing 208 agencies have had in small
waste flows management, information was sought from U.S. EPA, state, and
regional 208 agencies concerning answers to the following questions:
• How have rural wastewater planning areas been incorporated into the
208 planning process, and how has the use of small waste flows tech-
nology and management been considered?
• A certified 208 plan designates who the grant applicant must be. Will
this cause problems for small waste flows management programs?
• Are there staff members available within the 208 agency knowledgeable
in small waste flows technology and management?
• Is there potential funding support for small waste flows programs
under the 208 programs?
Answers to all but the first of these questions were basically the same from
all of the 208 agencies contacted. The question concerning designation of a
management agency was raised because it was felt that the management agency
that was designated to operate conventional wastewater facilities may either
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tion and experience requirements in each of these States are similar to the
Illinois requirements. However, sanitarians do not have to be certified to
work within these states. Certain local health departments require their
sanitarians to be certified in accordance with the State program while other
localities fill sanitarian positions with political appointees and under-
skilled personnel. Wisconsin, as explained above, requires persons involved
in the administration and enforcement of on-site sewage disposal facilities to
be certified plumbing inspectors. Requirements for obtaining plumbing certi-
fication include the successful completion of a training program and the
passage of a state examination. Wisconsin also requires all persons conduct-
ing soils evaluation to be certified as soil testers. Certified soil testers
are required to pass a state examination. All local units of government
regulating on-site disposal systems in Wisconsin are required to hire or
contract the services of a certified soil tester. Certification and hiring
requirements are described in greater detail in Section VI.F.
4. AUTHORITY OF SANITARIANS
The authority of sanitarians to regulate on-site systems, like hiring and
certification requirements, vary from locality to locality within Region V.
The extent of a sanitarian's authority is determined by the State's codes for
on-site regulation (Section XV.A.) and enabling legislation (both local and
state) concerning issues such as access to inspect systems and the power to
condemn houses served by systems creating a health hazard. Facilities plan-
ners considering SWF alternatives need to investigate the authority that the
local health department of utility district has with regards to the regulation
of on-site systems and enforcement of health and water quality standards.
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B. ORGANIZATION AND MANPOWER FOR ON-SITE REGULATION
1. INTRODUCTION
On-site systems in the Region V states primarily are regulated by county
and municipal governments. State involvement in the regulation of on-site
systems, in contrast with centralized facilities, is relatively minor. The
States' role consists of promulgating on-site regulations and providing
technical assistance to local health departments. Overall, the regulation of
on-site systems varies from one locality to another throughout most of Region
V.
2. MANPOWER ESTIMATES
Sanitarians, in most cases, are the persons responsible for regulating
on-site systems on the local level. Hiring and certification requirements
differ according to locality and state. Estimates of the number of sani-
tarians were collected from each of the Region V states. These estimates are
the following:
• Illinois: 1,189 registered sanitarians
• Indiana: 680 registered and unregistered sanitarians
• Michigan: 550 registered and unregistered sanitarians
• Minnesota: 329 registered sanitarians
• Ohio: 775 registered sanitarians
• Wisconsin: 111 certified plumbing inspectors
3,000 certified soil testers.
It must be noted that these estimates do not give a true picture of the
actual number of sanitarians actually working with on-site systems in the
field. Reasons for this include the difficulty in determining what amount of
effort is spent by sanitarians on on-site systems in addition to other duties
such as restaurant inspection, rodent control, etc. and the fact that many
states do not require the registration of sanitarians. One state, Wisconsin,
does not list on-site regulators as sanitarians. They are classified as
plumbing inspectors and soil testers instead.
3. TRAINING AND HIRING REQUIREMENTS
Illinois is the only state within Region V which requires the registra-
tion of all sanitarians working in the state. The remaining states, with the
exception of Wisconsin, having voluntary certification requirements for sani-
tarians .
The Illinois requirements consists of a combination of education and
experience criteria which must be met prior to a sanitarian becoming certi-
fied. Persons meeting the education requirements but lacking the required
experience may work in Illinois as sanitarians-in-training. Indiana,
Michigan, Ohio, and Minnesota have voluntary certification programs. Educa-
XV-B-1
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Wheeler, Gil, and Jim Bennett. 1979. The campaign in California for alterna-
tive systems. In: Individual on-site wastewater systems: Proceedings
of the Fifth National Conference, 1978 (Nina I. McClelland, ed.). Ann
Arbor Science Publishers, Ann Arbor MI, pp 83-93.
Wisconsin Department of Health and Social Services. 1976. Wisconsin Plumbing
Code. In: Wisconsin Administrative Code, Rules of Department of Health
and Social Services. Madison WI.
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REFERENCES
Great Lakes Basin Commission. 1976. Appendix 520. State laws, policies, and
institutional arrangements. Great Lakes Basin framework study. Ann
Arbor MI.
Ilinois Department of Public Health. 1974. Private Sewage Disposal Act and
Code. Springfield IL.
Illinois Environmental Protection Agency. 1980. Illinois recommended stand-
ards for sewage works. Springfield IL.
Illinois Pollution Control Board. 1979. Rules and regulations, Chapter 3:
Water pollution. Springfield IL.
Indiana State Board of Health. 1978. Septic tank-absorption field sewage
disposal systems. Bulletin No. S.E.8. Indianapolis IN.
Indiana State Board of Health. 1978. Planning guide for water supply and
wastewater disposal for small public, commercial and place of employment
buildings: Minimum requirements. Bulletin S.E.13. Indianapolis IN,
Indiana State Board of Health. 1978. Regulation HSE 25-R, Residential on-
site wastewater disposal. Indianapolis IN.
Indiana Stream Pollution Control Board. 1980. State water quality management
plan. Indianapolis IN.
Michigan Department of Public Health, Bureau of Environmental and Occupational
Health. 1977. Michigan guidelines for subsurface sewage disposal.
Lansing MI.
Minnesota Department of Natural Resources, Division of Waters. 1976. Shore-
land management: Elements and explanation of the municipal shoreland
rules and regulations. Supplementary Report No. 5. St. Paul MN.
Minnesota Pollution Control Agency. 1978. 6 MCAR Section 4, 8040, Individual
sewage treatment standards, WPC 40. St. Paul MN.
Ohio Department of Health. 1977. Home sewage disposal rules. Chapter
3701-20-01 to 3701-29-21 inclusive of the Ohio Sanitary Code. Columbus
OH.
Ohio Environmental Protection Agency. 1974. Rules of the Ohio EPA. Home
sewage disposal in special sanitary districts. OAC-3745-13; OAC-3745-43.
Columbus OH.
Ohio Environmental Protection Agency. 1979. Initial water quality management
plan, Maumee/Portage River Basins. Columbus OH.
Otis, Richard J., and David E. Stewart. 1976. Alternative wastewater facili-
ties for small unsewered communities in rural America. University of
Wisconsin, Small Scale Waste Management Project, Madison WI.
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system, levy property taxes, or levy special assessments for the purpose of
raising revenues to pay debt service as well as operation and maintenance
costs. Town utility districts appear to be eligible for EPA and FmHA waste-
water facilities grants.
Metropolitan sewerage districts are established by an order from
Wisconsin DNR after the receipt of a resolution for district formation from
one or more municipalities. Authorities granted to metropolitan sewerage
districts are delineated in Section 59, 66, and 67 of the Wisconsin Statutes
1973. Metropolitan sewerage districts have been granted broad powers to
manage wastewater systems. They may raise revenue through property taxes,
special assessments, service charges, and standby charges. Methods of
borrowing include: municipal bonds, general obligation bonds, mortgage bonds
and certificates, special improvement bonds, and promissory notes. Metro-
politan sewerage districts are enabled to receive grants from EPA and FmHA for
water pollution control facilities.
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Cities in Wisconsin are enabled to own, operate and maintain wastewater
systems under Sections 62 and 66 of the Wisconsin Statutes 1973. Wisconsin
cities are authorized to incur indebtedness to fund wastewater facilities
through financing mechanisms such as general obligation bonds, promissory
notes, mortgage bonds, and special assessment bonds. Cities may institute a
user charge system and levy special assessments. Cities are eligible to
receive Federal grants for wastewater facilities.
The powers and authorities of villages essentially are the same as
cities. Villages may own and operate wastewater facilities as well as to
incur indebtedness and establish user charge systems to pay for the
facilities. Villages may receive grants from EPA and FmHA to construct
wastewater facilities. The authorization for villages to manage wastewater
systems is contained within Sections 61, 62, and 66 of the Wisconsin Statutes
1973.
Towns (townships) are authorized to construct, own, and operate
wastewater facilities in accordance with Sections 60, 66, and 67 of the
Wisconsin Statutes 1973. Towns which are incorporated under Section 60.18
have the same powers and authorities as villages. Unincorporated towns have
the ability to incur indebtedness through means such as borrowing, town bonds,
general obligation bonds, mortgage bonds, and special assessment bonds.
Indebtedness is limited by statute and must be approved by the electors of the
town. Towns may institute a system of user charges to retire debt and finance
operation and maintenance costs.
Wisconsin counties also are authorized to directly manage wastewater
facilities through Sections 59 and 66 of the Wisconsin Statutes 1973. The
financial powers of counties are limited to the use of mortgage bonds and
constructors certificates to pay facilities construction costs. They have the
ability to tax, institute user charges, and, to a limited extent, levy special
assessments. It is not clear whether or not counties have even the implicit
authority to manage decentralized facilities and they may not have the
authority to accept EPA Construction Grants (Otis and Stewart, 1976).
Special purpose districts allowed under Wisconsin law include town
utility districts, town sanitary districts, and metropolitan sewerage
commissions. Town sanitary districts (TSD's) may be formed in any unincor-
porated area of Wisconsin under Section 60, 66, and 67 of the Wisconsin
Statutes 1973. TSD's are enabled to borrow money, issue mortgage bonds, gen-
eral obligation bonds, TSD bonds, revenue bonds, and special improvement
bonds. TSD also have been granted authority to levy a tax on all taxable
property within the district to cover debt retirement, operation, and
maintenance costs. TSD's are authorized to collect user charges and levy
special assessments. They are authorized and eligible to receive Federal
water pollution control grants. TSD's may be established by a town board or
by order of the Wisconsin Department of Natural Resources.
Town utility districts are formed by a town board ordinance (after a
public hearing) in accordance with Section 66.072. Town utility districts are
authorized to provide and manage wastewater facilities. A town utility
district may use the following methods of borrowing: municipal bonds,
mortgage bonds, public improvement bonds, certificates, promissory notes, and
bond anticipation notes. Town utility districts may develop a user charge
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Ohio municipalities are authorized to manage wastewater facilities under
Article XVIII of the Ohio Code and Section 729.49 of the Ohio Revised Code.
Municipalities may acquire, construct, own, maintain, and operate wastewater
collection and treatment systems. Municipalities have the power of eminent
domain for any public purpose including wastewater facilities. Fiscal
authorities granted municipalities include setting rates for services provided
within and outside corporate boundaries, levy property and use taxes, and
issue bonds (general obligation and revenue).
Counties may acquire, construct, and operate wastewater systems.
Counties are authorized by Ohio Revised Code Section 6117 to provide waste-
water service. Ohio counties have taxing authority and the ability to issue
bonds to plan and construct wastewater facilities.
Sanitary districts are allowed under Section 6115 of the Ohio Revised
Code. Sanitary districts may be established by a petition of landowners,
municipalities, or counties. The purposes of the district include correcting
water pollution problems, providing water, and disposing of liquid and solid
waste. As such they are enabled to own, construct, and operate wastewater
systems. Sanitary districts may levy special assessments against benefited
property and issue bonds to pay for the costs of wastewater facilities.
Regional sewer and water districts are organized under Section 6119 of
the Ohio Revised Code. The purpose of regional sewer and water districts are
the provision of water and the collection of liquid wastes. Formation of the
districts may be accomplished by court petition within unincorporated portions
of counties or by one or more municipalities. Powers include acquiring,
constructing and operating wastewater facilities as well as eminent domain.
Regional sewer and water districts may issue bonds for construction and
operation costs, levy taxes for bond retirement, and levy special assessments.
Conservancy districts are the final form of management agency allowed in
Ohio. Their authority is contained in Section 6101 of the Ohio Revised Code.
Conservancy districts are organized for a variety of purposes such as flood
control, flow regulation, public water supply, and collection and disposal of
liquid wastes. Conservancy districts can be established by a court order
resulting from the petitions of either landholders or local governments. A
conservancy district must develop and adopt a plan for carrying out its
purposes. The districts have limited power of eminent domain and the power to
own, construct, and operate wastewater facilities. Conservancy districts are
enabled to tax property, levy special assessments against benefited
properties, and issue revenue or general obligation bonds.
Wisconsin
Five mechanisms exist in Wisconsin to manage wastewater facilities. The
management mechanisms are: cities, villages, towns, counties, and special
purpose districts. None of these have been granted explicit authority to
manage on-site systems. The breadth of their authorities granted under the
Wisconsin statutes appears to grant implicit authority for this management
function. All of the management agencies described in the section are
eligible for receipt of Federal water pollution control grants from either EPA
or FmHA.
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upgrade and rehabilitate the community's malfunctioning on-site systems. The
State of Illinois is monitoring the performance of on-site wastewater
management zones to determine whether or not similar mechanisms should be
established for counties, townships, and special purpose districts.
Currently, Illinois enables the on-site wastewater management zones to be
created only within the boundaries of cities, villages, and incorporated towns
(IEPA, 1979).
Counties in Illinois have very little active involvement in the
management of either centralized or decentralized facilities outside of
traditional health department and planning department activities. Counties
have been granted authority (Chapter 34, Section 3101, Illinois Revised
Statutes) to construct and operate a sewage system for the purpose of
controlling and regulating the disposal of sewage. They may also pass rules
and regulations governing the operation and maintenance of sewage facilities.
Despite the authority, few counties appear to be actively involved in managing
wastewater facilities. No explicit authority has been granted counties to
manage SWF districts in Illinois (IEPA, 1979).
Townships having less than 500,000 population have the power to
construct, own, and operate sewerage facilities (Chapter 139, Section 160.31,
Illinois Revised Code). No explicit authorities have been granted townships
in Illinois to manage SWF districts. Like counties, townships are used very
little as wastewater system management agencies (IEPA, 1979).
Two types of special purpose districts are enabled under Illinois law to
manage wastewater facilities. Sanitary districts (Chapter 42, Sections 247
and 418, Illinois Revised Code) are organized to prevent the pollution of
water through the construction and operation of wastewater facilities. Over
100 districts have been formed throughout Illinois. Sanitary districts can be
formed to serve either incorporated or unincorporated areas. They have the
authority to establish user charges and levy property taxes. No explicit
authority has been granted sanitary districts to manage on-site systems.
Conservancy districts are the other type special purpose district which
can be utilized in Illinois to manage wastewater (Chapter 42, Sections
383-410.1, Illinois Revised Code). In addition to prevention of water
pollution, conservancy districts may organize to carry out activities such as
conservation practices, construct flood control projects, irrigation, and
recreation. Conservancy districts generally are more difficult to form and
few have been used recently for the purpose of constructing and operating
wastewater facilities. Conservancy districts have not been granted explicit
authority to manage on-site systems. Conservancy districts do have the
authority to issue general obligation bonds with referendum approval and to
levy special assessment taxes on property benefited by district improvements.
Because of the taxing power, it is easier for conservancy districts to issue
funds to meet front end costs than it is for special districts lacking the
authority to tax.
