6135
oEPA
United States

Environmental Protection

Agency
Region V

230 South Dearborn

Chicago, Illinois 60604
June 1979
               Water Division
Environmental      Draft
Impact Statement

Alternative Waste
Treatment Systems
for Rural Lake Projects

Case Study Number 1
Crystal Lake Area
Sewage Disposal Authority
Benzie County, Michigan

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                 DRAFT ENVIRONMENTAL IMPACT STATEMENT
                  CRYSTAL LAKE FACILITY PLANNING AREA
                        CRYSTAL LAKE,  MICHIGAN
                              Prepared by
             US Environmental Protection Agency,  Region V
Comments concerning this  document  are invited and should be received by
_ AUG 20
For further information, contact
Mr. Alfred Krause, Project Monitor
230 South Dearborn Street
Chicago, Illinois  60609
312/353-2157
                               Abstract

     A  201  Facility  Plan was  prepared  for  the Crystal  Lake  Facility
Planning  Area.   The  Facility  Plan concluded  that extensive  sewering
would be  required  to  correct malfunctioning on-site wastewater disposal
systems and to protect water quality.

     Concern about the high proposed costs of the Facility Plan Proposed
Action prompted  re-examination  of the Study Area and led to preparation
of  this  EIS.   This EIS  concludes  that existing  wastewater  treatment
plants  in the  area should  be  replaced, but  complete abandonment  of
on-site  systems  is unjustified.   An  alternative  to the  Facility  Plan
Proposed Action  has therefore  been presented and is recommended by this
Agency.

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                          VOLUME  I

              DRAFT ENVIRONMENTAL IMPACT  STATEMENT

ALTERNATIVE WASTEWATER TREATMENT  SYSTEMS  FOR RURAL LAKE PROJECTS

 CASE STUDY No. 1:  CRYSTAL LAKE  AREA  SEWAGE DISPOSAL AUTHORITY

                   BENZIE COUNTY, MICHIGAN



                       Prepared by  the




          UNITED STATES ENVIRONMENTAL  PROTECTION  AGENCY

                 REGION V, CHICAGO,  ILLINOIS
                            AND
                     WAPORA, INCORPORATED
                       WASHINGTON, D.C.
                                    Approved by:
                                       fn McGuire
                                       ional Administrator
                                       S. Environmental  Protection Agency
                                       e, 1979
                                              U.S. Environmental Protection  i«ency
                                              Region 5, Library (5PL-16)
                                              230 S. Dearborn Street,  Soon 1670
                                              Chicago, IL   60604

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                            LIST OF PREPARERS

     This Environmental  Impact Statement  was  prepared by  WAPORA,  Inc.
under the guidance  of  Alfred Krause, EPA Region V Project Officer.   Key
personnel for WAPORA included:

     WAPORA, Inc.
     6900 Wisconsin Avenue
     Chevy Chase, MD  20015
          Michael Goldman, P.E.    -  Project Manager
          Winston Lung, P.E.       -  Water Quality Modeler
          Gerald Peters            -  Project Director
          Dennis Sebian            -  Project Engineer

     In addition, several subcontractors and others assisted in prepara-
tion of  this  document.   These, along with their areas of expertise, are
listed below:

Aerial Survey
     Environmental Photographic Interpretation Center
     Vint Hill Farms Station
     Warrenton, VA
          Barry Evans

Septic Leachate Analysis
     K-V Associates
     Falmouth, MA
          William Kerfoot

Engineering
     Arthur Beard Engineers
     6900 Wisconsin Avenue
     Chevy Chase, MD  20015
          David Wohlscheid, P.E.

Financial
     Kearney Associates
     699 Prince Street
     Alexandra, VA  22313
          Charles Saunders

Soils Interpretation
     Soil Conservation Service
     Traverse City, MI
          Richard Larson

Sanitary Survey
     University of Michigan Biological Station
     Pellston, MI
          Mark Paddock

Water Quality Study
     Crystal Lake Property Owners Association
     Crystal Lake, MI
          Fred Tanis

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                                SUMMARY
CONCLUSIONS

     Most  on-site  systems  around  Crystal  Lake and  in  the Village  of
Benzonia are operating satisfactorily.   Approximately 90  effluent plumes
entering Crystal Lake  and  a few surface malfunctions have  been  identi-
fied.  Periodic  backup of  sewage  in the systems also occurs.   On-site
systems  do  not appear  to  be  a significant contributor of  nutrients  to
Crystal  Lake -- of  the total  input  of phosphorus,  6.7%  or less  comes
from effluent plumes.   Where  plumes  do emerge, however,  they  appear  to
be supporting localized growths of  Cladophora,  a green alga.

     The only improvement in Crystal  Lake water quality likely  to result
from the Facility  Plan  Proposed Action or any of the EIS  alternatives
would  be the  possible  reduction  in  number  and  density   of  localized
growths  of  Cladophora  along the shoreline.   This could occur if  on-site
systems  along   the  shoreline  were  abandoned   and   cluster systems  or
centralized sewers  used.   No  alternative  is expected to affect either
adversely or beneficially  the  water  quality of the main  body of  Crystal
Lake through the year 2000.

     Future development in the Crystal Lake  watershed  is  primarily  a
function of how many new lots  can be  developed  and the density  of future
development.  Alternatives that rely  on continued use of  on-site  systems
would restrict both the number of new lots and  their  density as compared
to extensive sewering  around  the  lake.  One effect of these limitations
would be to preserve the present character of the community.

     There  are  large  differences  in  the present worth  and user  costs
among the alternatives.  Both costs increase in direct proportion to the
extent of new centralized sewers provided.  In  the more expensive alter-
natives, high  local  user charges would result  in  substantial  displace-
ment pressure  for  the permanent population and  pressure for conversion
of seasonal residences  to  permanent  use.   Proportionate  improvements  in
water quality would not occur.

     The recommended  action in  this  EIS is the Limited Action Alter-
native.  The alternative would provide:

     o    construction  of  new sewers  and  a   new   rotating biological
          contactor   (RBC)  treatment   plant   to  serve  Frankfort  and
          Elberta;

     o    sewer  system  evaluation surveys  and  rehabilitation  of  the
          existing sewers in Frankfort and Elberta;

     o    design and  implementation  of a small waste  flow  district for
          the rest of the Study Area;

     o    site-specific environmental and engineering analyses  of exist-
          ing  on-site  systems  in  the  unsewered  parts of  the Proposed
          Service Area;

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     o    repair  and  replacement  of on-site  systems  as  required;  and

     o    cluster systems or  other  off-site  treatment  for the northeast
          and southeast shorelines.

The recommended  action will  result  in an improvement in  water  quality
similar to any  of the other alternatives.  Its present  worth,  however,
is  only about  a third,  and  its tentative  local costs one  sixteenth,
those of the Facility Plan Proposed Action.

     If the action recommended by the EIS were accepted at the State and
local levels, it would be equivalent to a revised Facility Plan Proposed
Action.  EPA would  recommend that  Step II  and  Step III  construction
grants  for Frankfort  and Elberta be made independently  of  action taken
in the remainder of the Study Area.

     With  respect  to  the rest of the Study Area, State and  local con-
currence with  the Recommended Alternative  in the EIS would  imply that
three  additional  steps would be taken with  respect to formation of a
small waste flow district.  As part of the Step I process,  the applicant
would:

     o    certify that  the  project  will be constructed and an operation
          and maintenance program established  to  meet  local,  State, and
          Federal  requirements   including those  protecting present  or
          potential underground potable water sources.

     o    obtain assurance (such as an easement or covenant running with
          the land) of unlimited access to each individual system at all
          reasonable  times  for such  purposes  as inspection, monitoring,
          construction,   maintenance,   operation,   rehabilitation,  and
          replacement.   An  option would  satisfy  this  requirement if it
          could be  exercised  no  later than the initiation  of construc-
          tion.

     o    establish a comprehensive  program for  regulation and  inspec-
          tion  of  individual  systems before EPA  approves  the  plans and
          specifications.  Planning for this comprehensive program would
          be completed  as part  of the facility plan.  The program would
          include, as a minimum,  periodic testing of water from existing
          potable water wells in the area.  Where  a substantial number
          of on-site  systems exist,  appropriate additional monitoring of
          the aquifer(s) would be provided.