Indiana
Municipalities and special purpose districts are the only public bodies
enabled under Indiana law to manage wastewater facilities. Neither munici-
palities or special purpose districts have been granted explicit authority to
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manage a SWF district. However, these management structures do have the
implicit authority to carry out a local SWF program.
Municipalities (cities and towns) do have the authority to manage
wastewater systems (Indiana Code 19-2-5). Their authorities are broad enough
to meet the grant assistance requirements of U.S. EPA and FmHA. Front-end
costs can be met through taxes or general revenues of the municipality. The
authority of municipalities extends only to their boundaries, but they may
accept wastes from other nearby jurisdictions.
There are three types of special purpose districts which may be used to
manage wastewater facilities in Indiana: sanitary districts, regional sewage
districts, and conservancy districts. Sanitary districts can be formed only
by cities having a relatively large population (50,000 and over) and are not
applicable to this study.
Indiana enabled the formation of regional sewage districts (RSD) in 1969
under Indiana Code 19-3-1. RSD's can be formed to serve either incorporated
or unincorporated areas. They are the predominate mechanism used to manage
wastewater facilities in unincorporated areas. RSD's are relatively easy to
form in comparison to conservancy districts. They also meet eligibility
requirements for Federal grants. They do not have taxing authority and thus
have difficulty generating funds to meet front-end costs. Operating costs and
debt retirement are paid through the receipt of user charges.
Conservancy districts are formed under Indiana Code 19-3-2 to provide one
or more functions such as flood control, drainage, irrigation, water supply,
sewage, recreation, and soil erosion control. The actual process of
establishing a conservancy district can be arduous and time consuming. Con-
servancy districts have the statutory authority to levy taxes on real property
within the district and to make assessments on property within the district
receiving special benefits from district improvements. They can meet front-
end costs as a result of their taxing authority. However, also due to their
power to tax, they meet more public opposition during the process of district
formation.
Counties and townships have not been granted the legal authority to
construct, own, and operate wastewater facilities in Indiana. Attempts are
being made, however, to grant counties this authority.
Michigan
Four major types of public agencies are enabled to manage SWF districts
in Michigan. These management structures are incorporated cities and
villages, counties, townships, and special purpose districts. The State of
Michigan has not granted explicit authority to any of these for the purpose of
managing a local SWF district.
Municipalities (cities and villages) are legally enabled (Act 233, Public
Acts of 1955) to construct, own, and operate wastewater facilities. Munici-
palities can serve users inside and outside of its boundaries. It is not
known whether or not municipalities can manage a SWF district which lies
outside the corporate boundaries. Municipalities can levy special assessments
and property taxes. Front-end costs can be met through the taxing mechanisms.
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Michigan municipalities meet the management agency requirements for EPA and
FmHA grant assistance.
Counties have been granted the authority to manage wastewater systems in
Michigan (Act 342, Public Acts of 1939). Their powers and authorities include
taxing. Counties also are eligible for federal grant assistiance from EPA and
FmHA. No explicit authority exists for counties to manage decentralized
facilities, but they have implicit authority to do so.
Townships also have been granted the authority (Michigan Constitution,
Article 7, Section 123.241) to construct, own, and operate wastewater facili-
ties. Townships are grant eligible and have taxing authority. They have the
ability to meet front-end costs associated with planning centralized or
decentralized wastewater facilities.
Special purpose districts which are allowed to manage wastewater
facilities under Michigan's laws include water and sewage districts, special
assessment districts, and metropolitan districts. Water and sewage disposal
districts are empowered under the Michigan Constitution, Article 7, Section
323.158, to construct, own, and operate sewage disposal districts within their
territory. The water and sewage districts may be created when any two or more
municipalities (defined to be any county, township, city, or village) petition
the Michigan Water Resources Commission for the organization of a water or
sewage disposal district. Approval by the electorate of the participating
local units of government also is required. A participating municipality may
levy special assessments and issue general obligation bonds against the full
faith and credit of the municipality to pay for its portion of district costs.
The districts are eligible to receive Federal grants from EPA and FmHA.
Special assessment districts may be formed to acquire, own, and operate
parks or public utilities for the purpose of supplying sewage disposal,
drainage, water, or transportation. Special assessment districts may be
formed by any two or more local units of government. Their powers and
authorities are similar to those of the water and sewage districts.
Metropolitan districts may be formed for the purpose of owning,
operating, and maintaining sewage disposal systems (Act 312, Public Acts of
1929). The districts may establish special assessments to pay for the costs
associated with construction, operation, and debt retirement. They are
enabled to receive grants from any government or private source.
Minnesota
Cities, counties, towns, and special purpose districts are enabled to
manage wastewater facilities. Cities, including villages and boroughs, are
authorized to construct, operate, and maintain sewer systems, sewage treatment
works, disposal systems, and other facilities for disposing of sewage within
or outside of their corporate limits. While not explicitly allowed to manage
SWF districts, the implicit authority of cities, villages, and boroughs to do
so is apparent (Otis and Stewart, 1976). They are able to issue tax backed
general obligation bonds and levy special assessments against property which
is benefitted by the wastewater facilities. Cities, villages, and boroughs
are eligible to receive Federal wastewater pollution control grants and loans.
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Minnesota counties are empowered to manage wastewater facilities in a
manner similar to that of cities. The major exception to this is that the
seven counties of the Twin Cities metropolitan area. These couties must
obtain approval by the Metropolitan Council prior to receipt of Federal
wastewater facilities grants.
Only organized towns (townships) having a population exceeding 3,000 and
an assessed valuation of taxable property of more than $10 million are enabled
under Minnesota's statutes to manage sewage treatment plants and lay sewers.
It is uncertain whether or not towns are enabled to collect user charges and,
thus, they may not be eligible for Construction Grants from EPA. The
Minnesota statutes enable towns to pay operating costs from the general fund
or from special assessments.
There are two major types of special purpose districts which can be
formed in Minnesota for the purpose of providing wastewater collection and
treatment. One form of sanitary district may be formed under Chapter
115.17-37 of the Minnesota Statutes. The Minnesota Pollution Control Agency
must be petitioned to establish a sanitary district under Chapter 115.19-37.
Sanitary districts may include municipalities, organized towns, or unorganized
(unincorporated) parts of counties. Sanitary districts formed under this
chapter have the explicit authority to manage on-site systems as well as
centralized facilities. Sanitary districts may issue bonds and draw upon the
full faith and credit of participating units of government to back up general
obligation bonds. Bond issues must be approved by the participating units of
government. Sanitary districts organized under Chapter 115.19-37 are eligible
to receive Federal water pollution control grants.
Public water and sewer systems may be formed under Chapter 116A of the
Minnesota Statutes in all areas of the State except for the seven-county Twin
Cities metropolitan area and Mower County. Public water and sewer systems are
relatively easier to organize than sanitary districts formed under Chapter
115.19-37. Public water and sewer systems are created by a county board,
district court, or upon petition from 50 percent of the landowners in the
proposed service area. Unlike sanitary districts, public water and sewer
systems are not required to be approved by the Minnesota Pollution Control
Agency prior to formation. No explicit authority to manage on-site systems
has been granted to public water and sewer systems. However, the enabling
legislation is very broad and implicitly allows for management of decen-
tralized facilities. The public water and sewer systems may issue general
obligation bonds backed by the full faith and credit of the county where the
management agency is located. At least 60 percent of the principal and
interest on general obligation bonds must be paid from user charge receipts
and special assessments. Public water and sewer systems are not authorized to
issue revenue bonds or special assessment bonds. Public water and sewer
systems clearly are eligible for Federal water pollution control grants.
Ohio
Five types of public bodies have legal authority to manage wastewater
facilities. These agencies are municipalities, counties, sanitary districts,
regional sewer and water districts, and conservancy districts. None of these
are explicitly authorized to manage SWF systems. However, it does appear that
implicit authority does exist for the agencies to manage SWF systems in Ohio.
XV-A-14
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purpose district does vary according to the legal authority granted by a
state. In some cases, special purpose districts such as conservancy districts
have the legal authority to levy taxes on property. However, districts having
the power to tax often involve a long and tedious legal formation process.
Districts which do not have taxing authority are easier to form but have
difficulty raising funds to meet front-end costs associated with the planning
and designing of wastewater facilities. Special purpose districts
historically have been oriented towards the ownership, operation, and
management of centralized facilities. They also appear to be well suited for
the management of SWF districts. The State of California has been promoting
the on-site wastewater management district (OSWMD) concept. The use of
OSWMD's gives great flexibility in supervising potential water quality
problems from on-site systems and provides a means to ensure reliable
management of on-site systems (Wheeler and Bennett, 1979).
Municipalities
Municipalities (including cities, villages, and townships) traditionally
have been heavily involved in the construction, ownership, operation, and
management of wastewater facilities. The focus of municipalities typically
has been on centralized facilities. Most states have granted municipalities
the legal authority to manage sewers and treatment plants. It is not known
definitely whether or not this power also enables municipalities to manage SWF
systems. In response to this uncertainty, the State of Illinois granted
explicit authority to municipalities to create on-site wastewater disposal
zones.
In addition to direct management of wastewater facilities, some
municipalities also have their own health department and planning department.
As such, these municipalities have the authority to approve or disapprove the
installation of individual on-site systems and to make planning decisions
based on soils suitability criteria.
c. Local Management Agencies in the Region V States
Different types of public agencies can be used to directly manage
(construct, own, and operate) a local SWF program in Region V. This section
describes the types of management agencies with a state-by-state focus. The
focus is on the primary management agencies, i. e. those which will be
eligible for EPA Construction Grants and which will be responsible for the
day-to-day operation of the SWF district.
Illinois
The State of Illinois has enabled several types of public bodies to
manage wastewater facilities. Most of the bodies have implicit authority to
manage a SWF system. However, in 1978, the Illinois legislature passed
legislation (Public Act 80-1371) enabling the creation of on-site wastewater
disposal zones. Local governments are enabled to assume responsibility for
assuring proper design, installation, maintenance, and rehabilitation of
systems within their boundaries. The ownership of on-site systems can remain
private, but the responsibility for system performance is the local
government's. Under the State legislation, municipalities forming on-site
wastewater management zones are eligible for an EPA Construction Grant to
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to a public body to operate and maintain private on-site systems. In spite of
this, SWF management agencies can be organized on the basis that their legal
authority is implicit from existing legislation. The types of existing
management agencies which have been set up to own, operate, and maintain
publicly owned centralized wastewater facilities can be used to manage local
SWF programs. The authority granted these agencies to operate sewers and
wastewater treatment facilities has been interpretated by some to imply that
these agencies also have the legal authority to manage privately owned on-site
systems (Otis and Stewart, 1976).
The interpretation of implied authority will vary from state to state and
may be challenged in courts on the grounds that the authority to run publicly
owned facilities does not imply authority to manage privately owned on-site
facilities. Thus, while SWF programs can be operated on the basis of implied
legal authority, there is a need in each Region V state except Illinois to
judicially test implied authorities or to grant explicit authority to SWF
management agencies along the lines of the legislation enacted in Illinois and
California.
b. Types of Management Agencies
Several types of management agency structures can be utilized to
implement a local SWF program. The functions of SWF management agencies are
described in Section VI.A. Management agencies must have administrative,
technical, and planning capabilities to successfully conduct a SWF program.
These functions may be shared by more than one agency on the local level. The
types of local management agencies which can be used to carry out SWF programs
are described in this section.
Counties
Counties may perform a variety of SWF management functions. County
health departments generally have the responsibility for approving or
disapproving individual on-site systems. Health departments have the
authority to monitor and inspect individual systems. They have the power to
enter upon private land if a threat to public health from a malfunctioning
on-site system is suspected. Some states have granted health departments the
authority to issue permits to install on-site systems.
County planning and zoning departments have the ability to perform some
of the planning functions necessary for a SWF program. Planning and zoning
departments also have the authority for the approval of on-site systems in
some states.
Counties often have the authority to own and operate non-central systems.
The authority of counties to operate wastewater facilities varies considerably
from state to state.
Special Purpose Districts
•t
There are several forms of special purpose districts which can serve as
SWF management agencies. Major types of special purpose districts include
conservancy districts, sanitary districts, regional sewer districts, and
on-site wastewater management districts. The powers of each kind of special
XV-A-9
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code requirements cannot be met and when the proposed system would not create
potential for problems. This also is the case in Illinois, which requires
that data must support the request. In Ohio, variances can be requested when
compliance with the requirements would cause unusual hardships. Although it
appears that in these states a variance procedure exists for new systems, no
specific guidance is provided in the codes on what information must accompany
a request or on what criteria the request will be evaluated.
Performance standards or other requirements for existing systems that
were installed prior to the.enactment of the current state codes are rarely
addressed, if at all, in the codes. It is inapparent whether this lack of
attention implies that if existing systems are located in violation of the
setback requirements, then their continued use is permitted. This would seem
reasonable if the system were functioning properly; however, it would be
undesirable if the system is gradually contributing to the contamination of
nearby waters. In the few codes that mention existing on-site systems, it
generally is in connection with the need for corrective action for malfunc-
tioning systems. But without routine or periodic monitoring of water quality
near existing on-site systems, which would detect the discharge of inade-
quately treated effluent to the groundwater, only the more obvious failures
would be detected, such as surface ponding or backup of wastewater into the
house.
The Wisconsin rules state that when a failing or malfunctioning private
sewage system is encountered, it must be corrected or its use discontinued
within a period not to exceed one year. For existing systems that are located
in floodplains and that have failed, replacement systems are allowed on a
case-by-case basis in order to abate health hazards. In flood-fringe areas,
malfunctioning systems may be replaced provided favorable soil conditions and
other site conditions exist. The Indiana code also specifies that when mal-
functions exist or occur and cause unsanitary conditions, corrective action
must be taken within the time set by the health officer.
The Minnesota code is the only one in Region V that specifically
addresses existing systems in relation to setback requirements. Substandard
systems, which are those that do not meet the setback requirements, are per-
mitted for as long as they function properly. Nonconforming systems, which
are those that are not sized or located in accordance with the code, must be
eliminated or upgraded to meet the standards. The nonconformance provison
does not necessarily apply to all setback requirements. For example, if a
system is functioning properly but it is in violation of the setback distance,
the owner is not required to move the system; however, if the system is
located in groundwater or in an area with shallow or exposed bedrock, the
system would have to be moved.
5. IMPLEMENTATION OF SMALL WASTE FLOWS MANAGEMENT PROGRAMS
a. Explicit vs. Implicit Authority
Management agencies organized to carry out a local SWF program must have
the legal authority to perform their roles. Some States such as Illinois and
California have passed enabling legislation granting explicit legal
authorities to certain public bodies to perform the functions necessary for a
local SWF program. However, most states have not granted explicit authority
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• Establishment of a procedure for evaluation of new technologies
• Collection of performance data for alternative systems
• Prevention of public health problems related to unsatisfactory
performance of new systems
• Provisions for inspection during construction and monitoring after
system is operational
• Encouragement of additional specialized training of regulatory
personnel.