     Following  completion of  these  steps,  the Applicant  could  proceed
with  Step  II design  of facilities  for the small waste  flows district.

HISTORY

     In November  1976,  the  Crystal  Lake Area Sewage Disposal Authority,
consisting  of  Benzonia  and  Crystal  Lake  Townships,   prepared  a  201
Facility Plan  for wastewater disposal.   The Authority  also represented
the City  of Frankfort,  the Villages of  Elberta, Beulah,  and Benzonia,
and Lake Township, all  located in Benzie County, Michigan.   At the time,
                                   ill

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the  City  of  Frankfort  and  the  Village  of  Elberta had  already been
sewered and were  operating their  own sewerage facilities.   The Proposed
Service Area in the  Facility  Plan included  all the  jurisdictions  above.
The  Village  of Beulah,  although  included  in  the  Facility Plan  Study
Area,  was not  finally  incorporated into  the Proposed  Service  Area.

     With  respect  to wastewater treatment and  collection facilities  in
the  Study Area the  Facility  Plan  reached  the following  conclusions:

     o    Continued  use  of the existing septic tank systems would lead
          to continued deterioration of  water quality.

     o    Capacity at the Beulah  treatment  facility would be sufficient
          through  the year 1998 and that adequate  treatment  levels could
          be attained provided:

          1)    excessive infiltration and  inflow were removed

          2)    additional flood  irrigation  area were available,  if  re-
               quired

     o    Upgrading  and/or  expansion  of  the  treatment  facilities   at
          Frankfort  and Elberta  was  infeasible  and  those facilities
          should be abandoned.

     o    Collection and centralized treatment of  all wastewaters  in  the
          Proposed Service Area would be necessary.

EIS ISSUES

Cost Effectiveness

     Capital  cost of  the Proposed  Action   was  estimated  to  be  $18.4
million.  In terms of total net present  worth these  costs  were  judged to
be high.  In addition, since  approximately 80% of  the project cost would
be  for collection, examination of alternatives to  conventional  gravity
sewers would have  been  desirable.   The  Facility Plan rejected  continued
use  of  septic  systems, particularly  along  the  shorelines of  Crystal
Lake.

Water Quality

     Two  earlier studies of the water quality in Crystal Lake documented
the  presence of localized  growth of aquatic  vegetation near the  shore-
line.  Neither the studies nor the Facility  Plan quantified  the probable
impacts of sewers  upon water quality.

     With respect  to Betsie  Lake,  the Facility Plan estimated  that  the
phosphorus  load  would   decrease  by  approximately  40%  if  sewers were
constructed.   However,  the  Plan  did  not  describe  the  relationship
between  such a  reduction and eutrophication  of the  lake.   In  addition,
the  new,  and perhaps  larger  discharges  of  effluent that  would  follow
population growth were not considered.
                                    iv

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Economic  Impact
     The estimated user charge for the Facility Plan Proposed Action was
$175 per  year for  each  residence or residential equivalent  in  the  new
sewer  service  area around  Crystal  Lake.   This  charge  would amount  to
1.9% of the  average annual  income of the permanent  residents.   Crystal
Lake service area homeowners would pay an  initial $1500  for  stub  fee and
connection charge.   In addition,  there  would be an additional homeowner
cost for  installation  of a  house sewer connecting  individual household
plumbing with the public  sewer.

     These  sewerage costs  could encourage  seasonal and  fixed  income
residents to  sell  their properties  or  to convert from seasonal  use  to
permanent residency.

Induced  Growth and  Secondary Impacts

     While  the  high  costs  of  wastewater collection  might  force  some
current residents  to move,  the  availability of  sewers  in  the  Crystal
Lake watershed  would  make  possible  construction of  new dwellings  in
greater number and  in  higher  densities  than  is presently  feasible.   The
potential for  significant  future development  is indicated  by the  sub-
stantial  number  of  undeveloped  platted  shoreline, second tier and  sub-
division lots in the watershed.

     The  rate and  type of  development supported by a central  sewer  sys-
tem could have undesirable  impacts.   In  particular,  housing  construction
on  steep  slopes  could  accelerate  soil erosion  which,  in  turn, would
increase  inputs   of nutrients  to  Crystal   Lake or  Betsie  Lake.    In
addition,  the  density  and  type  of  future development  feasible  with  a
central sewer system could be considerably different from  that presently
typical of the Crystal  Lake  area.
ENVIRONMENT

Soils

     In general, soils on  sites  set back from Crystal  Lake  are  suitable
for on-site disposal of  wastewater.   Steep slopes  are  the major limita-
tion of such soils.

     Opinions differ on  the  suitability  of soils on shoreline sites  for
on-site disposal of wastewater.   The  Tri-County  Health Department  has
evaluated such sites and determined that over half the vacant  lots  are
suitable for  septic systems.  The  Soil  Conservation  Service considers
excessive permeability  to  be  a  limitation to  on-site systems.  Thus,
soils acceptable to one  agency may  be rejected by  the other.   However,
the difference alone does  not  account for the large discrepancy between
the two  sets  of soils data.   One explanation may  be  that  the  seasonal
high water  table  may not  be so high  as  was  suggested to SCS  in their
surveying.

                                    v

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Surface Water  Resources

     Crystal Lake, the centerpiece of  the  Study Area,  occupies approxi-
mately  15  square miles;  its  primary tributary is  Cold  Creek.   Betsie
Lake occupies approximately 0.4  square  miles.  Its  primary tributary is
the Betsie River and it is  itself tributary to  Lake  Michigan.

     The hydrology of the lakes  directly affects their  quality.  Crystal
Lake,  despite  a  retention time  greater than 60  years,  is generally
clean,  clear  and oligotrophic.   At  a  distance from the shoreline, the
Lake has shown  little  change  in productivity in  10 years.   Conversely,
Betsie  Lake,  with a retention time  of  2 days, is eutrophic.  For both
lakes, phosphorus has been identified as the limiting nutrient.

Groundwater Resources

     Groundwater  serves  as the  source  of drinking water  for Beulah,
Elberta and  Frankfort.   Water supplies  in the remainder  of the  Study
Area  consist  of  individual   and  small  community wells.   Water  is
generally plentiful  and  of good  quality, although hard.   A  1969 survey
of 165 wells around Crystal Lake indicated  no  contamination by indicator
bacteria;  nitrates were generally present at concentrations ranging from
0-2 mg/1.   The concentration of  nitrate in  2 wells exceeded the Drinking
Water Standard of 10 mg/1.

Additional Studies

     Because of  the scarcity of recent data, three additional studies
were performed in connection with this  EIS.

     1)   An  aerial  survey was  performed  by  the  Environmental Photo-
          graphic  Interpretation Center (EPIC)   during the  summer of
          1978.    Few surface malfunctions  of on-site sewage disposal
          systems were found,  but foliage may have hidden  from view some
          failing  systems.   The  densest growths of   submerged aquatic
          vegetation  were  found along the  northeastern  and  eastern
          shores.

     2)   A sanitary survey was  conducted  by the  University  of Michigan
          during  September and  October of  1978.   The  results indicated
          that  over  half  the lakeshore on-site  systems were violating
          the sanitary code.  Few of the systems,  however,  had recurring
          problems  with  backups or  ponding.   Heavy  shoreline   algal
          growth was associated with about 10% of  the sites.

     3)   A  study of  septic  leachate   intrusion  into  Crystal  Lake was
          performed  during  November  1978.   Approximately  90   septic
          systems were determined to be leaching  into  the  Lake.   Growth
          of  submerged  vegetation   was  correlated with  effluent dis-
          charge.
                                    vi

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     An analysis of the  additional  data provided by these studies indi-
cates that septic tank effluents  contribute  to  the growth of algae along
the  lakeshore.   Malfunctions  generally  consist of  backups  of sewage
rather than surface ponding.   Groundwater data  are inconclusive.  Of the
problems  with  backups,  most  relate to  inadequate  maintenance, rather
than  insufficient  soil  absorptive  capacity.   In addition,  it was esti-
mated  on  the basis of  computer  models that 6.7% or  less  of the total
phosphorus loading  to Crystal Lake  was  contributed  by septic  systems.

Existing Population and Land Use

     Approximately 60% of the  Proposed Service Area population  consists
of  seasonal  residents,  located  primarily  in  the unsewered  areas sur-
rounding  Crystal  Lake.   The  permanent  resident  population,  located
throughout the  Proposed  Service  Area,  is  characterized by a  relatively
low  income  that  is  below  the  average  income for  all  of Michigan.
Retirement age population,  often  consisting  of  persons on fixed  incomes,
makes  up  17% of  the  Service  Area's population. The  proportion of the
Service Area's  retirement age  population is more than twice the propor-
tion for the State of Michigan.

     Land  use   in  the  Service  Area consists  of:   three  small  urban
centers  (Frankfort,  Elberta,  and   Benzonia);  permanent  and  seasonal
single  family  residences;  agricultural areas  devoted  to row crops and
orchards;  and  open  land consisting  of  woodlands,  wetlands,  and sand
dunes.  The  aesthetic appeal  of the area   has  resulted in substantial
residential development around Crystal Lake.   Most commercial areas are
located in the village centers and  along major  highways.

ALTERNATIVES

     Based upon  the  high cost of conventional  technology and questions
concerning the  eligibility of  the  new sewers for Federal funding, 7 new
alternatives were  evaluated  in this  EIS  along with  the  Facility Plan
Proposed Action.  These alternatives incorporated alternative  collection
systems  (pressure  sewers),  treatment  techniques   (land  application),
individual and multi-family septic  systems  (cluster systems), and water
conservation.

Limited  Action Alternative

     New treatment plant serving  Frankfort and  Elberta,  upgraded and new
sewers  for Frankfort  and  Elberta.   Cluster systems  for  the northeast
shore  of  Crystal Lake and  the Benzonia  Village shoreline.  Repair and
rehabilitation of  on-site systems  throughout the remainder of the Study
Area.

EIS Alternative 1

     Same  as Facility  Plan Proposed Action, except that pressure sewers
would be substituted for gravity  sewers.
                                   vii

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EIS  Alternative 2

     Same as EIS  Alternative 1, except  that  land  application of waste-
water would be substituted for RBC treatment.

EIS  Alternative 3

     Frankfort, Elberta,  and the  southwest  shore  would discharge their
wastes  to  a  new  RBC  plant in Frankfort.   Wastewaters  from  Benzonia
Township and  Benzonia  Village  would be  treated  by  land application.
Collection of wastewater by pressure  sewers from the northeast shore and
treatment by land  application.   The remainder of the Study Area would be
served by a combination of cluster systems and on-site systems suitable
to local conditions.

EIS  Alternative 4

     Same as EIS  Alternative 3, except  that  land  application of waste-
water would be substituted for RBC treatment.

EIS  Alternative 5

     The same  decentralized treatment as in  EIS  Alternative 3.  Flows
from  other  parts  of  the  Study  Area, the northeast  shore and from the
Crystalia-Pilgrim area  would  be treated at a  new RBC plant located in
Frankfort.

EIS  Alternative 6

     Same  as  EIS  Alternative  5,   except  that  wastewater  from  the
Crystalia-Pilgrim area  would  be treated by  rehabilitated on-site sys-
tems.   Extensive  use of  cluster  systems  assumed  to  be  unnecessary in
contrast to EIS Alternatives 3,  4, and 5.

     Project costs were most directly related to the extent of sewering.
No cost advantage would obtain for pressure  sewers.

Implementation

     Local  jurisdictions  have  the   legal  and financial  capability to
implement  small waste  flow districts.   Although  the concept of public
management  of septic systems has not been  legally tested in Michigan,
present  sanitary  codes have been  interpreted  as  authorizing such man-
agement  by local  governments.  Some, but  not many local jurisdictions
have  experience in  the organization  and operation of small waste flows
districts.   California  and Illinois provide some  specific examples.
                                   viii

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IMPACTS  OF THE ALTERNATIVES

     Five major  categories of  impacts  were relevant  in the  selection  of
an alternative.  These categories included:  surface  water;  groundwater;
environmentally  sensitive  areas;  population  and  land use; and  socio-
economics.

Surface  Water

     None of the  wastewater  management alternatives  would have  signifi-
cant impact on the  trophic  status of Crystal Lake in  terms of  the  open
water  quality,  which  would  continue  to be  good.   The  problem  of
Cladophora growth in  shoreline areas,  however,  would  remain unless the
shoreline homes are  sewered.

     Betsie Lake  is expected  to  benefit significantly from all the EIS
alternatives,  as  well as the  Facility Plan Proposed Action, with  sub-
stantially     reduced phosphorus  input  to the lake.   Total phosphorus
concentration  in  the  lake would  decrease from the  present level  as  a
result of any of the alternatives except the  No  Action  Alternative.  The
classification of Betsie Lake as  eutrophic will  not change although  some
reduction in aquatic plant growth is likely.

Groundvater

     No significant primary  or secondary impacts  on  groundwater quanity
are anticipated either as a  result of the short-term  construction  activ-
ities or  long-term  operation  of  any of the various  alternatives.   This
is mainly because all  of the  water quantities  associated with the  alter-
native are almost miniscule  in comparison with the estimated groundwater
storage,  recharge  from  all  other sources,   and  available  groundwater
yield.

     No significant short-term impacts  on groundwater  quality are anti-
cipated to result from  the  construction activities of  any of the  alter-
natives.   Conclusions with  respect  to  long-term groundwater  quality
impacts are as  follows:

     o    Impacts on  bacterial quality  are expected  to be insignificant
          for all alternatives.

     o    Continued  use of septic  tank/soil  absorption systems  (ST/SAS)
          particularly  on  the northeastern   lake  shore may  result  in
          minor impacts  associated with shoreline  algal growths.

     o    No significant  impacts  on nitrate  concentrations  are antici-
          pated providing the density of ST/SASs complies with generally
          accepted standards.  Only  the  No Action Alternative is  likely
          to result  in significant adverse impacts.
                                   ix

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Environmentally Sensitive  Areas

     Any  of the  alternatives  may  allow  development  on  steep  slopes
around Crystal Lake.   This  would  result in erosion, sedimentation, and
transfer of  nutrients  to the  lake.   The Facility Plan Proposed Action
and EIS  Alternatives  1 and  2  might have  a  somewhat greater impact in
this respect than would the  Limited  Action or EIS Alternatives 3, 4, 5
or 6.

Population and  Land Use

     It  is  estimated  that the  centralized alternatives  would permit a
19% increase above standard  population projections  for the Service Area.
The Limited and No Action Alternatives would  result in population growth
7%  below standard  projections  while EIS  Alternatives  3,  4, 5,  and 6
would  generate population  growth 4%  above  the  standard  projections.