Indiana allows alternative on-site treatment facilities to be constructed
in cases where soil conditions preclude the use of standard systems. While
not detailing the evaluation procedure to be followed, such rules do not
prevent the use of alternative systems.
c. Improving Outdated Regulations
Many state regulations have not been updated since the various
alternatives to septic tank systems were developed. These codes, therefore,
do not include mechanisms, other than variance procedures, for encouraging new
technologies. Before updating these codes, states should enact legislation
which provides for enforcement of the codes, if such legislation does not
exist. Regulations are much more effective if enforcement power exists. The
criteria mentioned in part a. of this section should be considered when
updating codes. Regulations from other states should also be reviewed to
determine if ideas or approaches to specific problems may have some appli-
cability in revising outdated codes. By revising outdated codes, states can
develop the flexibility needed to deal with the many types of alternatives now
being proposed.
4. SETBACK REQUIREMENTS OF THE STATE CODES
Implicit in the state codes is the recognition that private on-site
disposal systems, if improperly designed or if operated in unsuitable sites,
could lead to water quality degradation or human health hazards. The state
codes recommend minimum setback and soil depth requirements as a means to
minimize the potential for future adverse effects on local water quality. The
primary emphasis in these codes, however, is placed on the design and approval
of new or, in some cases, replacement systems. In general, the state codes
give very little guidance concerning the use of existing systems that are not
in compliance with setback requirements.
Most of the codes specify the minimum distances that new soil absorption
fields can be located from water supply wells, surface waters, and property
lines. Also set are separation distances between the bottom of new absorption
fields and groundwater tables or bedrock layers. Conformance with other
siting requirements, which are intended partially to minimize pollution
potential, is required as well. Typically, more stringent standards can be
adopted in local ordinances when such provisions would be necessary to protect
groundwater and surface water.
For new systems, some codes allow design factors, including setback
requirements, to be waived. Variances are considered in Michigan when the
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State regulatory programs often do not include guidance for dealing with
existing systems. The main thrust of state regulatory programs is usually the
permitting of new systems and not the management of existing systems. Rural
areas expecting Federal grants must propose an acceptable operation and
maintenance program along with a program for regulation and inspection of
individual systems.
These programs need to address the continuing operation and management of
existing systems, thus broadening the scope of regulatory programs to include
more than the permitting of new systems. Such programs should be considered
regardless of the status of Federal grants funds.
State codes can be judged for their encouragement of alternative
technology development by reviewing them in light of the following criteria:
• Ability to adopt new technologies
• Control of new technologies through experimental programs
• Guidance on how to use variance procedures
• Consideration of existing systems in regard to facilities planning,
variances, design, application procedures, and community management.
Every state has a different approach to regulation of on-site treatment
systems. After evaluating existing state codes in EPA's Region V for
regulation of on-site wastewater systems, methods that encourage the
development and acceptance of alternative on-site systems are noted in Section
b. below. Regulatory approaches that do not promote the development of new
alternatives are identified in Section c.
b. Regulatory Approches Encouraging the Development of
Alternative Technologies
One of the better ideas for encouraging the development of alternative
on-site systems is Minnesota's Advisory Committee on Individual Sewage
Treatment Systems (ISTS). This Committee is comprised of on-site systems
contractors and other people knowledgable of on-site treatment technologies
from universities and regulatory agencies. The ISTS Committee has power to
change existing codes so that they can be kept up to date with the numerous
alternatives available.
Wisconsin developed regulations in June of 1980 that allow alternative
on-site treatment systems to be acceptable under controlled conditions.
Although other alternatives can be considered, the only systems currently
included in the rules are mounds and subsurface pressure distribution systems.
The conditions under which these alternatives can be accepted include a 5-year
control period during which inspections and monitoring are conducted. If
performance is satisfactory after the 5-year monitoring and assessment period,
controlled use shall no longer be required. A limit on the number of
alternative systems allowed in each region is established which controls the
use of unproven technologies. Additionally, new alternative systems must be
inspected by a certified plumbing inspector specifically trained in mound
systems during the construction of the system. This regulatory approach has
many beneficial aspects, such as:
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Construction variances are granted under Ohio's on-site regulatory
program for experimental systems systems having design or components which
differ from those specified in the Rules. No mention is made in the Rules
concerning use variances.
f. Wisconsin
Chapter H 63 of the Wisconsin Administrative Code is the primary
regulation governing on-site systems. Wisconsin's regulatory program recently
was transferred from the Departemnt of Health and Social Services (DH&SS) to
the Department of Industry, Labor and Human Relations (DILHR). Counties are
the local unit of government responsible for carrying out Wisconsin's on-site
regulations. Every county in Wisconsin is required to adopt ordinances in
conformance with Chapter H 63.
Two permits are required for new on-site systems. The first of these is
the State septic tank permit. The septic tank permit is required prior to the
purchase and installation of a septic tank. The permit is obtained from the
local agency responsible for regulating on-site systems. Septic tank permits
are required for the purpose of keeping a record of the number of tanks sold
and the location of tank installations throughout the State.
Sanitary permits also are required by Wisconsin law. They are to be
obtained prior to the installation of any type of on-site system. No permits
are required for systems in existence prior to 1977 unless the system is
required to be altered or replaced.
Wisconsin provides for an open-ended consideration of alternative
systems. Chapter H 63 specifically allows septic tanks, mounds, and shallow
subsurface pressure distribution systems. The use of alternative systems can
be approved provided written approval from local authorities is obtained and
submitted along with detailed plans and specifications to DILHR for their
review and consideration.
Variances are not specifically mentioned in Chapter H 63. However, a
county is required to issue a written notice to each applicant whose sanitary
permit application is disapproved. The rejection notice is to state reasons
for disapproval and list any changes which would lead to the approval of the
application. Appeal procedures are delineated on the rejection notice. The
appeals procedure applies to new systems. There is no formal variance
procedure for allowing properly functioning substandard existing systems to
continue to be used.
3. THE EFFECT OF STATE CODES ON ALTERNATIVE TECHNOLOGY
DEVELOPMENT
a. Introduction
A variety of on-site technologies are available for the unsewered public
to treat and dispose of their wastewater. Many individual homeowners are not
aware of the large number of these options. As new techniques are tested and
field data are accumulated, alternatives to conventional septic tanks-soil
absorption systems become accepted and widely known. A restriction to this
process is often the regulatory codes that do not allow alternative systems to
be evaluated, installed, and monitored on an ongoing basis.
XV-A-5
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a number of innovative and alternative systems such as modified standard sys-
tems, privies, toilet devices, greywater systems, mounds, sewers for community
systems, sewage osmosis, seepage pits, and holding tanks.
Both WPC-40 and the Shoreland Management Act govern the use of existing
as well as new on-site systems. The Shoreland Management Act categorizes
lakes by three major uses and requires varying septic system setback distances
according to lake category types. Under Minnesota's Shoreland Management Act,
on-site systems are classified as conforming, non-conforming, and substandard.
Non-conforming systems are those which fall into one or more of the following
categories: 1) do not conform to size, construction, use, or maintenance
requirements of the local shoreland ordinance; 2) create a nuisance, public
health, or pollution problem; or 3) are located in certain areas having severe
limitations for on-site systems. Substandard systems are properly sized and
constructed but do not meet minimum setback requirements. Substandard systems
may be utilized until there are indications of system failure or need of
repairs while non-conforming systems are to be eliminated or upgraded to meet
standards upon identification.
e. Ohio
The principal regulations governing the use of on-site systems in Ohio
are the "Home Sewage Disposal Rules." The Rules are minimum standards for
on-site systems serving up to three residences. The Rules are promulgated by
the Ohio Department of Health under the Ohio Sanitary Code. All local health
districts are required to, at a minimum, adopt and enforce the Rules. How
ever, ODH does not have the power to force local health dis tricts to comply
with the "Home Sewage Disposal Rules" and, as a result, some counties have
on-site programs falling below ODH's minimum standards.
Systems serving more than three residences are regulated by the Ohio
Environmental Protection Agency (OEPA). OEPA also has jurisdiction over
on-site systems serving three or less residences within designated special
sanitary districts. Approximately 100 special sanitary districts have been
designated in Ohio and OEPA has established on-site system permit programs in
eight of the districts. Special sanitary districts consist of the land (up to
one mile) surrounding lakes, State parks, canals, reservoirs, and nature
preserves. OEPA enforces the "Home Sewage Disposal Rules" in the districts
where permitting programs are established. On-site systems in the remaining
special sanitary districts are regulated by OEPA in cooperation with the local
health departments.
The design criteria set out in the Rules cover septic tanks, aerobic
systems, surface and subsurface sand filters, pit privies, and soil absorption
systems. Innovative and alternative systems may be permited after receiving
written approval from the Director of ODH.
The Rules focus on new systems and systems undergoing alterations.
Installation and operation permits are required for all newly constructed or
altered on-site systems. No operation permits are required for systems in
place prior to the effective date of the Rules. Existing systems specifically
come under the regulations when malfunctions cause a nuisance or discharge
into groundwater or water supply.
XV-A-4
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Procedures for variances are contained in HSE-25R. Permits are required
prior to the installation of all new systems and any alteration of existing
systems. No provision is contained regarding permits for substandard existing
systems not planning or requiring alterations and repairs.
Three goals for improving the State's on-site program have been
identified by the Indiana Stream Pollution Control Board (SPCB) in the State
Water Quality Management (208) Plan. These are 1) improving the quality of
siting septic systems, 2) promoting the utilization of acceptable alternative
systems, and 3) strengthening the local management structure (Indiana SPCB,
1980).
c. Michigan
The regulation of on-site systems treating up to 10,000 gpd in Michigan
is carried out by local health departments. The "Michigan Guidelines for
Subsurface Sewage Disposal" promulgated by the Michigan Department of Public
Health (MDPH) suggest minimum standards which may be adopted at the discretion
of local health departments. Thus the actual regulation of on-site systems
varies from county to county.
The "Michigan Guidelines for Subsurface Sewage Disposal" consist of
standard design criteria for on-site systems. No mention is contained
concerning innovative and alternative on-site systems. A variance procedure
is outlined in the Guidelines where site conditions preclude the use of
standard on-site systems. A variance may be granted after the applicant makes
a written request stating the reason for the request and documenting site
conditions. The Guidelines also fail to make any mention of granting use
variances for existing systems which are operating without any malfunctions
but do not meet design criteria.
d. Minnesota
On-site systems are managed under two major regulatory programs in
Minnesota. The "Individual Sewage Treatment Standards" (WPC-40) were
developed by the Minnesota Pollution Control Agency (MPCA) and are enforced by
local units of government. WPC-40 represents minimum standards which must be
enforced throughout Minnesota. Local governments have the option of enacting
standards stricter than the ones delineated in WPC-40.
Some on-site systems also are subject to Minnesota's Shoreland Management
Act. All land located within 1,000 feet of a lake or 300 feet from a stream
fall under the jurisdiction of the Shoreland Management Act. The Minnesota
Department of Natural Resources has been responsible for developing regula-
tions under the Act. These regulations must be adopted and enforced by local
governments.
Minnesota's on-site regulatory program is an exemplary one for several
reasons. WPC-40 created the Advisory Committee on Individual Sewage Treatment
Systems (ISTS). The ISTS Committee is enpowered to recommend changes in
WPC-40. Committee members consist of regulators, practitioners, and
university professors specializing in on-site systems. Thus, a mechanism
exists for keeping Minnesota's on-site regulatory program technologically up
to date. WPC-40 also is a flexible regulation in that it specifically allows
XV-A-3
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Sewage Disposal Licensing Act and Code." The Code sets out minimum require-
ments which must be adopted by each county. The code requirements are
enforced by local health departments. Permits for systems serving one
residence are handled by the local health departments. A number of different
systems are allowed under the Code: privies, septic tanks, Imhoff tanks (with
or without sand filters), waste stabilization ponds, and approved package
treatment units in conjunction with approved supplemental treatment. Existing
as well as new systems are to comply with the Code.
The State of Illinois authorizes the trial and use of innovative and
alternative systems for private on-site systems. Variances for new systems
will be considered where site limitations make it impossible to comply with
the Code. No mention is made in the Code of "use variances" for existing
on-site systems which do not meet the State of Illinois standards. Variances
are described in detail in Chapter VII-A. Generally, existing systems with no
problems are left alone (By phone, Mr. Larry Heisserer, Illinois Department of
Public Health to Mr. Robert France, WAPORA, July 1980).
The Code is applicable to systems serving only one residence. Systems
serving more than one residence are regulated by the Illinois Environmental
Protection Agency (IEPA) through the "Illinois Recommended Standards for
Sewage Waste" (March 1980) and the State's NPDES program. Explicit standards
for innovative systems serving small rural and lakeshore areas are not
detailed by IEPA. However, the Standards do mention that it is the policy of
IEPA to encourage rather than obstruct the development of any equipment for
treatment of wastewater.
b. Indiana
Indiana State Board of Health (ISBH) issued minimum standards for on-site
systems in 1978 under Regulation HSE 25-R. The standards delineated in HSE
25-R are to be adopted and enforced by local health departments. Local
governments also may enact standards which are stricter than Regulation HSE
25-R. Further technical criteria are delineated in Bulletin S.E. 8 and S.E.
13.
Design criteria for septic tanks and subsurface absorption fields are
strictly laid out in HSE 25-R. The regulation covers components such as
building sewers, septic tanks, subsurface absorption fields, and privy vaults.
Site evaluations for the use of an on-site system in Indiana are based on soil
properties as set forth in the soil manuals and handbooks of the U.S. Soil
Conservation Service (SCS). Alternative equipment, facilities, or pollution
control devices may be approved where soil conditions preclude the
installation of a standard subsurface absorption field sewage disposal system.
The staff of the ISBH, Division of Sanitary Engineering, Area Personnel
Section must be consulted prior to the installation of systems which are an
alternative to conventional on-site systems.
Purdue University, in cooperation with the ISBH, currently is conducting
research on several alternative systems. The systems being considered include
pressure distribution system, alternating drainfields, double wide systems,
and elevated sand mound systems. The results of the study will be integrated
into ISBH's on-site education and assistance program. The education program
is carried out by ISBH in conjunction with Purdue University and the SCS.
XV-A-2
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A. REVIEW OF STATE CODES AND IMPLEMENTATION AUTHORITY FOR SMALL
WASTE FLOWS (SWF) MANAGEMENT
1. INTRODUCTION
The treatment and disposal of wastewater in the U.S. traditionally has
relied on two vastly different methods. Centralized facilities serving
densely developed urban areas consist of publicly owned sewers and a treatment
plant. A number of management structures have been developed to construct,
operate, maintain, and pay for these facilities. The effluent discharged from
centralized facilities must meet legislated standards for protecting the water
quality of the receiving stream or lake.
Decentralized facilities, on the other hand, serve less densely developed
rural areas and small communities. Decentralized facilities primarily consist
of privately owned on-site systems serving individual residences. They are
regulated by local health departments. Therefore, the objective of on-site
systems has been to protect public health rather than to meet water quality
standards. Small yet relatively dense rural and lake communities located far
beyond centralized wastewater systems may experience water quality problems
when numbers of on-site systems are high or where local ground or surface
water resources are sensitive to the impacts of these systems. Often,
malfunctions are caused by poor maintenance or inappropriate system design.
Many rural communities cannot afford centralized facilities to solve their
water quality problems. Thus, a need has arisen to merge certain aspects of
centralized and decentralized systems into a new system. The small waste
flows (SWF) management approach serves small rural communities by providing
centralized management to insure the proper planning, design, installation,
operation, and maintenance of decentralized facilities at an affordable cost
to users. The purpose of this report is to review existing state on-site
codes and authority granted for their management. The focus of the review is
on the ability of each Region V state to provide or allow centralized
management of on-site systems and to carry out a SWF management program.
2. ON-SITE REGULATORY PROGRAMS
On-site regulatory programs vary from state to state within Region V.
Generally, all of the state codes regulating on-site systems are focused on
specific design standards rather than on the performance of on-site systems.
Homeowners and builders wishing to install systems which do not meet design
standards, but which should perform without creating a public health or
pollution problem, must obtain a variance from either local or state agencies.
In addition, the state codes are oriented towards the installation of new
systems or replacement of malfunctioning existing systems. For the most part,
substandard existing systems (in terms of design) are left alone until they
malfunction whereupon they are required to be upgraded to meet code standards.
Program specifics such as the agencies involved, on-site design criteria,
allowance for alternative systems, regulation of existing on-site systems, and
variances are described in this section.
a. Illinois
Regulations for the use of on-site systems serving one residence have
been promulgated by the Illinois Department of Public Health in the "Private
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CHAPTER XV
STATE AND 208 PROGRAMS
-------
PART FOUR
STATE AND EPA ADMINISTRATIVE ALTERNATIVES
-------
REFERENCES
American City and County. December 1980. Public forum: Public participation
costs prove small change. 96(12):12.
Glass, J. J. 1979. Citizen participation in planning: The relationship
between objectives and techniques. J. of the American Planning
Association, Chicago IL.
Gravity, N. , et al. Shopping for sewage treatment: How to get the best
bargain for your community or home. The Environmental Policy Institute
and the Clean Water Fund, Washington DC.
Sargent, F.O. 1976. Rural environmmental planning. American Planning Asso-
ciation, Chicago IL.
U.S. Environmental Protection Agency. 1979. Municipal wastewater management:
Public involvement activities guide. EPA-430-9-79-005. Office of Water
Program Operations. Washington DC.
XIV-A-15
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local group responsible for providing input to a project at these meetings. A
self-contained slide program keyed to a narrative tape recording is parti-
cularly effective since it can be presented at meetings, be stationed at a
centralized information center, and be presented through media such as televi-
sion. Brochures may also be developed that coordinate with an audio-visual
package and provide more in-depth information.
A slide and tape program is relatively inexpensive and can be developed
around and aimed at a specific locality. Such media can portray the local
existing natural and man-made environment in a manner with which the audience
can readily identify. Within this framework, existing water quality problems
and their interrelationship with the existing environment can be explained.
It would then be possible to demonstrate the growth trends in the area, which
would in turn lead to a discussion of the 20-year planning period in terms of
population growth and wastewater flows. Treatment alternatives, including a
demonstration of standard as well as alternative and innovative treatment
systems, can then be presented.
The audience would be shown how to scrutinize a facilities plan and
evaluate the alternatives in terms of how they would affect the community.
Evaluative tools are outlined in U.S. EPA Environmental Assessment Manuals.
Local technical expertise could be provided by the Soil Conservation Service,
Agricultural Extension Service, and public health agencies.
The chronology and structure of the facilities planning process would be
presented with emphasis upon input by the public. Notice of when and where
public hearings are to be held would be given, and testimony would be soli-
cited. The requirements for formulation of a Public Advisory Committee that
acts as an intermediary between the public and the grantee or the grantee's
consultants would be explained. The avenues of communication between faci-
lities planners and the public and mechanisms for two-way communication and
feedback would also be discussed. Such a program would fulfill both the
letter and spirit of the Clean Water Act in providing a meaningful dialogue
between the planners and the public.
XIV-A-14
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Wastewater treatment facilities planning may be perceived as a highly
complex process by the citizens of an area. For any given decision-making
process, some segments of the public will feel adversely affected, while
others will feel positively affected. In addition, part of the public sector
will show lesser levels of interest in the decisions that are being made.
These individuals can be inventoried and identified, particularly since many
of them belong to voluntary associations, professional groups, and other civic
organizations.
Interest groups may be categorized according to the likely impacts of the
proposed action. Improvement of surface water quality by abating point-source
pollution will be felt as a benefit by lakeside homeowner associations and by
fishing and sports clubs. Taxpayers' associations may feel that the project
will erode the local tax base and have an overall adverse impact on the
locality.
For each type of impact, organizations and individuals likely to be
affected can be identified. Research to identify organizations can take
various forms. Techniques include canvassing the community, membership direc-
tories, and the yellow pages. This may be accompanied by formal attitude
surveys, such as the sanitary survey outlined in Chapter II-G, interviews, and
examination of existing membership mailing lists.
The recipient population might generally be categorized into four general
segments:
1. public interest groups,
2. general civic organigations ,
3. public health associations, and
4s. social groups.
Public interest groups include consumer associations, environmental organi-
zations, and minority associations. General civic organizations include
homeowner associations, industrial and labor groups, a Rotary or Lions Club,
state and local governments, and educational institutions. Public health
associations inlude scientific societies and professional organizations.
Social groups are differentiated into organized and unaffiliated citizens.
Organized social groups encompass churches, the Grange, 4-H Clubs, swim or
boat clubs and historical societies. Unaffiliated citizens are those who do
not fall into the above categories and may include such diverse groups as
large land parcel owners or minorities. The public participation specialist
would uncover these local groups, associations, and institutions that could
provide input to the public participation program.
Once population groups have been identified, a public information program
may be designed. Such a program would respond to local concerns, and would
explain in simple language what facilities planning is, how it proceeds, and
how the public can provide input.
Many information mechanisms are available to reach the public and draw
them into the process. Such mechanisms include audiovisuals, brochures,
public service announcements in commercial TV or radio programs, and presenta-
tions at organization meetings. Information meetings could be sponsored by
local organizations and associations, and efforts should be taken to make the
XIV-A-13
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TABLE XIV-A-4. MODEL PLAN OF STUDY: FULL SCALE PUBLIC PARTICIPATION (Concluded)
Decision point/technique
Schedule
Staff support
Target audience
5 .
Engineer's recommendation on
preferred alternative
a) public hearing notice2
b) prepare and mall fact sheet
30 days in advance2
c)
hearing on recommended
alternative and EIS1
6.
Town approval
a) agency responsiveness summary
distributed to hearing
participants2
b) final responsiveness study
submitted to U.S. EPA with
facility plan1
c) public notice of final
decision3
Application for Step 2 grant
a) CAC meeting to develop public
participation plan for Step
2 and 3
mos. 7-8
mos. 9
Public part. coor. General public
Public part. coor. Mailing list, civic
organizations, local
government
Grantee, General public
public part. coor.
Public part. coor. EPA, state, hearing
participants
Public part. coor. CAC members, grantee
rep.
1 Required by Part 35.
2 Required by Part 25.
3 Meets a performance standard of Parts 25 and/or 35.
SOURCE: Municipal Wastewater Management: Public Involvement Activities Guide, United States
Environmental Protection Agency, Office of Water Program Operations, Facility
Requirements Division, Washington, DC.
XIV-A-12
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TABLE XIV-A-4. MODEL PLAN OF STUDY: FULL SCALE PUBLIC PARTICIPATION—Continued
Decision point/technique
Schedule
Staff support
Target audience
Review public participation work
element. Develop public participa-
tion work.
a) Public CAS meeting to review
public participation workplan3
b) Revised public participation
workplan3
Development of Facilities Plan
1. Assess current situation
a) begin monthly newsletter3
b) informal consultation/
interviews3
c) joint 201-208 staff and CAC
wk. 5
mos. 2-4
Grantee,
Public part.
coor.
Public part.
coor.
Public part.
coor.,
consultant's
public liaison
Broad range of com-
munity interests, CAC,
consulting engineer,
grantee representative
General public
Key officials,
selected citizen
leaders and special
interests
Public part. coor. 201-208 staff and key
Grantee rep., advisory committees
consultant staff
and public liaison
2. Assess future situation mos. 3-6
a) field trip3
b) speakers bureau3
c) series of workshops on special
issues3
1) sensitive environmental areas
2) residential and industrial
growth
d) public meeting1
e) agency responsiveness summary1
Public part. coor.
CAC, consulting
engineer, grantee
rep.
Public part. coor.
consultant,
public liaison
CAC, public
part. coor.,
consultant
liaison, grantee
rep.
public part. coor.
General public
Public and civic
interest group
General public and
special interests
U.S. EPA, state
participants
in meetings
Consideration of alternatives
Cost-effectiveness analysis
a) fact sheet on alternatives2
b) speakers bureau continues3
c) CAC mid-study briefing3
d) public meeting1
e) agency responsiveness summary1
Public part, coor., General public
as previously
described
consulting engi-
neer staff
public part. coor.
CAC, grantee, public
groups
General public
U.S. EPA, participants
in meeting
(Continued)
XIV-A-11
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TABLE XIV-A-4. MODEL PLAN OF STUDY: FULL SCALE PUBLIC PARTICIPATION
Decision point/technique
Schedule
Staff support
Target audience
Award of Step 1 Grant
Engineer selection
a) public notice
b) informal meeting w/key interests
wk. 1
Grantee
Range of community
interest that will
ultimately be on
advisory committee
environmental
civic
business
labor
Initiate preliminary stages of
public participation plan of
study (work element of)
a) grantee hires public participation wk. 2
coordinator
b) consulting firm designates public wk. 2
c) begin to develop mailing list2 wks.
1-3
Grantee
Consultant
Grantee
d) Deposit key documents in town
library
e) public notice regarding avail-
ability of documents
f) establish citizen advisory
committee1
1) notice to mailing list
and media of opportunity
to become member2
2) notice to mailing list and
media of finally selected
members.3
g) public notice w/fact sheet of
first CAC meeting to review public
participation workplan. Fact sheet
will describe project. Notice will
include list of advisory committee
and engineer.3
h) train advisory committee members
and grantee in one-day workshop.
Purpose will be to review
briefly town's water quality
problems, need for action, role
of CAC, types of conflicts, and
tradeoffs likely. Establish
goals of CAC. Workshop run by
grantee and consulting engineer.2
wks. 1-3
wk. 3
Grantee
Public part.
coor.
Grantee
wk. 6
Public part.
coor.
Grantee
Voluntary community
leader w/organizational
skills and knowledge of
water
All those private and
public interests with a
potential interest in
the facilities plan. Some
of the list will be
obtained from the 208
agency.
Mailing list media
Members of local organi-
zations such as:
League of Women Voters
Chamber of Commerce
Sierra Club
taxpayers association
local union
minority group
mailing list
newspapers
CAC members, engineer,
town officials, state
officals
(Continued)
XIV-A-10
-------
TABLE XIV-A-3. PUBLIC PARTICIPATION WORK PLAN FOR BASIC PROGRAM (TOWN OF 10,000) (Concluded)
Decision point/technique
Schedule
Staff support
Target audience
b) notice of public hearing wk. 41
in local newspaper and
sent to all on mailing list2
Public liaison
General public,
mailing list
c) conduct public hearing to wk. 46
present final plan along
with the draft EIS (if
required) for their approval
to community. Allow for
additional citizen comments.
If previous public partici-
pation efforts have been
successful, however, no
significant new issues should
be raised at this time.1
5. Town of approval and submission
to State and EPA
a) public notice wk. 47
b) prepare final responsiveness wk. 48
1) place on file at local
libraries, town hall
Public liaison, General public
consultant, grantee
Public liaison
Public liaison
General public
U.S. EPA
1 Required by Part 35.
2 Required by Part 25.
3 Meets a performance standard of Parts 25 and/or 35.
SOURCE: Municipal^ Wastewater Management: Public Involvement Activities Guide, United States
Environmental Protection Agency, Office of Water Program Operations, Facility
Requirements Division, Washington, DC.
XIV-A-9
-------
TABLE XIV-A-3. PUBLIC PARTICIPATION WORKPLAN FOR BASIC PROGRAM (TOWN OF 10,000)--Continued
Decision
e)
f)
point/ technique
compile
attend
results
various
of survey3
local group
Schedule
wks.
wks.
15-16
17-10
Staff support
Public liaison
Consultant/public
Target
PTA,
JC
audience
' s , Grange ,
8)
3.
meetings3
Get on the agenda of
various civic groups'
weekly/monthly meetings.
Present overview of com-
munity water quality problems,
answer questions, explain re-
sults of citizen survey, seek
to further refine community
goals and objectives
prepare agency respon- wk. 22
siveness summary2
1) summarizes results of
citizen survey and other
public consultation efforts
2) outlines grantee's response
to citizen input
3) placed on file at local
libraries, town hall
Consideration of alternatives
a) develop fact sheets that wk. 26
describe various alternatives
being considered and outline
the costs and environmental
impacts of each3
b) distribute fact sheets that wk. 28
also include notice of up-
coming public meeting2
c) informal public meeting to wk. 32
discuss various alternatives,
answer questions, identify
options that may require
future study1
d) prepare local newspaper wk. 33
article that describes
public meeting and decisions
made3
liaison League of Women Voters,
Sierra Club
Public liaison U.S. EPA
Public liaison Mailing list
Public liaison Mailing list
Consultant, General public
public liaison,
grantee
Public liaison General public
e)
prepare agency responsiveness
summary2
A. Submission of final plan to town
a) distribute fact sheet that
highlights the major elements
of the proposed plan and
rationale for the selection3
wk. 34
wk. 40
Public liaison U.S. EPA
Public liasion Mailing list
(Continued)
XIV-A-8
-------
TABLE XIV-A-3. PUBLIC PARTICIPATION WORKPLAN FOR BASIC PROGRAM (TOWN OF 10,000)
Decision point/technique
Schedule
Staff support
Target audience
1. Step 1 grant award
a) hire public liaison
b) develop mailing list
c) develop public participation
workplan
d) distribute workplan and fact
sheet
wks. 1-6
Public liaison General public
Assessment of present and future
situation
a) interview 208 PAC and/or
CAC members3
1) their views on areawide
and local water quality
problems and key issues
that should be addressed,
population projections
2) their experience w/public
participation, key citizens
who should be contacted
wks. 9-10
Consultant
Members of 208 PAC
and CAC
b) interview key local officials wks. 11-12
and citizens3
1) identify major water
2) identify community goals
and objectives
c) publish article in local wk. 13
newspaper that:3
1) describes current situa-
tion and status of facilities
planning process
2) summarizes attitude of town
officials and key citizens
on local water quality
problems
3) highlights the importance
of public input and
describes scheduled public
participation activities
4) identifies staff contacts
d) develop and distribute wks. 13-14
citizen survey3
Based on data collected
during previous interviews,
survey will seek to refine
community goals, identify
level of knowledge and
preferences concerning
water quality.
Consultants
Public liaison
Public health officer,
town engineers, planners,
Conservation Commission
members, industrial
dischargers, Chamber of
Commerce
General public
Public liaison on
consultant or
grantee's staff
All registered voters
(Continued)
XIV-A-7
-------
TABLE XIV-A-2. MODEL PLAN OF STUDY OUTLINE: BASIC PROGRAM (TOWN OF 10,000) (Concluded)
Decision point/technique
Schedule
Staff support
Target audience
Consideration of alternatives
Develop and distribute mos. 7-9
factsheets3
Notice of public meeting2
- Public meeting1
Prepare article for local
- Agency responsiveness summary2
Submission of final plan to town
- Distribute factsheets3 mo. 10
- Notice of public hearing2
Public hearing1
Agency responsiveness
summary1
Town approval state/EPA review
and EIS decision
- Final responsiveness mo. 11
summary1
Public liaison
Public liaison
Public liaison,
consultant,
grantee
Public liaison
Public liaison
Public liaison
Public liaison
Consultant,
grantee
Mailing list
Mailing list
General public
General public
General public
Mailing list
Mailing list
General public
1 Required by Part 35.
2 Required by Part 25.
3 Meets a performance standard of Parts 25 and/or 35.
Source: Municipal Wastewater Management: Public Involvement Activities Guide, US Environmental
Protection Agency, Office of Water Program Operations, Facility Requirements Division,
Washington, DC.