     Acreage in residential  use would  increase 77% (No Action Alterna-
tive)   to  88% (centralized alternatives)  of land available.   The provi-
sion of sewers  would allow the  present demand for  land development along
the Crystal Lake shoreline to be met.  The  decentralized, No Action, and
Limited Action alternatives  would increase the value of existing resi-
dential property by restricting the  amount  of additional land that could
be developed.  Centralized facilities might result  in increased develop-
ment pressure.   The No  Action,  Limited  Action,  and decentralized alter-
natives would tend to maintain  existing  community  character.

Economic  Impacts

     Annual  user  charges are  much  higher for  the centralized alter-
natives  than  the  decentralized  alternatives   with  respect  to  the
currently unsewered  portion of the  Study  Area.   User  charges  for the
centralized  alternatives  are somewhat lower  in Frankfort  and Elberta.
The centralized  alternatives place  a  significant  financial  burden and
displacement pressure  on housholds  in  the  unsewered  areas.   Only the
Limited  Action  Alternative  and EIS  Alternatives  5 and  6 are not high-
cost  for  the  unsewered  area.   None   of  the  alternatives   have  been
identified as a high-cost project  with  respect  to  Frankfort and Elberta.
Significant financial burden and displacement pressure are much lower in
Frankfort and Elberta  as  compared to the remainder of the Service Area.

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                               CONTENTS
List of Preparers 	 i
Summary 	•	 ii
List of Tables 	 xv
List of Figures 	 xvii
Symbols and Abbreviations 	 xix


                   I - INTRODUCTION, BACKGROUND AND ISSUES                1

A.  Project Description and History 	   1

    1.  Location	   1
    2.  History of the Construction Grant Application 	   1
    3.  The Crystal Lake Area Facility Plan 	   4

B.  Issues of This EIS 	  15

    1.  Cost Effectiveness 	  15
    2.  Impacts on Water Quality 	  15
    3.  Economic Impact	  16
    4.  Induced Growth and Secondary Impacts 	  16

C.  National Perspective on the Rural Sewering Problem 	  16

    1.  Socioeconomics 	  17
    2.  Secondary Impacts	  19
    3.  The Need for Management of Decentralized Alternative Systems ..  19

D.  Purpose and Approach of the EIS and Criteria for Evaluation of
    Alternatives 	  21

    1.  Purpose 	  21
    2.  Approach 	  21
    3.  Major Criteria for Evaluation of Alternatives 	  23
                         II - ENVIRONMENTAL SETTING                      25

Introduction 	  25

A.  Physical Environment 	  26

    1.  Physiography 	  26
    2.  Geology 	  27
    3.  Soils	  31
    4.  Atmosphere 	  37
                                      xi

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                                                                        Page

B.  Water Resources	  41

    1.   Water Quality Management 	  41
    2.   Groundwater Use 	  46
    3.   Groundwater Hydrology	  47
    4.   Groundwater Quality 	  49
    5.   Surface Water Hydrology 	  52
    6.   Surface Water Use and Classification 	  56
    7.   Surface Water Quality 	  56
    8.   Flood Hazard Areas 	  64

C.  Existing Systems 	  66

    1.   Summary of Data on Existing Systems 	  66
    2.   Types of Systems 	  68
    3.   Compliance with the Sanitary Code 	  71
    4.   Problems Caused by Existing On-Site Systems 	  72

D.  Biotic Resources 	  78

    1.   Aquatic Biology 	  78
    2.   Wetlands 	  81
    3.   Terrestrial Biology 	  81
    4.   Threatened or Endangered Species 	  83

E.  Population and Socioeconomics 	 	  84

    1.   Population	  84
    2.   Characteristics of the Population:  Employment and Income 	  87
    3.   Housing 	  88
    4.   Land Use 	  90
    5.   Archaeological and Historical Resources 	  96
                             III - ALTERNATIVES                          97

A.  Introduction 	  97

    1.  General Approach  	  97
    2.  Comparability of Alternatives:  Design Population  	  99
    3.  Comparability of Alternatives:  Flow and Waste Load
        Projections	  99

B.  Components and Options  	  99

    1.  Flow and Waste Reduction 	  99
    2.  Collection 	  103
    3.  Wastewater Treatment 	  106
    4.  Flexibility 	  110
    5.  Reliability 	  112
    6.  Effluent Disposal 	  115
    7.  Sludge Handling and Disposal  	  116
                                     xii

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C.  EIS Alternatives	 117

    1.  Introduction 	 117
    2.  Alternatives 	 123
    3.  Flexibility 	 133
    4.  Costs of Alternatives 	 136
    5.  Engineering and Economic Analysis of Flow Reduction Devices ... 137

D.  Implementation 	 138

    1.  Centralized Districts 	 138
    2.  Small Waste Flow Districts 	 140
                                IV - IMPACTS                            145

A.  Surface Water 	 145

    1.  Primary Impacts 	 145
    2.  Secondary Impacts:  Non-Point Source Nutrient Loads 	 152
    3.  Mitigative Measures 	 153

B.  Groundwater 	 154

    1.  Groundwater Quantity Impacts 	 154
    2.  Groundwater Quality Impacts 	 155
    3.  Mitigative Measures 	 160

C.  Population and Land Use 	 160

    1.  Introduction 	 161
    2.  Population 	 161
    3.  Land Use 	 161
    4.  Transportation 	 162
    5.  Changes in Community Composition and Character 	 162

D.  Encroachment on Environmentally Sensitive Areas 	 163

    1.  Wetlands 	 163
    2.  Sand Dunes 	 164
    3.  Steep Slopes 	 164
    4.  Prime Agricultural Lands 	 165
    5.  Flood Hazard Areas	 165
    6.  Critical and Unique Habitats 	 165

E.  Economic Impacts 	 166

    1.  Introduction	 166
    2.  User Charges 	 166
    3.  Local Cost Burden	 170
    4.  Mitigative Measures 	 173

F.  Impact Matrix 	 174

                                    xiii

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                                                                        Page

                          V - THE RECOMMENDED ACTION                    179

A.  Selection of the Recommended Alternative 	 179

    1.  Evaluation Results 	 179
    2.  Conclusions 	 182

B.  Draft EIS Recommended Alternative 	 183

    1.  Description 	 183
    2.  Implementation 	 185
    3.  Impacts of the Recommended Alternative and Mitigating
        Measures 	.  . 187


                 VI - THE RELATIONSHIP BETWEEN SHORT-TERM USE
                      AND LONG-TERM PRODUCTIVITY                        189

A.  Short-Term Use of the Study Area	 .. 189

B.  Impacts Upon Long-Term Productivity	 189

    1.  Commitment of Non-Renewable Resources 	 189
    2.  Limitations on Beneficial Use of the Environment 	 189
               VII - IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS
                     OF RESOURCES                                       191
                 VIII - PROBABLE ADVERSE ENVIRONMENTAL IMPACTS
                        WHICH CANNOT BE AVOIDED                         193
Glossary 	 195
Documents Cited in This Report	 209
                                      xiv

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                                 TABLES
Table                                                                   Page

  1-1     Comparison of Proposed and Observed Effluent Parameters
          for Frankfort and Elberta 	    9

  1-2     Projected 1998 Design Flows, Crystal Lake Area Facility
          Plan 	   11

  1-3     Present Worth Comparison of EIS Alternatives, Crystal Lake
          Area Facility Plan 	   14
 II-l     Soils Suitability for On-Site Systems Around Crystal Lake ...   36

 II-2     Climatological Summaries for the Crystal Lake Area 	   40

 11-3     Municipalities Using Groundwater for Prinking Supplies in
          the Study Area 	   47

 I1-4     Physical Characteristics of Betsie Lake and Crystal Lake ....   55

 II-5     Non-Recreational Water Uses of Betsie Lake 	   57

 II-6     Total Phosphorus Loads to Crystal Lake 	   60

 II-7     Water Quality of Crystal Lake 	   62

 II-8     Total Phosphorus Loads to Betsie Lake (1972-1973)  	   63

 II-9     Parameters Influencing Septic Tank Performance Along
          Crystal Lake Shoreline Areas 	   69

 11-10    Permits Issued in the Proposed Service Area by GT-L-BHD
          Between 1970-1977 Including Repairs and New Installations ...   71

 11-11    Distribution of Cladophora Growth Along Crystal Lake
          Shoreline as Percent of Sites Investigated 	   79

 11-12    Characterization of Wetland Areas in the Crystal Lake
          Study Area 	   82

 11-13    Permanent Population Trends (1940-1975) 	   85

 11-14    Population Projections and Average Annual Growth Rates for
          Crystal Lake Proposed Sewer Service Area 	   86

 11-15    Poverty Status - Families (1970) 	   87

 11-16    Housing Characteristics of the Socioeconomic  Study Area 	   89

 11-17    Minimum Shoreland Ordinance Standards 	   94
                                    xv

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Table                                                                   Page

III-l     Alternatives—Summary of Major Components 	  119

III-2     Cost-Effective Analysis of Alternatives 	  124

III-3     Small Waste Flow Management Functions by Operational
          Component and by Basic and Supplemental Usage	  142

                                        2
 IV-1     Phosphorus Loading Limits (g/m /yr) 	  146

 IV-2     Estimates of Phosphorus Loads to Betsie Lake for the
          Wastewater Treatment Alternatives 	  148

 IV-3     Crystal Lake Phosphorus Budget 	  150

 IV-4     Effluent Quality Comparison for Land Treatment and AWT
          Systems 	  159

 IV-5     Annual User Charges	  167

 IV-6     High-Cost Alternatives (Annual User Charges Exceed 2.5%
          of Median Household Income) 	  171

 IV-7     Financial Burden and Displacement Pressure 	  172


  V-l     Alternative Selection Matrix 	  180
                                    xvi

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                                FIGURES
Figure                                                                  Page

  1-1     Location of Crystal Lake Study Area 	    2

  1-2     Crystal Lake Study Area 	    3

  1-3     Existing Wastewater Facilities and Boundaries of Presently
          Sewered Areas 	    6

  1-4     Facility Plan Proposed Service Area 	   12

  1-5     Monthly Cost of Gravity Sewers 	   18


 II-l     Topography of Crystal Lake Study Area 	   28

 II-2     Bedrock Geology of the Crystal Lake Study Area 	   29

 II-3     Surficial Geology of the Crystal Lake Study Area 	   30

 II-4     Major Soil Associations in the Crystal Lake Study Area 	   32

 II-5     Soil Conservation Service Land Resource Inventory Maps for
          the Crystal Lake Study Area 	   33

 II-6     Location of Soil Borings Around Crystal Lake and the
          Corresponding Limitations of the Soil Type for On-Site
          Systems 	   35

 II-7     Soil Suitability for On-Site Systems and Supply Irrigation ..   38

 II-8     Prime Agricultural Lands of the Crystal Lake Study Area 	   39

 II-9     Groundwater Flow Patterns for Crystal Lake 	   50

 11-10    Location of High Nitrate Concentrations on the North Shore
          of Crystal Lake (Selected Wells) 	   51

 11-11    Surface Water Hydrology and Wetlands of the Crystal Lake
          Study Area 	   53

 11-12    Flow, Phosphorus Concentration and Phosphorus Loads in the
          Cold Creek (1976-1977) 	   59

 11-13    Flood Hazard Areas of the Crystal Lake Study Area 	   65

 11-14    Plume Locations on Crystal Lake 	   67

 11-15    Results of Aerial Shoreline Survey, EPIC 1978 	   70

 11-16    Results of the Aerial Shoreline Survey, July 6,
          September 5, 1976 	   75
                                    xvii

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Figure                                                                  Page

 11-17    Existing Land Use of the Crystal Lake Study Area 	   91


III-l     Phosphorus Loadings at Michigan Treatment Plants,
          1976-1978 	  102

III-2     STEP-Typical Pumps Installation for Pressure Sewer	  105

III-3     Land Application Sites for the Crystal Lake Study  Area 	  108

III-4     EIS Alternative 1:  Proposed Wastewater Facilities 	  126

III-5     EIS Alternative 2:  Proposed Wastewater Facilities 	  128

III-6     EIS Alternative 3:  Proposed Wastewater Facilities 	  129

III-7     EIS Alternative 4:  Proposed Wastewater Facilities 		  131

III-8     EIS Alternative 5:  Proposed Wastewater Facilities 		  132

III-9     EIS Alternative 6:  Proposed Wastewater Facilities	  134


 IV-1     Trophic Status of Betsie Lake and Crystal Lake	  147


  V-l     Limited Action Alternative 	  184
                                     xviii

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                          SYMBOLS AND ABBREVIATIONS
P
y
v
a
An asterisk following a word indicates that the term is
defined in the Glossary at the end of this report.  Used
at the first appearance of the term in this EIS.
less than
greater than
Rho
Mu, micro
Nu
Sigma
                           TECHNICAL ABBREVIATIONS
AWT
BOD
DO
ft2
fps
g/m /yr
GP
gpcd
gpm
I/I
kg/yr
kg/cap/yr
kg/mile
Ib/cap/day
mgd
mg/1
ml
msl
MPN
N
NFS
advanced wastewater treatment
biochemical oxygen demand
dissolved oxygen
square foot
feet per second
grams per square meter per year
grinder pump
gallons per capita per day
gallons per minute
infiltration/inflow
kilograms per year
kilograms per capita per year
kilograms per mile
pounds per capita per day
million gallons per day
milligrams per litre
millilitre
mean sea level—implies above msl unless otherwise indicated
most probable number
nitrogen
ammonia nitrogen
nitrate nitrogen
non-point source
                                     xix

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O&M
P
PH
P°4
ppm
psi
RBC
SS
STEP
STP
ST/SAS
TKN
TP-P
EPAECO
operation and maintenance
phosphorus, or "as phosphorus"
measure of acidity or basicity; <7 is acidic; >7 is basic
phosphate
parts per million
pounds per square inch
rotating biological contactor
suspended solids
septic tank effluent pumping
sewage treatment plant
septic tank/soil absorption system
total Kjeldahl nitrogen
total phosphorus as phosphorus
micrograms per liter
name of a mathematical model
                         NON-TECHNICAL ABBREVIATIONS
DNR
EIS
EPA
EPIC
FWS

GT-L-BHD
HUD
NOAA

NES
NPDES
SCS

STORET
USDA
USGS
Michigan Department of Natural Resources
Environmental Impact Statement
United States Environmental Protection Agency
Environmental Photographic Interpretation Center (of EPA)
Fish and Wildlife Service, United States Department of
the Interior
Grand Traverse-Leelanau-Benzie District Health Department
United States Department of Housing and Urban Development
National Oceanic and Atmospheric Administration, United
States Department of Commerce
National Eutrophication Survey
National Pollutant Discharge Elimination System
Soil Conservation Service, United States Department of
Agriculture
STOrage and RETrieval (data base system of EPA)
United States Department of Agriculture
United States Geological Survey, Department of the Interior
                                      xx

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                               CHAPTER I

                INTRODUCTION,  BACKGROUND AND  ISSUES
A.   PROJECT HISTORY  AND DESCRIPTION

1.   LOCATION

     The  subject  of  this  Environmental  Impact  Statement  (EIS)  is
requested  Federal   funding   of  proposed  wastewater  collection  and
treatment  facilities  in  the  Crystal  Lake  area  of  Benzie  County,
Michigan.  The "Crystal Lake  Area Facility Plan - Wastewater Collection
and Treatment" recommended construction of the facilities which will be
described later in this  chapter.   The  new wastewater facilities would be
located  in  the City of Frankfort,  the  Villages  of  Beulah,  Elberta and
Benzonia,  and  the  Townships  of  Benzonia,  Crystal  Lake  and  Lake.
Together  these   communities   make   up   the   Facility  Planning  Area,
approximately  one-fifth  of the  land area  of Benzie County,  which is
located in the northern part of the  Lower Peninsula on the eastern shore
of  Lake  Michigan.   The  combined year-round population  of  the  areas
proposed  prepared  for  sewering  (i.e.,  the  Proposed Service  Area) is
estimated to  be  4,400,  a  figure which swells  to  about 8,300  in the
vacation  season.   Figure  1-1   shows  their  location  within  the State of
Michigan.  Figure 1-2 delineates  the Study Area.