XIV-A-6
-------
TABLE XIV-A-2. MODEL PLAN OF STUDY OUTLINE: BASIC PROGRAM (TOWN OF 10,000)
Decision point/technique
Schedule
Staff support
Target audience
Grant Award
Select engineer
- Public notice wk. 1
- Identify public liaison on wk. 2
grantee/consultant staff2
Information program
- Public notice to media and
mailing list of despository
and materials available
Identify key interests and
develop project mailing list2
- Deposit key documents in wks. 6-7
town library2
Public participation workplan
- Develop detailed public wks. 3-4
participation workplan
w/informal public input3
- Develop and distribute public wk. 5
participation workplan and
first factsbeet which identi-
fies engineer and describes
project1
Development of Plan
Assessment of present and
future situation
Interview 208 PAC members3 mos. 2-6
- Interview key local officials
and citizens3
- Newspaper articles in paper
- Develop and distribute
citizen survey3
- Attend various local group
meetings3
Compile results of survey3
- Agency responsiveness summary2
Grantee
Grantee and/or
consultant
Consultant
Public liaison
on grantee or
consultant's staff
Consultant
Consultant
Public liaison
Consultant
Public liaison
Public liaison
Key citizen leaders who
express interest in
participating
Mailing list
208 PAC members
Public health officer,
town engineer, town
planner, regional
planners, conservation
commission members,
rep. of local industry,
Chamber of Commerce, etc.
Mailing list
PTA, JC's, Grange,
League of Women Voters
Available to general
public, prepared for
EPA
(Continued)
XIV-A-5
-------
the formation of a mailing list. The public must be notified and consulted
regarding the nature and scope of the proposed project. The Step 1 grant
application must include an outline of the proposed public participation
program, and, if that is accepted, a Public Participation Work Plan must be
submitted (see Tables XIV-A-2 and XIV-A-3). Before selecting alternatives for
evaluation, the grantee should consult with the public as well as prepare and
distribute a responsiveness summary. When the alternatives are largely
developed, a public meeting must be held for consultation before a particular
plan has been selected. At this juncture, the grantee must prepare and dis-
tribute a responsiveness summary. Before final adoption of a facilities plan,
the grantee is required to hold a formal public hearing to discuss the recom-
mended alternative. A final responsiveness summary is to be included in the
final facilities plan.
For projects that justify a more intensive public involvement effort, the
regulations outline a full-scale public participation program. This type of
program is required when an Environmental Impact Statement is prepared, when
advanced wastewater treatment is called for, or when more active public parti-
cipation is needed. Reasons cited for more active public involvement include
significant cultural or environmental impacts, significant increase in
capacity or service area, substantial capital cost or user charge, significant
public controversy, and substantial opportunity for innovative or alternative
wastewater treatment systems.
In complying with these regulations, a grantee must institute a more
in-depth public information program. During the development of the plan of
study, the grantee must notify and consult with the public regarding the
nature and scope of the proposed project and outline the participation program
(see Table XIV-A-4). In this expanded program, a public participation coordi-
nator must be hired or designated and an advisory group established. The
grantee is required to submit a public participation work plan, including
measures to coordinate with the water quality management agency public parti-
cipation activities. A public meeting must be held during assessment of the
existing environment and discussion of the 20-year planning period, but before
selection of alternatives for evaluation. At this point a responsiveness
summary must be prepared. When alternatives are largely developed but before
a particular plan is selected, a public meeting should again be held and a
responsiveness summary prepared. Prior to the adoption of a final facilities
plan, a formal public hearing is to be held that may coincide with the public
hearing on the Draft EIS. Part of the final facilities plan must be a final
responsiveness survey.
In rural lake areas, the potential for public controversy in facilities
planning is high, judging by the experience of the Seven Rural Lake EIS. An
understanding of the human ecology of an area, the resident's current view-
points, attitudes, and goals, must be understood in order to develop a faci-
lities plan that is appropriate to the area. There are a number of ways in
which a community can go beyond the minimum participation requirements to meet
the particular needs in these rural areas. Grantees and their consultants
must be prepared to discover who the citizens in the area are and how they are
organized and to involve them directly in the facilities planning process.
This program will maximize the use of existing community resources.
XIV-A-4
-------
TABLE XIV-A-1.
DISTINCTIONS BETWEEN BASIC AND FULL-SCALE PUBLIC PARTICIPATION
PROGRAMS
Basic Public
Participation Programs
Full-Scale Public
Participation Programs
• Public notification and consultation
during preparation of the plan of study
• Public consultation early in the planning
process during the assessment of existing
and future situations but before the
selection of alternatives for study
• A public meeting when alternatives have
been developed but the preferred alter-
native has not yet been selected
• A public hearing prior to the adoption
of the facilities plan
• A public information program throughout
the planning process (including develop-
ment and use of a mailing list)
• Responsiveness summaries (1) after the
public consultation/public meeting that
occurs before selection of alternatives,
(2) after the public meeting on alterna-
tives, and (3) in the facility plan
(Final Responsiveness Summary)
• Advisory group
• Public participation
coordinator
• Consultation with advisory
group in developing public
participation workplan
• A public meeting early in
the planning process dur-
ing assessment of existing
and future situations but
before the selection of
alternatives for study
*This table is from material prepared by Barry Lawson Associates, Inc., Boston,
Massachusetts.
XIV-A-3
-------
monstrating that those viewpoints and preferences have been considered by
the decision-making official."
These regulations cover all aspects of the facilities planning process. Part
25 also specifies certain general ways to carry out the necessary steps to
gain public input.
Section 25 contains provisions specifying effective ways of carrying out
public participation activities. Section 25.4 requires the formation of a
mailing list to notify interested parties of deeds and events and to dis-
seminate pertinent information through fact sheets or newsletters. A central
repository of reports or information documents must be established at such
locations as schools, public libraries, town halls, or other places where
economical reproduction facilities exist. Periodic notice is to be given of
the availability of information materials, major decision-making events,
public hearings, or public meetings. In rural lake areas, consideration
should be given to conducting these meetings in areas most contiguous to the
lake, such as in swim clubs, boat houses, or sport clubs. Besides local
newspaper notice, efforts should be made to post meeting information at local
stores, crossroads areas, or in local membership newsletters.
Section 25.5 spells out the necessary steps for the timely distribution
of pertinent project information prior to notification of a public hearing or
public meeting. More informal public meetings may include such forums as
conferences, seminars, or workshops with local voluntary associations or
interest groups and should be held at a publicly convenient place and time.
The procedures for conducting public hearings are more fully described
(Section 25.6) to include 45-day notification, with background information, so
that presentations and witnesses may be scheduled in advance. The public
hearing must be located and scheduled to facilitate public attendance. Hear-
ing locations should be accessable by public transit and should be planned for
evening or weekend hours. In rural lake areas, these meetings should be
conducted in the summer months when seasonal residents may attend. A record
of the public hearing is to be made available to interested parties at cost.
Section 25.7 outlines provisions for the establishment of an advisory
group composed of balanced interests in the project area. These include local
business interests, local government officials, realtors, churches, civic
groups, sport clubs, developers, or environmental groups. The advisory
group's specified responsibilities include making recommendations to U.S. EPA
and decision makers, and conducting public participation activities. U.S. EPA
is to be available for training and assistance to the advisory group. These
specific sections should be consulted for further information.
40 CFR Subpart E, Part 35, Grants for Construction of Treatment Works,
outlines a two-tier public participation program in planning for wastewater
treatment facilities. A basic public participation program consists of the
minimum tasks and tools necessary in most Federally funded projects. A
full-scale public participation program applies to more complex projects with
potentially significant community impacts. Table XIV-A-1 shows the distinc-
tions between a basic and full-scale public participation program. A basic
public participation program is defined as suitable for less complex projects
with only minor community impacts. Under these provisons, a grantee must
conduct a public information program as specified in Section 25.4, including
XIV-A-2
-------
A. PUBLIC PARTICIPATION PLANS FOR RURAL PLANNING AREAS
The Clean Water Act regulations requiring public participation in the 201
facilities planning process have been in effect for almost 2 years. Sources
indicate that the reaction to the regulations has been frustration over
another set of regulations and very little experience with the techniques for
satisfying them (American City and County, 1980). However, it is recognized
that budgetary expenditures on public participation are modest in comparison
to the cost of litigation and construction delays that result from project
controversy. The public participation process does afford opportunities for
constructive input to the facilities planning process that can be key to the
implementation of a project. Through this process, facilities planners can
take into consideration a community's character, its social and environmental
values, and the attitudes of its citizens. This is especially true in rural
lake areas where the populace is more in touch with community and environ-
mental resources.
The Clean Water Act stipulates in Section 101(e) that "public partici-
pation... [in the facility planning process] shall be provided for, encouraged,
and assisted by the [EPA] Administrator and the States. The administrator, in
cooperation with the states, shall develop and publish regulations specifying
minimum guidelines for public participation in such processes." This mandate
reflects Congressional recognition that clean water depends on strong grass-
roots support. It demonstrates the necessity for the establishment of a
working relationship between the public and officials who make water quality
management decisions.
The Federal regulations referenced were published in final form on
16 February 1979 in 40 CFR 25, which relates to public participation programs
under the Resource Conservation and Recovery Act, the Safe Drinking Water Act,
and the Clean Water Act, as well as in 40 CFR Subpart E, Parts 35.917-1(g) and
35.917-5, which relates to Federal grants for the construction of sewage
treatment works. These regulations provide the overall framework for a public
participation program and furnish facilities planners with some useful tools.
Part 25 regulations define the public as "representatives of consumer,
environmental, and minority associations; trade, industrial, agricultural, and
labor organizations; public health, scientific, and professional societies;
civic associations; public officials; and governmental and educational asso-
ciations." This is a partial listing of persons and organizations who may
feel direct impacts, either benefical or adverse, from the implementation of a
particular facilities plan alternative. While these associations and organi-
zations exert considerable influence on decisions made on the local level, the
public at large must also be actively solicited for input.
Part 25 also defines public participation as follows:
"Public participation is that part of the decision-making process through
which responsible officials become aware of public attitudes by providing
ample opportunity for interested and affected parties to communicate
their views. Public participation includes providing access to the
decision-making process, seeking input from and conducting dialogue with
the public, assimilating public viewpoints and preferences, and de-
XIV-A-1
-------
CHAPTER XIV
PUBLIC PARTICIPATION
-------
REFERENCES
Nelson, J. D. , and R. C. Ward. 1980. Groundwater monitoring strategies to
support community management of on-site home sewage disposal systems.
Bulletin 140. Colorado State University Experiment Station.
Todd, D. K. , R. M. Tinlin, K. D. Schmidt, and L. G. Everett. 1976. Monitoring
groundwater quality: monitoring methodology. EPA-600/4-76-026. U.S.
Environmental Protection Agency.
Wolterink, T. J. , H. J. Williamson, D. C. Jones, T. W. Grimshaw, and W. F.
Holland. 1979. Identifying sources of subsurface nitrate pollution with
stable nitrogen isotopes. EPA-600/4-79-050. U.S. Environmental
Protection Agency.
Hagedorn, C., and E. L. McCoy. 1979. Soil suitability for on-site waste
disposal: Development of genetically marked Escherichia coli strains as
tracers of subsurface water flow. WRRI-65. Water Resources Research
Institute, Oregon State University.
Stewart, G. L. and J. R. Stetson. 1975. Tritium and deuterium as water
tracers in hydrologic systems. Pub. No. 55, Report FY-76-2. Water
Resources Research Center, University of Massachusetts, Amherst MA.
Thompson, G. M., and V. M. Hayes. 1979. Trichlorofluoromethane in groundwater:
A possible tracer and indicator of groundwater age. Water Resources
Research 15(3).
Bouwer, H. , and R. C. Rice. 1976. A slug test for determining hydraulic
conductivity of unconfined aquifers with completely or partially pene-
trating wells. American Geophysical Union 12(3).
XIII-C-10
-------
would probably reveal a three-way interrelation between data locations,
nitrate levels, and the concentrations of phosphorus. Although the results in
this example are fairly obvious, correlation analysis can demonstrate inter-
relations that are sometimes surprising and unexpected.
Hydrologic phenomena typically exhibit seasonal variations, and the
sampling of surface water bodies is often planned to coincide with low flow
periods when dilution is minimal and contaminant concentrations at maximum
levels. Thus, sampling times are generally selected on a systematic, rather
than random, basis. Sampling locations for surface water can be selected
either randomly or systematically. Groundwater is far less accessible, and
available access points such as wells or springs must be used regardless of
the resulting sampling pattern. Discrete samples collected from varying
depths within the water column of a well should be acquired when possible,
since the chemical species present can vary with changes in temperature, eH,
pH, and lithologic contacts.
The determination of a statistically representative number of samples is
difficult because the groundwater chemical variance is often high but unknown.
Estimates of sample population variance can be made by studying the varia-
bility in previous data and applying confidence tests to the results. One
method of determining a valid number of samples in this way is described by
Nelson and Ward (1980). The investigator must realize that the variance of
hydrologic data is especially subject to time-variant change.
3. CONCLUSIONS
Assuming that the treated effluent from an on-site system consists only
of typical household greywater and blackwater waste, the two most important
chemical quality parameters to know are the concentrations of nitrates and
fecal coliforms. These potential contaminants must always be considered in a
monitoring plan. The proximity of lakes to on-site systems will also neces-
sitate the study of phosphorus influx rates because high levels can greatly
accelerate eutrophication processes.
Despite advances in remote sensing of hydrologic phenomena, there is
presently no substitute for on-site inspection of waste treatment systems to
evaluate performance accurately. The effective implementation of a ground-
water monitoring network requires technical expertise in the areas of environ-
mental engineering, chemistry, hydrogeology, and photography/photo-
interpretation.
The use of experienced technical personnel is essential to the accurate
prediction of the results of establishing various treatment options. The
examples cited throughout this chapter have been intended to illustrate the
normal conditions that may be expected in rural areas of U.S. EPA Region V and
to describe possible variations of those conditions that might be encountered
at specific sites. This chapter has shown that different levels of data may be
required for different applications. The application of full-scale model
results from similar nearby systems is a crucial and most accurate first
approximation for assessing the suitability of a site for a particular land
application system.
XIII-C-9
-------
Chloride measurements can be useful in the planning of on-site systems,
but only in areas isolated from roadways that are salted during winter months.
Highly soluble salts such as NaCl and KC1 are relatively nonreactive and thus
are easily transported long distances in groundwater. Chloride analyses pro-
vide no measure of the degree of treatment provided to effluent by existing or
proposed drainage fields. But chlorides are useful tracers for studying
groundwater flow patterns and for evaluating the possible extent of pollution
caused by system failures.
The use of tracers for groundwater flow studies has the basic advantage
of providing irrefutable results. It has the disadvantages of being very
costly and of suffering from the uncertainty associated with monitoring only a
very few points, any or all of which could miss detecting the main stream of
any plume of tagged water. An additional limitation is that only one injec-
tion point may be used in one groundwater shed at one time. Tests on addi-
tional points could not be performed until the system is flushed of the first
test. Tracer tests are also very slow. With groundwater flow velocities
averaging 0.5 to 0.05 feet per day, long monitoring periods (lead times) are
required for the useful completion of such tests.