2.   HISTORY OF THE  CONSTRUCTION GRANT  APPLICATION

     Water quality problems  and wastewater management needs of the Study
Area have  for several years  been a  concern  of  both area  citizens and
governmental agencies.   The  following  chronology lists actions that were
taken  before  and  during  the  preparation of  this  Environmental Impact
Statement.

March,  1970    "Crystal Lake  Water  Quality Investigation"  completed by
               Dr.  John J.  Gannon  of  the  School  of  Public  Health,
               University  of   Michigan,  for  the  Keep  Crystal  Clear
               Committee.

April,  1974    National Pollutant Discharge Elimination  System (NPDES)
               permits   issued  to  City of  Frankfort and  Village  of
               Elberta   by  State of  Michigan,   Department  of  Natural
               Resources (DNR).

November, 1974 NPDES permit  issued to  Village of Beulah by Michigan DNR.

March,  1975    "Report  on Betsie Lake, Benzie County, Michigan, Working
               Paper#185"   published  by  United  States   Environmental
               Protection Agency (EPA) Region V, as part of the National
               Eutrophication  Survey (NES).

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                               BENZ1E  COUNTY
Figure 1-1:   Location of Crystal Lake Study Area



                    2

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fc,

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August-
November, 1975 Resolutions   passed   by   local  units   of   government
               designating   the   Crystal   Lake  Area  Sewage   Disposal
               Authority as  the  lead  agency to prepare a  facility  plan
               in application for an EPA construction grant.

December, 1975 Notice  of   Noncompliance   with  NPDES permit  issued  to
               Village of Beulah by Michigan DNR.

October, 1976  Notice of  Noncompliance  and Order  to Comply with NPDES
               permit  issued  to  Village  of  Beulah by  Michigan  DNR.

November,  1976  Michigan DNR proposed  discharge limitations  for Betsie
               Lake,  recommended  that  discharges  not be made  to Betsie
               River  or to  Lake  Michigan,  and recommended  land disposal
               if possible.

December, 1976 Engineering  study  of wastewater treatment  alternatives,
               "Crystal Lake Area Facility Plan—Wastewater  Collection
               and  Treatment," completed by  Williams and Works,  Inc.;
               McNamee, Porter,  and Seeley;  and Perla Stout  Associates
               for  the  Crystal   Lake  Area  Sewage  Disposal  Authority.

December, 1976 Hearing held by Crystal Lake Area Sewage  Disposal
               Authority on proposed Facility Plan.

June, 1977     Crystal  Lake  Area  Sewage   Disposal  Authority  and  the
               Michigan DNR formally request an EIS.

July, 1977     Declaration  of  Intent by EPA Region V to  prepare an EIS.

October, 1977  Work  begun  by  WAPORA,  Inc.,  on the EIS for  the Crystal
               Lake  area.

December,  1977 First  EIS public information meeting.

February,  1978 "Final  Summary  Report  on  Crystal  Lake  Water  Quality
               Study"  completed  by Mr.  Fred  J.  Tanis  for the Crystal
               Lake  Property Owners Association.

June  15, 1978  Second EIS public  information meeting.

3.    THE CRYSTAL LAKE AREA  FACILITY PLAN

      In December  1976 the Crystal Lake Area Facility Plan was completed
and was subsequently submitted to EPA by the Benzie County Department of
Public   Works,   acting   as  the  applicant  for funding   under the EPA
Construction  Grants  Program.  The  Plan, which proposed  construction of
new  wastewater collection  and treatment  facilities,  had  been developed
for  the Crystal Lake Area  Sewage Disposal Authority by three consulting
firms:   Williams  and Works, Inc., the lead consultant;  McNamee, Porter,
and  Seeley; and Perla Stout Associates.

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     This section describes wastewater treatment facilities now existing
in  the  Study  Area,  summarizes  the  existing  water  quality  problems
presented in the Facility  Plan,  and discusses the alternative solutions
and  recommended  course  of  action (the Proposed Action)  developed  there
in  the Facility  Plan.   Conclusions  reached in  the  Facility  Plan  and
summarized  in  this Section  are  not necessarily  those  reached in  this
EIS.

a.    Existing  Wastewater Treatment Facilities

     Three communities in the Study Area—the City of Frankfort, Elberta
Village,  and  Beulah  Village—presently have  some type of  centralized
wastewater  collection and  treatment facilities.   Crystal Lake Township,
Lake  Township,   Benzonia   Township  and  Benzonia   Village  do  not  have
collection  facilities.    Wastewater  in  the latter  areas  is treated
on-site,  principally  by septic  tank-soil  absorption systems  (ST/SAS).
Figure   1-3  shows  the   locations  of  existing  community  treatment
facilities, the boundaries  of the sewer service areas,  and the points of
effluent disposal.

     Frankfort Primary Plant.  The  Frankfort primary  treatment  plant,
which  was  constructed in  1939,  has a  design capacity  of 0.26 million
gallons per day (mgd).  The plant serves almost all of  the population of
Frankfort  and  also treats  wastes  from Pet,  Inc.,  the  only  significant
source  of  industrial  wastewater  in the Study Area.  Effluent  from the
Frankfort  plant  is discharged  into Betsie Lake.   A description  of the
treatment  facilities  at   the  City  of  Frankfort,  Elberta Village  and
Beulah Village and evaluation of the treatment performance are contained
in Chapter 4 of the Facility Plan.

     Plant records indicate that the average daily flow to the Frankfort
plant  for  the  period  July  1974 to June 1976 was 0.27 mgd;  the peak flow
reached  0.436 mgd.  Treatment  has provided removal of  approximately 25%
of  the  biochemical  oxygen  demand (BOD) and  40% of the  suspended  solids
(SS).  Maintenance  costs have  increased and some  equipment,  such  as the
chlorination system and the comminutor*,  needs  repair  or replacement.
Problems  exist  which are  related  to  the  age  and  condition of  the
equipment  and  the  plant  cannot  meet  the  proposed  limitations  on
discharge   into   Betsie   Lake.   Further,   infiltration*   and  inflow*
hydraulically  overload  the  plant,   as  documented in the  Infiltration/
Inflow Analysis (I/I)  conducted for the City.

     Elberta Primary Plant.  The Elberta primary  treatment plant,  built
in  1957  with  an   average  design  flow of 0.10  mgd,   also  discharges
effluent  into Betsie  Lake.  This plant serves most of  the population in
the Village.

     From  July  1974 to June 1976  average  daily  flow  to  the treatment
plant  was  0.126  mgd; the  peak  flow reached 0.225 mgd.   The  plant has
averaged  approximately  35%  removal  of  BOD and 50% removal  of  SS.   The
*See Glossary.

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cost  of maintaining  the Elberta  plant,  like  the  Frankfort plant,  is
increasing.  The Infiltration/Inflow Analysis  for the  Village of  Elberta
concluded  that  the  existing  sewer system  is  subject  to  significant
infiltration.

     Beulah Oxidation Ponds.   The  Village  of Beulah  treatment facility
was designed  to handle  an average  annual  flow of 0.1 mgd.   The  system
serves  the entire  Village plus  a mobile home  park with approximately  40
trailers in the northwestern corner of  the  Village of  Benzonia.

     The facility  employs four  oxidation ponds and two  seepage  cells.*
The plant,  constructed  in  1971,  was originally designed to  dispose  of
all effluent  through  the seepage cells, but during the  last five years
it has  been  necessary  to discharge some of the effluent  into the Betsie
River when the  cells  become  hydraulically  overloaded.  The  NPDES permit
to discharge  semi-annually to the Betsie River states that  effluent may
not contain more than  30 mg/1 of BOD,  30  mg/1  of SS  and 200 coliforms/
100 ml.  However, stipulations in the permit that the  treatment facility
be monitored and improved have not been met.   Monitoring  wells have been
provided  to   detect   whether   seepage  from   the  cells pollutes the
groundwater.

     The  annual  average  flow   to  the Beulah  treatment  facility  is
approximately  0.081   mgd.    It   has  periodically  been necessary  to
discharge treated  wastewaters from  the final  seepage  cell to the Betsie
River because  the  hydraulic  capacity of the seepage cells  is 4,500 gpd
less than the present wastewaster flows.

     Influent to the treatment system is not sampled prior to treatment.
Consequently,  the  present  waste  loadings  and treatment  efficiency are
not  known.    However,  the  Facility Plan  estimated  the average  waste
loading  to  the  plant  at 70  pounds per day  of both  BOD and SS.  The
Infiltration/Inflow Analysis  for the  Village  of Beulah  indicated that
the sewer system is subject  to significant  infiltration.

     On-Site Treatment Systems.     On-site   wastewater   systems,   most
commonly the  conventional  septic tank-soil absorption system (ST/SAS),
serve all remaining parts of the Study  Area.   There  are also a number  of
systems  in   which  wastewaters  are   disposed  of   in   earth-covered,
gravel-filled  pits  in  the  ground.   A few  holding  tanks  have  been
installed in the area in recent  years.

     The Facility  Plan  claims  that  on-site  sewage  disposal   systems
contribute  to the degradation of water  quality in Crystal Lake.

b.    Existing Problems with  Water Quality and Wastewater
      Treatment Facilities

     As  a  preliminary  step  in the  development of wastewater management
alternatives, the Facility Plan  cites the following  problems.

     Betsie Lake.  An  analysis  of  Betsie Lake  (National Eutrophication
Survey  1975)  indicated  that  excessive  nutrient  loading  is   causing
eutrophic conditions.  In 1972,  48% of the phosphorus load  to the Lake

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was  contributed  by the  two  primary treatment plants  serving Frankfort
and  Elberta.   These  plants are incapable of meeting  effluent standards
proposed   by   the   State   of  Michigan   for   effluent   discharges
to   Betsie Lake.  Table  1-1  compares  the proposed effluent limitations
with effluent characteristics of the plants in 1975.

     Significant infiltration  was detected in the three  sewer systems.
Storm  sewers   connected  to the  sanitary  sewers  in  Frankfort are  the
source  of  inflow in  that system.  The Facility  Plan  recommended sewer
system  evaluation  surveys for Frankfort  and Elberta;  rehabilitation of
Beulah's sewers was also recommended, but without such a survey.

     Crystal Lake.    During the  preparation of  the  Facility  Plan  the
primary  source of  data  on water quality in Crystal Lake  was a  report
titled "Crystal Lake Water Quality Investigations" by Dr.  John J.  Gannon
of the University of Michigan (1970).  The Gannon report concluded that:

     o    the most important source of pollution in Crystal Lake was the
          inflow from Cold Creek.   Several  business  establishments and
          houses along  its north branch  contribute phosphates to Cold
          Creek.

     o    the  highest coliform levels  and  algal  concentrations existed
          in the waters  adjacent  to the north shore toward the east end
          of the lake.

     o    wells  along the northeast shore showed  significantly  higher
          concentrations  of  nitrate  than  did  wells  in  other  areas.
          Nitrate  levels  in  this  area generally ranged from  1  to 6 mg/1
          as N.*   (EIS  Note:   of the  99  wells  sampled on the northeast
          shore, 45 had nitrate concentrations less than 1 mg/1 as N, 50
          had   concentrations  between   1   and   6   mg/1  and  5  had
          concentrations  greater than  6 mg/1.)

     o    Crystal  Lake  is oligotrophic; dissolved oxygen concentrations
          in the deep areas are 7.2 mg/1  or greater.

     o    the  algal  mass in Crystal Lake will increase three  times in  a
          period of  7 to  10 years.

     o    sanitary sewage  should be  collected by means of a sewer system
          that would  encircle  the lake;  this   sewage  should then be
          treated and discharged outside  the basin.

     A  letter  was  included  in the  Facility Plan from Mr. Lyle Livasy,
R.S.,  staff sanitarian with the Grand Traverse-Leelanau Benzie District
Health  Department,  citing severe  soil limitations  around the lake for
on-site  sewage disposal and high coliform bacteria counts  at two houses
on the  northeast shore.

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                          Table 1-1

   COMPARISON OF PROPOSED AND OBSERVED EFFLUENT PARAMETERS
                 FOR FRANKFORT AND ELBERTA
                                                        Observed
Parameter (30-day average)
SS (mg/1)

Fecal Coliform (MPN/100 ml)

PH

Total P  (mg/1)

Proposed
10
15
200
6.5-9.5
1.0
^
Frankfort
140
128
440
7.1
11.0
b
Elberta
119
110
N/A
N/A
N/A
                           (or 80% removal,
                           whichever is stricter)
 Survey performed 8/75.
 Calculated from removal efficiencies.

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     The Crystal Lake Area Facility Plan reviewed  existing  data  on  water
quality  problems  in  Crystal  Lake  and  the   quality   of  surrounding
groundwater,  as  well  as  information  on site  conditions  such  as  soil
types  around  the lake.   The "Crystal Lake Water  Quality Investigation"
(Gannon  1970)  and  the  experience  of  Grand  Traverse-Leelanau-Benzie
District Health  Department  were  the major sources of information on the
problem  referenced  in the  Facility Plan.   The Facility Plan concluded
that high  water tables,  small  lots and  poor  soil provided sufficient
evidence to  link on-site  systems and subsequent  water quality  problems
and, therefore, to warrant sewering the Crystal  Lake  shoreline.

c.    Proposed  Solutions:   Alternatives    Addressed   in   the
      Facility Plan

     The Facility Plan  developed four  alternative wastewater management
plans  for  meeting   effluent   requirements   and   alleviating   problems
associated  with the  existing  collection and treatment  systems in  the
Facility Planning  Area.  Selection of the Proposed  Action from  among
these alternatives was based on analyses of costs, environmental impacts
and implementability of each.

     Collection  and  treatment facilities were  sized for  the year 1998
and were based  on  discharge of 100 gallons of wastewater per capita per
day  (gpcd)  for  permanent  residents and 60 gpcd for  seasonal residents.
Commercial  and  industrial   flows   were  included  in   the estimates.
Projected  flow  for the City  of Frankfort included 0.049  mgd from Pet,
Inc.   Also  included  is  residual  infiltration/inflow based  on values
determined  in the I/I  analyses  that had been  conducted previously for
the  Frankfort,  Elberta and Beulah collection systems (See Table  1-2).