For these reasons, tracer tests are used less frequently than less re-
liable modeling of various types (Chapter XIII, Section B).
i. Evaluate the Potential for Dilution
The preceeding paragraphs of this report describe water body tagging
techniques and refer to Chapter XIII, Section B on modeling of groundwater
flow. Both of these techniques are useful for evaluating the potential for
contaminant dilution. Standard techniques are used in such an evaluation.
2. SAMPLING THEORY
Some information about sampling statistics is included here to make
researchers aware of the difficulty of obtaining theoretically adequate
samples. Too often, an investigator assumes that data collected in the general
area of a proposed site will permit significant conclusions to be drawn about
the site itself. Water quality samples are especially sensitive to mistaken
conclusions of this kind, necessitating on-site sampling in almost all cases.
Determinations of the number of required samples and the time and loca-
tion of sampling are necessary. The planner generally must prepare a moni-
toring plan without the luxury of an adequate groundwater data base. In the
absence of data that could reveal spatial or time correlation in samples, the
investigator must assume that all observations are independent (unrelated).
Correlation analysis refers to the branch of statistics used to determine the
degree of interrelation between variables. For example, within a set of water
samples a group may appear with higher than average nitrate and phosphorus
levels. These samples may also cluster together, perhaps near cropland
fertilized by the detected nutrients. In this example, correlation analysis
XIII-C-8
-------
Some specialized fluids (high density, low kinematic viscosity) may violate
this rule with predicted migration rates faster than water.
The gradients and relationships between water table and piezometric
surfaces may control groundwater and contaminant flow. In general, groundwater
flows toward the center of the earth, following the path of least resistance.
In special circumstances (when the piezometric surface of a confined aquifer
is higher than the piezometric or water table surface in overlying aquifers),
groundwater flow may be opposite of that normally expected.
h. Tracing Subsurface Flow
A number of substances can be used in the evaluation of soil suitability
for on-site disposal systems. Tracers are especially valuable when used to
determine soil permeabilities in lakeshore areas selected for development.
Perhaps the best tracer of this sort is tritium, because it can comprise part
of the structure of the water molecule. Minute quantities of tritium can be
used to "tag" large volumes of water, remaining detectible in very low con-
centrations owing to its radioactivity (Stewart and Stetson, 1975). The use of
tritium as a tracer is especially attractive for groundwater flow into and out
of lakes located in low population density areas. The method involves inject-
ing a small amount of tritium into an aquifer, utilizing an auger hole or
well. The tagged water forms a plume that migrates down-gradient from the
source. It could be detected in monitoring wells drilled down-gradient of the
injection hole. An up-gradient well would be monitored for reference. The flow
direction and average flow velocity could be determined by this process.
However, because of the controversy associated with the introduction of even
minute quantities of radioactive material into the environment, this option
must be evaluated thoroughly prior to its use. Although tritium is theoreti-
cally one of the most reliable tracers of groundwater flow, other, more envi-
ronmentally safe tracers, (dyes, conservative nontoxic substances) should be
used when possible.
Genetically marked strains of E. coli have also been used successfully as
tracers to study groundwater flow patterns in soil columns. Hagedorn and McCoy
(1979) demonstrated the superiority of bacterial tracers over fluorescein dyes
in applications of this type.
Thompson and Hayes (1979) have shown that trichlorofluoromethane (CC1JF,
trade name Freon II) can be useful as a tracer and as an indicator of ground-
water age. All sources of this compound are believed to be artificially made,
more of the material existed in the environment prior to 1931. Although re-
leased to the atmosphere, this substance establishes an equilibrium solubility
in surface water. Even in ppt concentrations, Freon II in water is readily
detectable by gas chromatography.
With regard to the planning of on-site treatment systems, the presence of
Freon II in confined aquifers would indicate the occurrence of relatively
recent recharge from surface sources. Therefore, areas can be identified in
which groundwater reservoirs are especially sensitive to degradation by sur-
face contamination. The analysis of Freon II levels is best applied on a local
or county basis to evaluate the potential impacts to water supplies of
implementing new small waste flows systems.
XIII-C-7
-------
D. Acid rain
Recent research has shown that organic and inorganic sources of nitrates
in groundwater can be differentiated on the basis of stable nitrogen isotope
levels (Wolterink et al., 1979).
f. Evaluate Site Suitability Systems
Important considerations in evaluating site suitability for small waste
flows treatment systems include the following:
1. Proximity to drinking water supplies
2. Soil type and permeability (suitability)
3. Proximity to sensitive ecosystems such as lakes, bogs, and
marshes
4. Flooding potential
5. Prediction of future impacts that may result from system
failure by
a. Determination of groundwater flow direction from
hydrologic gradient data (see Chapter XIII, Section
B)
b. Determination of groundwater flow velocities from
gradient data and permeability estimates
These factors must be considered and compared for each treatment alter-
native to determine the respective contaminant loading rates and point of
introduction into the environment. This evaluation results in the delineation
of the forcing function for the evaluation that follows.
g. Vertical Mobility of Pollutants from the Surface or Shallow
Subsurface Application of Small Waste Treatment Systems
Vertical mobility of pollutants must be evaluated to predict their
effects on the groundwater system. Vertical mobility of pollutants is most
strongly controlled by the solubility, stability, and physical properties such
as density of the contaminant; by rate of recharge, permeability, and altera-
tions of the aquifers and intervening geohydrologic units, and by the gra-
dients of the water tables affected.
The solubility, stability and other physical properties of the con-
taminant may affect its rate of dispersion and its direction of migration. For
example, a contaminant with low solubility and with density greater than water
may migrate along the bottom of the aquifer. A contaminant with low solubility
and with density lower than water would float on the water table. Either could
become trapped in a local feature on the water table and defy predicted migra-
tion patterns and rates.
Rate of recharge, permeability, and ability of an aquifer or intervening
geohydrologic unit (aquitard) to attenuate contamination may affect vertical
mobility of a contaminant. Other factors that may limit the vertical movement
of groundwater and/or contaminants include groundwater discharge or removal
rates and thicknesses and continuity of aquitards. In general, contaminants
travel through aquifers at or below the average groundwater transport rates.
XIII-C-6
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Chapter II, Section C of this report describes direct and indirect
sensing techniques that may be applicable to small waste flows studies.
Expensive methods such as well drilling, aquifer testing, and geophysical
surveying are generally cost-effective only if the planning effort encompasses
a large area. Planning a new lakeshore community is an example of a project
for which these geophysical and engineering techniques would prove valuable.
Whenever possible, field data should be collected from existing sampling
locations. Wells and natural springs can be sampled to analyze prevalent
groundwater chemical species. An existing open well can also be used to deter-
mine the approximate hydraulic conductivity of penetrated formations, uti-
lizing the slug test method described by Bouwer and Rice (1976). Preliminary
information of this type creates a data base, allowing the investigator to
evaluate properly future trends discovered from continued monitoring at pro-
posed wastewater treatment sites.
The ability of soils to treat domestic effluent properly can only be
determined by on-site inspection of soil wetness, texture, and horizonation,
including the collection of samples for analyses of grain size distribution.
As described in Chapter III, Section B of this report, existing wastewater
treatment systems can function as full-scale models for the evaluation of soil
effectiveness in treating effluent.
Seasonally flown aerial photography (both color and infrared) should be
an integral part of any water quality data base. Similar photographs obtained
as part of a trend monitoring program could, during the period following
facility construction, be used to help identify the significant changes in
vegetation caused by system failures.
e. Identify Existing Nonseptic Pollutant Sources from Collected
Data
For most researchers, it is only important to identify existing chemical
constituents in groundwater without regard for their source(s). In some cases,
it may be useful to identify specifically existing nonseptic pollutant
sources. The most prevalent ones are outlined below:
A. Agricultural and domestic
1. Fertilizers (applied to field or lawn)
2. Pesticides
3. Animal wastes
4. Salt applied to roads during winter
B. Industrial sources
1. Organic solvents
2. Metal cations
3. Petrochemicals
C. Drainage from surface and underground mines
XIII-C-5
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3. Geohydrologic units
a. Transmissivity and storativity
b. Flow and boundary conditions
C. Remote sensing
1. Geophysics
2. Multi-spectral aerial photography (including infrared)
Chapter XIII, Section A describes in detail the sources of groundwater
quality data available in U.S. EPA Region V.
The primary sources of this information, which vary from state to state,
are listed below:
A. Federal government
1. U.S. Geological Survey*
2. U.S. EPA
3. U.S. Army Corps of Engineers
B. State government
1. Department of Health
2. Department of Natural Resources*
3. Geological Survey*
4. Water Survey*
5. State EPA
6. Pollution Control Agency
7. Soil Conservation Service
C. Local government
1. Department of Health
D. Other
1. Universities*
2. Scientific journals*
3. Well-drilling companies and operators
4. Private companies using groundwater
5. Personal communications*
Those sources followed by an asterisk can often provide extensive geo-
logic and geophysical data.
d. Collection of Field Data
In areas for which little published groundwater and geologic data exist,
it may be necessary to acquire additional field data to guide planning
efforts.
XIII-C-4
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After the data described above are collected and evaluated, the conserva-
tively defined groundwater basin may be refined. Careful consideration of the
time required for the system to cause contamination at any given location must
be included in the analysis of the data.
b. Describe Existing Uses of Groundwater within the Study Area
After the boundaries of the study area are determined, existing ground-
water usage should be described. This may be done by survey or evaluation of
existing records. The sensitivity of the groundwater use is the primary goal
of this phase of study. Potable water supplies are of the highest priority,
while agricultural, industrial process and cooling uses have correspondingly
lower priority for protection.
High groundwater withdrawal rates associated with public or industrial
water supplies should be identified at this stage, because they may locally
increase groundwater flow rates by increasing water table gradients. They may
locally even reverse groundwater flow directions. If their use is intermit-
tent, they may further complicate expected groundwater pollutant dispersion.
c. The Existing Data Base
Planners can avoid considerable expense of obtaining new groundwater data
if the existing data base is first acquired. This data base consists of both
published and unpublished material. When collecting this information, it is
most cost-effective to obtain it for the entire planning area at one time.
Then, first approximations (of affected areas, for example) may be enhanced by
extrapolating the known characteristics of the planning area. Outlined below
are the general classes of data that are applicable to groundwater problems in
small waste flows planning and that may be found in the existing data base:
A. Groundwater data
1. Water table elevations and variability
2. Groundwater geochemical analyses for the following:
a. pH
b. Specific conductivity
c. Acidity and alkalinity
d. Nitrates
e. Bacteria
f. Viruses
g. Phosphorus
h. Iron
i. Calcium, magnesium, and manganese
j. Aluminum
B. Geologic data
1. Soil types (thickness, composition, and variability)
2. Geologic formations
a. Lithology
b. Structure
XIII-C-3
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5. Describe any existing pollutants, their source(s), and identify poten-
tial pollutants
6. Evaluate waste disposal methods (existing and proposed)
7. Evaluate the vertical mobility of pollutants from surface or shallow
sources to the saturated zone
8. Estimate velocities of groundwater flow within underlying aquifers and
their ability to transmit pollutants
9. Estimate the potential for dilution of pollutants within the study
area or hydrologic basin (evaluate sensitivity of surface and subsur-
face waters)
This is an outline of ideal steps for the manager who is provided with
adequate finances, time, equipment, and technical skills. However, the
acquisition of original data for areas with little existing information (Step
4) is often very expensive. At a minimum, soil sampling and testing might be
performed on selected developed sites. The performance of existing systems in
soils similar to those found at the selected sites could be inferred from the
data.
a. Selection of the Monitoring Area
The extent of potential groundwater effects from the land application of
small waste flows may be closely approximated if the following basic informa-
tion is known:
• depth to the saturated zone (water table),
• permeability or grain size analysis of aquifer materials, and
• direction of groundwater flow.
In addition, if the groundwater flow rates or slope of the water table are
known, then the rate of groundwater transport of potential contaminants and
the time required for the contaminants to reach a sensitive receptor (for
example, well or surface water body) can also be modeled.
Since this information is rarely available before the data are collected,
it may be necessary to make a preliminary approximation of the potentially
affected area by examining the topography of the area surrounding the proposed
application site. In general, in humid areas such as those present in U.S.
EPA Region V, groundwater drainage basins coincide with surface water drainage
basins. Groundwater flow paths roughly approximate the direction of maximum
land surface slope. Thus, the affected area would approximately duplicate the
surface watershed of the application site, to the zone where the surface
watershed is intercepted by the first perennial surface water body (for
example, a stream, river, or lake).
Notable exceptions to this rule include sites near surface drainage
divides, sites with very deep (greater than 50 feet) water tables, or sites
located close to contacts of geohydrologic units or points of high groundwater
withdrawals. The first approximation of the groundwater basin that may be
affected by these sites should be chosen more conservatively than subsequent
approximations.
XIII-C-2
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C. GROUNDWATER RESOURCES DATA NEEDED FOR FACILITIES PLANNING IN
RURAL LAKE AREAS
1. INTRODUCTION
This section identifies the groundwater quality information required for
planning and design of small waste flows treatment systems. The benefits and
limitations of various data collection techniques are identified, analyzed,
and summarized to assist facilities planners in deciding how much background
data to collect and how to design an appropriate monitoring system. Chapter
VIII, Section C develops guidelines for facilities planners who will design
monitoring plans for treatment systems that are already constructed and under
operation.
The level of groundwater quality monitoring required is primarily depen-
dent on the utilization of the groundwater resource and the proximity of the
aquifer to the source of contamination. For example, groundwater used mainly
for agricultural purposes does not require the close monitoring needed to
protect drinking water supplies.
Confined and semi-confined aquifers have at least one zone of low permea-
bility between themselves and local surface sources of contamination. Typical
semi-confined sandstone aquifers are primarily recharged laterally from loca-
tions where the unit is exposed or in hydraulic continuity with the surface.
As the water travels over great distances from the recharge area to the point
of discharge or withdrawal, dilution or attenuation of low-levels of con-
tamination may occur.
Wells developed in fractured crystalline rocks are recharged almost
entirely from local surface sources. They are thus more readily subject to
contamination from these local sources.
The following outline (adapted from Todd et al., 1976) lists steps that
may be necessary to develop a groundwater monitoring strategy:
1. Select the monitoring area
2. Describe existing uses of groundwater within the study area
3. Obtain existing data on:
a. Groundwater quality and water table depths
b. Aquifer characteristics (flow and geology)
c. Soil properties
d. Climate (precipitation and temperatures)
4. Where data are lacking, obtain sufficient field information to ade-
quately evaluate the site, by means of:
a. Sampling and chemical analyses of well waters and springs
b. Well drilling to sample geology, establish observation wells, and
test aquifers
c. Auger sampling of soil profiles
XIII-C-1
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REFERENCES
Appel, C.A., and J.D. Bredehoeft. 1976. Status of groundwater modeling in the
U.S. Geological Survey. Circular 737. U.S. Geological Survey, Reston VA.
Bachmat, Y. , B. Andrews, D. Holtz, and S. Sebastian. 1978. Utilization of
numerical groundwater models for water resource management. EPA-600/
8-78-012. U.S. Environmental Protection Agency.
Childs, K. E., S. B. Upchurch, and B. Ellis. 1974. Sampling of variable waste-
migration patterns in ground water. Ground Water, November-December.
Davis, S. N. , and R. J. M. DeWiest. 1966. Hydrogeology. John Wiley and Sons,
Inc., New York NY.
Fetter, C.W., Jr., W. E. Sloey, and F. L. Spangler. 1977. Potential replace-
ment of septic tank drain fields by artificial marsh wastewater treatment
systems. Proceedings of the Third National Ground Water Quality
Symposium. EPA-600/9-770H. U.S. Environmental Protection Agency.
Grim, R. E. 1968. Clay mineralogy. McGraw-Hill, Inc., New York NY.
Konikow, L. F. , and J. D. Bredehoeft. 1978. Computer model of two-dimensional
solute transport and dispersion in ground water. Techniques of water-
resources investigations of the U. S. Geological Survey, Book 7, Chapter
C2. Washington DC..
Moore, J. E. 1979. Contributions of groundwater modeling to planning. J. of
Hydrology 5:(43).
Mudroch, A., and J. A. Capobianco. 1979. Effects of treated effluent on a
natural marsh. Journal WPCF, 51(9).
Prickett, T. A. 1979. Ground-water computer models: State of the art. Ground
Water, 17(2).
Rea, R. A., and S. B. Upchurch. 1980. Influence of regolith properties on
migration of septic tank effluent. Ground Water 18(2).
Rushton, K. R. , and S. C. Redshaw. 1979. Seepage and groundwater flow. John
Wiley and Sons, New York NY.
Seckel, C. W. 1978. Feasibility study for development of a transient three-
dimensional groundwater flow model utilizing the finite element method.
University of Maryland, College Park MD.
Walton, W. C. 1970. Groundwater resource evaluation. McGraw-Hill, Inc., New
York NY.
XIII-B-12
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TABLE XIII-B-2. APPLICABILITY OF GROUNDWATER MODELING TO DECISION-LEVELS IN
SMALL WASTEWATER FLOW MANAGEMENT
Model Types
I. Physical
Permeameter
Individual
(systems)
X
Local
(developments
and towns)
X
Area and
Regional
(cities and
counties)
Generally not
Applicable
Sand tank (full X X
scale)
Artificial marsh X X
Viscous flow X
II. Mathematical
A. Analog
Discrete circuit X X
Continuous circuit X
B. Digital
Flow X X
Quality X
III. Analytical XXX
With regard to the planning and design of on-site treatment systems,
empirical conclusions based on the careful monitoring of selected septic
systems are far more valuable than the results of predictive groundwater
quality monitoring. When planning the design of a treatment system for a new
site, the first priority for a planner should be to examine nearby existing
septic systems to evaluate their operating performance. If any system failures
are noted, the reasons for failure should be carefully analyzed and used as
guidance on the new site. In the absence of other treatment systems, a
thorough surface and subsurface sampling program should be implemented. The
initial expenses incurred in carefully documenting the geologic and hydrologic
variables in a new area would be recouped when additional new sites are added.
In this way, an expanding data base can be established that will allow plan-
ners to estimate more reliably the ability of a soil to treat septic effluent
effectively.
XIII-B-11
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• evaluation of existing septic system performance levels, and
• application of remote sensing.
3. SUMMARY AND CONCLUSIONS
Modeling can be a practical tool in the study of groundwater flow pro-
blems. Groundwater quality models developed during the 1970's represent the
state-of-the-art in digital flow analysis. But the use of these overly sophis-
ticated models can produce misleading results and is not cost-effective.
Solute transport in surface aquifers occurs as time-variant flow under
unconfined conditions. The boundary conditions and transport phenomena are so
complicated that computer analyses are required for credible quality modeling.
Unfortunately, quality models are not yet sophisticated enough to effectively
resolve patterns of multichemical transport and interaction. Thus, a paradox
exists in the digital evaluation of septic seepage flow. Although digital
methods are essential, they currently are theoretically inadequate and too
expensive for application to individual septic systems. Therefore, groundwater
quality models are not of practical value to planners in the evaluation of
septic seepage.
Applications of digital flow modeling are currently limited to the study
of annual water table fluctuation and patterns of local and regional ground-
water flow. Conclusions derived from large-scale studies of this type should
not be used to make assessments of specific site suitability. Only on-site
inspection and data collection can provide the necessary information.
The utility of groundwater modeling varies at different levels of manage-
ment decision-making. While only physical and analytical models can reasonably
be applied to individual septic systems, a wider range of techniques is prac-
tical on local, area, and regional decision levels. Table XIII-B-2 summarizes
the decision-level applicability of models discussed in this section.
In approaching a groundwater problem, the investigator should first try
to apply the simpler analytical techniques to determine whether mathematical
models will be required or useful. In small waste flows management, the two
most important variables are groundwater flow direction and velocity. After
obtaining this information, the planner can identify those areas that may be
affected by leachate from septic systems or that may be land application
sites. Reasonable, low-cost estimates of flow direction and velocity can be
made by using water table elevation data and estimates of aquifer porosity and
permeability. Other analytical models are the traditional methods used to
analyze aquifer test data to determine formation values of storativity and
transmissivity. These values are essential data for the subsequent application
of digital modeling.
Mathematical models are the only methods capable of handling the complex
boundary conditions inherent to seepage flow problems. Although electrical
analog techniques generally have been replaced by digital methods, the wide-
spread use of micro-processors should eventually cause a resurgence of
interest in the application of electrical analog modeling (Prickett, 1979).
XIII-B-10
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c. Analytical Models
Analytical models are equations which, subject to simplifying assump-
tions, can be directly solved to obtain information about groundwater flow.
The Laplace transformation is a powerful method for solving the linear dif-
ferential equations that describe subsurface flow phenomena. Analytical
methods can only be used when the geometry and boundaries of the flow medium
are relatively simple. These criteria are compatible with the pumping tests
used to derive the formation constants of transmissivity and storativity. Many
assumptions must be made before this class of problem becomes amenable to
analytical solution. For the case of pumping an unconfined aquifer, the fol-
lowing assumptions were given for an example analyzed by Walton (1970):
• aquifer is homogeneous, isotropic, infinite in areal extent, and has
uniform thickness,
• test wells fully penetrate the aquifer,
• water is unconfined,
• drawdown is very small compared to the original saturated thickness,
and
• pumping occurs at a fixed rate, and flow in the aquifer is unsteady.
It is apparent that seepage flow problems are often incompatible with
these ideal assumptions, necessitating the use of numerical approximations of
the governing differential equations. The investigator needs significant
experience dealing with groundwater flow problems to correctly determine
whether analytical methods are adequate to solve a specific problem.
Analytical techniques provide the essential aquifer parameters required for
the operation of more sophisticated digital flow and solute-transport models.
For most facilities planning efforts, these methods are useful for determining
aquifer characteristics in areas for which little information is available.
This kind of information is important when the possibility of aquifer contami-
nation from surface sources exists, or has been observed in existing wells.
d. Empirical Methods
In applying empirical methods, conclusions are based only on observations
without regard for existing theory. Because of the need for extensive data
collection to support digital or analog modeling, and because of the expense
and expertise required for the actual theoretical modeling, the most straight-
forward method to be used in the planning and design of soil-dependent waste-
water systems may often be a well-designed program of sampling existing
systems. Through time, a program of this type can provide invaluable infor-
mation about the wastewater treatment effectiveness of specific septic systems
and soil types. Another section of this report describes a plan of data col-
lection that can be used to establish a broad data base for use in site
evaluation and trend monitoring. The basic elements of this plan include:
• acquisition of existing data,
• sampling and analysis of groundwater,
• determination of water table levels,
• collection of geological data,
XIII-B-9
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TABLE XIII-B-1. DATA REQUIREMENTS TO BE CONSIDERED FOR A PREDICTIVE MODEL
(after Moore,1979)
I. Physical Framework
A. Groundwater Flow
1. Hydrogeological map showing areal extent, boundaries, and boundary
conditions of all aquifers
2. Topographic map showing surface water bodies
3. Water-table, bedrock-configuration, and saturated-thickness maps
4. Transmissivity map showing aquifer and boundaries
5. Transmissivity and specific storage map of confining bed
6. Map showing variation in storage coefficient of aquifer
7. Relation of saturated thickness to transmissivity
8. Relation of stream and aquifer (hydraulic connection)
B. Solute Transport (in addition to above)
9. Estimates of the parameters that comprise hydrodynamic dispersion
10. Effective porosity distribution
11. Background information on natural concentration distribution
(water quality) in aquifer
12. Estimates of fluid density variations and relationship of density
to concentration
13. Hydraulic head distributions (used to determine groundwater
velocities)
14. Boundary conditions for concentrations
II. Stresses on System
A. Groundwater Flow
1. Type and extent of recharge areas (irrigated areas, recharge
basins, recharge wells, etc.)
2. Surface water diversions
3. Groundwater pumpage (distributed in time and space)
4. Stream flow (distributed in time and space)
5. Precipitation
B. Solute Transport (in addition to above)
6. Areal and temporal distribution of water quality in aquifer
7. Stream flow quality (distribution in time and space)
8. Sources and strengths of pollution
III. Other Factors
A. Groundwater Flow and Dispersion
1. Economic information about water supply
2. Legal and administrative rules
3. Environmental factors
4. Planned changes in water and land use
XIII-B-8
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equation. The transport equation computes, for any point, the changes in
concentration through time caused by the processes of convective transport,
hydrodynamic dispersion, and dilution (Konikow and Bredehoeft, 1978). Models
of this type, which consider transport by flow only, are called conservative
mass-transport models. In addition to flow transport mechanisms, non-conserva-
tive mass-transport models also consider physical and chemical interactions
between the solute and flow medium. For example, models exist that include the
processes of adsorption and the biochemical transformation of nitrogen com-
pounds (Bachmat et al., 1978).
Groundwater quality modeling provides planners with a sophisticated tool
in the study of solute transport problems. But this kind of modeling cannot
readily be done without extensive technical expertise, the use of digital
computers, and the availability of a broad data base for the hydrological
regime. Table XIII-B-1 lists the data requirements for predictive digital
groundwater modeling. Relatively simple and inexpensive field methods allow
for determining parameters for flow models, but no comparable methods are
available for mass-transport models.
Soil variability is a serious obstacle in the study of groundwater
quality problems. This variability tends to be site-specific and generally
unpredictable on a regional basis. The most important variables in the soil/
regolith column are soil composition and structure, plant growth, and phreatic
fluctuation. The physical and chemical evolution of a soil profile is uniquely
controlled by climate and the nature and source of its parent materials.
Climate governs weathering rates, changes in the phreatic zone, and the growth
and variety of vegetation. Thus, it is difficult to fully account for the
complex chemical transformation undergone by septic leachate as it passes from
the unsaturated zone into and through the saturated zone.
The processes affecting these chemical changes are soil absorption,
adsorption, cation exchange, oxidation, and the activities of plants and
organisms. Numerical methods are capable of analyzing individual processes
like cation exchange, but are not yet sophisticated enough to effectively
resolve multichemical transformation and interactions.
In particular, multichemical waste migration does not readily lend itself
to numerical analysis. There is good evidence to indicate that chemicals
commonly found in septic leachate can migrate at different rates and along
independent directional axes (Childs et al., 1974). Point source leachate
cannot be assumed to migrate as a single plume, and "index" chemicals like
chlorides do not provide safe indicators of solute transport patterns. It is
apparent that the most sophisticated mass-transport models provide only first-
order estimates of solute movements. As shown in Table XIII-B-1, modeling of
mass-transport phenomena requires a much broader data base than that required
for the predictive modeling of flow systems, further increasing the cost of
the inherently expensive digital approach. Also, simplifying assumptions are
required in addition to those required for flow modeling. Considering all of
these factors, mass-transport models are overly sophisticated for the small
waste flow problem. The problem of solute-transport will continue to be a
topic of intense research.
XIII-B-7
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These techniques are the most accurate means available for studying flow
systems on both a local and a regional basis, where they become more cost-
effective. Flow modeling is commonly used to study seasonal water table
fluctuations, especially as they relate to precipitation events and the
associated discharge and flood potential of surface waters.
The Laplace equation is the foundation of all digital groundwater flow
problems. This differential equation takes many forms, dependent on the
aquifer characteristics, type of flow, and boundary conditions. Flow seepage
is a very complicated mathematical problem because of the presence of an
unconfined boundary. The position and geometry of this boundary are time-
dependent variables that change in response to evapotranspiration and surface
and subsurface recharge. Digital groundwater models are based on a variety of
techniques that are alternative algebraic methods of solving the simultaneous
equations that represent the flow process. Numerical models of the finite-
difference and finite-element type are common today.
The finite-difference method (FDM) is simpler, and the resulting equa-
tions can be solved with either analog or digital computers. In digital solu-
tions, involved matrix operations are not required for this method. The
geometry of the field is maintained in the FDM solution, and boundary con-
ditions for the model can readily be changed.
In the finite-element method (FEM) the field is not restricted to a grid
network of uniform mesh. Elements of varying size can be used. The method can
more easily handle flow problems with highly irregular and complex geometries,
and boundary conditions are more easily resolved than with FDM. Anisotropy of
aquifer properties can be included in the solution. Disadvantages of the FEM
are long computational times and large computer storage requirements.
The basic idea of the finite-difference method (FDM) is to represent the
flow system by a two-dimensional gridded network. Derivatives at the inter-
section points are replaced by ratios of the changes in the flow variables
over small but finite intervals. This approximation generates a set of simpler
algebraic equations, which are more easily solved. The number of equations is
directly proportional to the number of intersection points. Solution of the
equations provides the values of hydraulic head at each intersection point.
Three-dimensional problems can be handled by the use of arrays of parallel
grids to represent the flow media dimensionally.
A more sophisticated technique is the finite-element method (FEM). An
excellent description of the FEM is given by Seckel (1978). The flow domain is
divided into a finite number of sections, which are connected at common nodal
points. The sections collectively represent the shape of the actual flow
medium. The value of the continuous quantity at each of the nodal points
represents the hydraulic head variable. The derived finite-element equations
are then independently applied to each section, and the results are assembled
into the total flow domain. Solution of the set of algebraic equations then
determines the values of hydraulic head at each node.
Numerical models that study the groundwater transport of contaminants are
called mass-transport models. Most of these techniques have been created since
1973. In actual operation, the researcher first studies the pertinent flow
system to thoroughly understand its variables. Then the solute-transport
differential equation is coupled with a form of Laplace's groundwater flow
XIII-B-6
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include heavy organic oils, silicone oils, and liquid plastics. Temperature
control is essential since the model fluid viscosity may vary significantly
with temperature. Both steady and non-steady effects can be included by
changing the model's temperature. Flow lines can be studied by the injection
of colored dyes, and groundwater potentials can be measured with piezometers.
Viscous-flow models have the major disadvantages of complicated construction
and operation procedures (Rushton and Redshaw, 1979). These models can be used
to study and demonstrate groundwater flow in aquifers, but they have little
practical value in the analysis of quality problems.
b. Mathematical Models
Analog Models. In the past, electrical analog modeling has been used
primarily as an instructional technique in engineering and hydrology. Models
consisting either of discrete circuits or continuous conduction media have
been devised. Electrical analogs cannot be used to study groundwater quality
problems directly. The physical laws governing electrical flow are only
analogous to the hydraulic flow equations, and not to solute transport
phenomena. Accordingly, the principal value of these models is in the analysis
and demonstration of groundwater flow systems.
Resistors and capacitors in a mesh network provide, by analogy, the
solutions in electrical terms to the representative set of finite-difference
flow equations. The electrical network may be constructed in two or three
dimensions, and circuit connectors can be designed in a way that facilitates
the disassembly and reconstruction of the network. This kind of discrete
network, compared to a continuous conducting medium, has the advantage of not
requiring a constant mesh size throughout the model. The number of circuit
components can thus be reduced in model regions that are distant from speci-
fied boundaries (Rushton and Redshaw, 1979).
Other electrical analog models, such as the conductive paper method and
the electrolytic tank, employ continuous conduction media. These models are
operationally less flexible than the resistance-capacitance networks. For
example, in the conducting paper model, the flow medium is represented by a
scaled model cut from paper with a conducting layer. Complete reconstruction
of the model is often necessary to implement geometric changes in the flow
regime. Also, non-steady flow characteristics and variations in aquifer
hydraulic properties cannot conveniently be represented in this way. Thus,
continuous conduction models cannot readily be applied to non-steady, uncon-
fined flow.
Digital (Mathematical) Models. In the study of groundwater flow prob-
lems, numerical models have substantially replaced the analog techniques. This
is a direct result of the availability, utility, and convenience of computer
facilities. Digital computers are powerful tools for the solution of complex
hydrology problems, and software packages for groundwater models are now
accessible to potential users. Flow modeling techniques are available that can
be applied to many combinations of surface and subsurface data variables. And
there are numerous models which could potentially be applied to flow problems
encountered in the planning and design of on-site wastewater treatment
systems.
XIII-B-5
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of soil permeability. But there are two important deficiencies, and therefore
disadvantages, to the widespread use of this method. First, the sampling
process usually disturbs the original stratification of unconsolidated
samples. Thus, the actual soil layers will not be represented in the flow
analysis. Secondly, permeameters test discrete samples that may not be
statistically representative of the medium underlying the seepage field.
Sand Tanks. Sand tank models are scaled-down versions of actual flow
regimes. Groundwater flow patterns can also be studied by observing the
migration of chemical dyes through sediment-filled tanks. Flow media often
used in sand tanks include sand, glass beads, and actual soil sections. It is
difficult to represent media porosities and permeabilities accurately in scale
models, and, as a result, capillary action in the unsaturated part of the
model often has an exaggerated effect. Time-variant effects are also poorly
represented by these models. The principal value of sand tank models is in the
realm of research, studying the complex problems of molecular diffusion,
dispersion, and ion exchange. Small sand tank models may be of use to planners
in the demonstration of local flow patterns, but their operation yields
strictly qualitative results.
Artificial Marshes. Artificial marshes are essentially flooded and
vegetated sand tank models. They have recently become a subject of experi-
mentation as alternative means of wastewater treatment. Artificial marshes
can be considered models for the biological treatment of wastewater. The marsh
consists of a gravel-filled tank or basin in which the bottom and sides are
sealed. Prior to the addition of effluent, growths of emergent aquatic vegeta-
tion are established for several growing seasons. Effluent is then filtered
through the tank to provide a nutrient supply for absorption by the plant
rootlets. Inflow and outflow pipes must be high enough to prevent the marsh
from drying out. Artificial marshes may be used only during the growing
season; at other times, alternative disposal methods such as holding tanks
would be necessary.
Existing System Performance. Existing septic tank systems can function
as full-scale sand tank models in the hydrochemical study of leachate treat-
ment and migration (Childs et al., 1974; Rea and Upchurch, 1980). Only in
this manner can the actual effects of nutrient load and soil variability be
adequately understood. For example, the most important considerations in
evaluating the suitability of soils for wastewater treatment is the per-
formance of similar nearby systems. On-site inspections are essential for
proper evaluation, and when correlated with site characteristics, usage data,
and design information, provide a data base for the future trend monitoring of
existing and newly constructed systems. Sites with confirmed system failures
should be classified according to probable cause of failure, such as system
overloading due to improper maintenance, high water tables, and improper soil
conditions. Data of this type constitute a descriptive model for the per-
formance of existing on-site treatment systems.
Viscous-Flow Models. Viscous-flow models are three-dimensional construc-
tions of flow media in which transmissive zones are represented by parallel
plates made of metal or plastic. The movement of viscous liquid between the
plates is directly analogous to the laminar flow of groundwater. In fact, the
equations for viscous flow between parallel plates are identical to the equa-
tions for groundwater flow. Liquids used for modeling groundwater to scale
XIII-B-4
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permeability varies with the choice of direction from a specified point. A
flow medium is said to be homogeneous if its properties, isotropic or
anisotropic conditions, are constant throughout. A fluid is homogeneous when
it consists of a single phase. Heterogeneous flow occurs if either the medium
or the fluid is heterogeneous. Theoretically, a medium can be both isotropic
and heterogeneous, as for example when permeability is unaffected by direction
but varies at different points (Davis and DeWiest, 1966).
Groundwater models often assume that flow occurs under steady-state
conditions. This assumption is generally accurate for analyzing flow in con-
fined aquifers, but is not generally applicable to septic seepage, which
occurs under unconfined condition. By definition, steady-state flow does not
vary, through time and only occurs when the fluid variables (velocity, pres-
sure, density, temperature, and viscosity) are functions of the spatial
coordinates within the medium. Time-variant flow occurs when any of the above-
listed variables are also functions of time. Septic seepage is always a time-
variant phenomenon in that it is influenced by diurnal and seasonal changes in
climate and by household discharge rates.
d. Boundary Assumptions
The functioning of a septic system is strongly influenced by the nature
of local hydrogeological boundaries. These boundaries must be identified since
they act either as recharge areas or zones that retard or prevent groundwater
flow. Streams, lakes, and coastal areas are generally recharge boundaries.
Shale beds, clay layers, and massive igneous and metamorphic formations often
function as barrier boundaries. Reservoir breastworks and flood levees are
examples of man-made barrier boundaries. Confined flow occurs when all boun-
daries are fixed in space and do not change with time. Unconfined flow occurs
when at least one boundary is a free surface exposed to the atmosphere. Small
waste flows management is a problem in unconfined seepage flow. Flow seepage
is very complicated mathematically because of the presence of an unconfined
phreatic boundary (water table). The position and geometry of this boundary
are time-dependent variables that change in response to evapotranspiration
surface and subsurface recharge. The proper operation of a septic system
requires that its outflow point and drainage field remain in the unsaturated
zone above the water table.
2. DESCRIPTIONS OF GROUNDWATER FLOW MODELS
a. Physical Reproductions
Permeameters. Physical reproductions of flow systems have been used
scientifically since the early 1800's. In 1856 a French engineer named Henri
Darcy was the first person to state the mathematical law that governs ground-
water flow. Darcy invented the permeameter, a device used to measure the
hydraulic conductivity of earth materials. The equipment consists of a sample-
filled pipe through which water is forced to flow. Pressure variations within
the sediment sample, in combination with the discharge rate, are used to
quantify the ability of the sample to transmit water. Permeameters are used
today to study the permeability and chemical adsorption characteristics of
soils, sediments, and rocks. The suitability of a soil as a medium for septic
seepage application is often evaluated by the use of a permeameter. This
method is inexpensive and generally provides a reasonable first-order estimate
XIII-B-3
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it is necessary to become familiar with the principles of groundwater flow.
The following paragraphs describe the development of the present groundwater
flow theory and provide insight into the analytical advantages water quality
models may provide.
b. Groundwater Flow
The groundwater of most interest in the management of small waste flows
is the shallowest water, which flows through open spaces between shallow earth
materials. This shallow groundwater flow usually occurs approximately
parallel to maximum land surface gradients. It is not like an underground
river, rather it is laterally extensive like the flow of water through a
sponge.
The ability of a soil, regolith, or aquifer to hold and transmit water is
dependent on the properties of porosity and permeability. The porosity of a
medium depends on the shape, distribution, sorting, and cementation of indi-
vidual particles. Porosity is a fraction defined as the void volume divided by
the given volume of porous medium. For a medium to be transmissive, voids or
fractures must be interconnected. The coefficient of permeability for a medium
is defined as the hydraulic conductivity (K).
This important variable has traditionally been estimated by the use of a
permeameter, in which water is forced to flow through a sample and the change
in hydraulic head between the inflow and outflow points is measured. K has the
dimensions of velocity and is dependent on properties of both the fluid and
the medium. The Darcy velocity (V) is defined as
dh Q
V = -K = KS =
dl A
in which K = hydraulic conductivity (L/T)
S = —j-r- = hydraulic gradient (dimensionless)
Q = flow rate (L3/T)
2
A = cross-sectional area of flow (L )
The Darcy velocity (V) thus computed is an apparent velocity. V divided
by the porosity fraction is the average velocity of the fluid as it moves
around and between the particles of the flow medium.
c. Simplifying Assumptions
The application of flow modeling requires that simplifying assumptions be
made concerning the uniformity and directional properties of a flow system. A
medium is said to be homogeneous if its structure and composition are uniform
or vary uniformly. A medium composed of random elements is heterogeneous.
Characteristics of a medium can also be defined in directional terms. For
example, in an isotropic flow medium, the permeability is the same in all
directions emanating from any point. Conversely, in an anisotropic medium, the
XIII-B-2
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B. REVIEW OF GROUNDWATER MODELING TECHNIQUES
1. INTRODUCTION
This section reviews currently available techniques of groundwater
quality modeling. The review should be useful in determining which models are
applicable to planning and design of on-site sewage disposal technologies that
include land application of wastes. The information presented will assist
planners in selecting models that represent good balances between performance
and cost.
In recent years, groundwater models of all types have become increasingly
available. Scientific journals, textbooks, and the International Clearinghouse
for Groundwater Models are all important sources of this information. Some
useful references to groundwater models are listed in the bibliography of this
section.
The term "model" is used to denote an abstraction of reality in any form
or scale other than that of nature. Models range in complexity over a broad
spectrum from simple verbal models like "water flows downhill" to highly
complex numerical models that require digital computers for their operation.
Most groundwater models are used to evaluate the velocity, volume, and
direction of subsurface flow. The principal types of flow models include
physical representations, analogs, digital methods, and analytical equations.
Groundwater quality models are specialized digital flow models that incor-
porate solute-transport calculations. Since it is impossible to apply digital
quality modeling credibly unless the underlying flow system is thoroughly
understood, groundwater flow models are also examined here.
It is also possible to model groundwater flow and quality by statisti-
cally describing trends in the areal distribution of subsurface data. Des-
criptive models of this type are applicable only to the area for which there
are data, and can be refined through time as additional subsurface information
is acquired.
An analysis of seepage flow problems is presented, followed by descrip-
tions of the existing models. Finally, recommendations are made concerning the
limitations and benefits of various models with regard to small waste flows
management.
a. Description of the Seepage Flow Problem
An ubiquitous problem in small waste flows management is the environ-
mental impact of septic seepage. Under optimum site and operation conditions,
the impact is minimal. But the long-term operational effectiveness of indi-
vidual and cluster septic systems and the specific factors that cause
unacceptable impacts (and possibly health hazards) have seldom been rigorously
evaluated. Potential problems caused by surburface failures of septic tanks
include the degradation of water quality in shallow aquifers and the accelera-
tion of eutrophication processes in adjacent lakes.
To provide planners and health officials with an evaluation of the aid
that groundwater quality models can provide to the decision-making process,
XIII-B-1
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Direct contact should be made with agencies for which data were obtained
from the computer data bases. Often, other miscellaneous information about the
site or historic data may not have been entered into the system, and these
items may reside in paper copy files at the agency.
The organizations that register their data collection activities with
NAWDEX do not all store their data in WATSTORE or STORE!. These agencies
would have to be contacted to obtain the data.
During this data acquisition process, it is likely that other potential
sources of data and relevant information will be identified and will need to
be contacted. If after all leads have been exhausted and no data exist, well
water sampling in the study area would be the only means to acquire the
necessary background data.
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TABLE XIII-A-3. LIST OF U.S. EPA AND USGS OFFICES
THAT CAN PROVIDE COMPUTERIZED DATA
STORET*
Region V, STORET Representative
U.S. EPA
230 S. Dearborn Street
Chicago, IL 60604
312/353-2061
STORET User Assistance Group
U.S. EPA
401 M Street, SW
Washington, DC 20460
201/426-7792
NAWDEX**
National Water Data Exchange
USGS
421 National Center
Reston, VA 22092
703/860-6031
NAWDEX Assistance Centers, USGS, Water Resources Division
605 N. Neil Street
Champaign, IL 61820
217/398-5353
6520 Mercantile Way
Lansing, MI 48910
517/372-1910
975 W. Third Avenue
Columbus, OH 43212
614/469-5553
1819 N. Meridian Street
Indianapolis, IN 46202
317/269-7118
1033 Post Office Bldg.
St. Paul, MN 55101
612/725-7841
1815 University Avenue
Madison, WI 53706
608/263-2189
* WATSTORE data also are stored in the STORET system.
** Data stored in the U.S. EPA STORET system and in the USGS WATSTORE system
may be obtained through NAWDEX.
XIII-A-14
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bottles for water samples. The homeowner is notified of the results. In the
other states, water samples are collected by local health department sani-
tarians. Most local health departments send the samples to state labora-
tories.
Although there appears to be a significant amount of potentially useful
data collected, data storage methods may frustrate efforts to retrieve that
data. In the worst case, the central state laboratory is the only place where
all the water analysis records are kept, and they are filed or recorded in the
order in which the analysis was completed. It would be extremely difficult
and time-consuming to obtain this type of data, as is the case in Illinois and
Wisconsin.
Results of water sample analysis for new wells and retested wells are
maintained by local or county health departments in Michigan and Ohio, and for
retested wells in Minnesota. The ease with which the data are retrievable
will depend on how the records are filed; some will be organized by location
whereas others will be arranted by well owner's name or by date of water
analysis. Regardless of filing method, it should be possible to obtain what-
ever relevant data are available because the number of records would be
considerably less at the county level than at the state level. Well owner's
permission is not required to access water quality data for private wells from
state or local county health departments.
11. OTHER SOURCES
Only Federal and state agencies were contacted, but other sources exist.
Local agencies, including county health county heatlh departments, may be able
to provide data or information. State universities potentially are a valuable
source .of information. Many of the university engineering departments are
involved in groundwater studies, looking at environmental problems, and using
the most modern techniques for their investigations. Reports or theses
published by university members offer the advantage of scientific interpre-
tation along with data presentation. Local industries using groundwater may
have quality data. Finally, consulting firms may have gathered data in the
area during projects.
12. DATA ACQUISITION
Initial use of computerized data base systems may facilitate the data
source identification and data acquisition process. The NAWDEX data bases
offer a good starting point; these can be accessed concurrently for surface
water, water quality, and groundwater. Once the study area boundaries have
been defined, the data bases can be searched by state and county codes or by
geographic locations identified by latitude-longitude vertices. The Master
Water Data Index (MWDI) can be accessed to obtain a list of data collection
sites (for example, groundwater quality, lake water quality, stream flow,
water level, etc.) in the specified area, and the Water Data Sources Directory
(WDSD) can be used to obtain the addresses of offices from which the data may
be acquired.
Data stored in the U.S. EPA STORET system or the USGS WATSTORE system may
be obtained through NAWDEX Assistance Centers or from U.S. EPA offices. All
data stored in the WATSTORE data files are contained also in STORET. A list
of NAWDEX Assistance Centers and U.S. EPA central offices is provided in Table
XIII-A-3.
XIII-A-13