     The  Facility  Plan  concluded  that  the  capacity  at the Beulah
treatment  facility  would  be  sufficient through  1998 and  that  adequate
treatment levels could be attained if (a) the  I/I  problem were corrected
and  (b)  an  additional flood  irrigation  area  were  to  be provided  if
required.   Each  of  the  alternatives  presented  in  the Facility  Plan
assumed  that  wastewater from  the Village of Beulah would  be treated at
the  local  treatment plant  and  that I/I  would  be corrected.   The Plan
also  determined that  it  was  not  feasible  to upgrade  and expand  the
existing  primary  plants  at  Frankfort  and   Elberta and  recommended
abandonment of these facilities.

     Finally,   the   Facility   Plan  concluded   that   collection  and
centralized  treatment of  all wastewaters  in  the  Proposed Service Area
shown in Figure  1-4 would be necessary.

     In  developing the  alternatives presented  in  the  Facility  Plan,
several elements were considered:

     o    Optimum operation of existing facilities,
     o    Flow and waste reduction,
     o    Collection systems,
     o    Wastewater treatment and disposal,  and
     o    Sludge disposal.
                                    10

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                          Table 1-2

 PROJECTED 1998 DESIGN FLOWS,. CRYSTAL LAKE AREA FACILITY PLAN
Community Yearly
Benzonia
Benzonia Township
Crystal Lake
Township
Elberta
Frankfort
Lake Township
average flow
0.046 mgd
0.128 mgd
0.122 mgd
0.068 mgd
0.257 mgd
0.035 mgd
Average
summer flow
0.048 mgd
0.141 mgd
0.183 mgd
0.068 mgd
0.257 mgd
0.059 mgd
Flow on
peak day
0.058 mgd
0.182 mgd
0.210 mgd
0.117 mgd
0.401 mgd
0.070 mgd
Williams & Works; McNamee, Porter and Seeley; and Perla Stout
Associates.  1976.  Crystal Lake area facility plan for wastewater
collection and treatment, Benzie County, Michigan.
                                11

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12

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     Plans  for  correcting  I/I  problems  were  incorporated  into  the
alternatives, but no  other  structural  flow-  or waste-reduction measures
were  analyzed.   Also  recommended by  the  Plan  was the  non-structural
approach  of  increasing   sewer  use  charges  as a  tool  to   encourage
conservation.   The  sewerage systems  consisted of  conventional  gravity
collectors with  a  combination  of force main  and  gravity  interceptors;
routing  of  sewers  varied  with  each  alternative  plan,  depending  on
location  and number  of treatment  facilities.   Treatment of  centrally
collected  wastewaters  by  processes   such   as  activated  sludge  and
physical-chemical  techniques   and by  land  application  after  aeration
in  lagoons  were  examined.    Methods   investigated  for  disposal   of
sludge  were: (1) digestion, with disposal  of liquid sludge on land;  (2)
digestion, with  disposal of dewatered  sludge on land;  and (3) digestion
and landfilling of dewatered sludge.

     The  four  wastewater  management  alternatives  developed  by  the
Facility Plan were:

     Alternative No.  1.   Treatment   of  wastewaters  from   Frankfort,
Elberta,  Lake Township,  and  Crystal  Lake Township  at  a new  rotating
biological contactor (RBC)  plant located in Frankfort and discharging to
Betsie  Lake.   Treatment  of  wastewaters  from  Benzonia  and  Benzonia
Township at  a new  land disposal  facility  located in  Benzonia Township.

     Alternative No.  2.  Treatment of all wastewaters at  a new RBC plant
in Frankfort, on land previously purchased by the City,  and discharge of
the effluent  to Betsie Lake.

     Alternative No.  3.   Treatment of  all  wastewaters  at a new  land
disposal facility.

     Alternative No.  4.   Treatment of  wastewaters  from Frankfort  and
Elberta at a  new land disposal facility.

     Table  1-3  shows  the  estimated   project construction  costs  and
operation and maintenance  costs and  salvage values in terms  of present
worth   and   sums the  total   present  worth  for  each   of   the  four
alternatives. An interest  rate  of 6-1/8% and  a 20-year  planning period
were used in  developing the costs presented in the table.

d.    The Facility  Plan  Proposed Action

     Alternative No.  2 was selected.    It  included improvement  of  the
operation  of the Beulah plant plus entirely new  centralized  facilities
to  collect  and  treat  wastewaters.   Flow would originate  not  only from
Frankfort  and  Elberta  but  also  from  new  areas--Benzonia  Village,
additional areas of Benzonia Township and Crystal Lake Township and from
Lake  Township.   The  sewer  service  area proposed  in  Figure  1-2  in  the
Facility Plan is shown in Figure 1-4.

     The  RBC system  was  selected over  activated sludge  and  physical-
chemical  treatment  on  the bases  of  cost and  ease of operation.   The
plant would  include  facilities  for chemical addition and microstraining
to provide advanced treatment.
                                   13

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B.   ISSUES OF  THIS  EIS

     The Environmental  Protection  Agency's  review of the Facility Plan
Proposed  Action  identified  the  following  issues  as  warranting   the
preparation of this EIS.

I.   COST  EFFECTIVENESS

     Capital cost for the Facility Plan Proposed Action was  estimated in
the  Plan  to be  $18.4  million.   This  equates  to an investment of $2207
per  person and  $8654   per  existing dwelling unit  within the Proposed
Service Area.   These per-person and per-household investments would  be
among the highest in EPA Region V.

     Eighty-one percent of  the  estimated  capital cost would be for  new
collector and interceptor sewers.  Extensive  use of  pressure sewers as a
potentially less expensive  alternative  to  gravity sewers was considered
by the  Facility  Plan consultants but at the insistence  of  the State of
Michigan was not evaluated in the Plan.   Reliance on septic  tank systems
to reduce the new areas to be sewered was  briefly considered but was  not
incorporated into  any  of  the Facility Plan alternatives.  Use of other
on-lot  sewage  disposal methods  or  small-scale technologies  was   not
considered.

2.   IMPACTS ON WATER QUALITY

     The  likely  impacts  of  the  Facility  Plan  Proposed  Action   and
alternatives to  it on  water quality were not satisfactorily addressed
in   the  Plan.   Of  principal   concern  are eutrophication  of Crystal
Lake and Betsie Lake and nearshore plant growth  in Crystal Lake.

     Citizen  concern   over   growth  of  aquatic plants in scattered
shoreline  areas of Crystal  Lake  resulted   in local  funding  of   two
limnological investigations of the Lake:  by  Gannon  in 1970  and Tanis in
1978.   Both studies  documented the  presence  near  some shorelines  of
aquatic plants growing on the lake bottom.  The  earlier report by  Gannon
predicted  that   substantial  increases   in  plant growth  would occur  at
existing nutrient loading rates.  The report  recommended that a sanitary
sewer  be  built  around the  lake  to  collect sewage  for treatment  and
export   from   the   Crystal  Lake   watershed.    The   conclusions   and
recommendations  of  this report  and statements  of the  local  sanitarian
(Livasy n.d.)  were  cited  in  the  Facility  Plan as  the  basis  for  not
relying on  septic  tank systems  around Crystal Lake in  the  future.   The
later report by  Tanis,  showed that plant  productivity had not increased
as predicted and suggested that "an alternative  which  addresses specific
problem areas  may  be  more  appropriate" than complete  sewering  of  the
shoreline.    Neither the  Facility  Plan  nor  the  limnological  reports
evaluated  quantitatively  the  probable  impacts  on  water  quality   of
sewering or not sewering the shoreline of  Crystal Lake.

     A  41% reduction in  phosphorus load  to  Betsie Lake, resulting   in
removal  of   phosphorus  from  Frankfort  and  Elberta  wastewater,  was
                                    15

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cited in  the Facility Plan.   However,  the Plan  did not describe  the
relationship  between   such   a   reduction   and   lake  eutrophication.
Nor were  calculations made  of  an increase  in  the  nutrient load from new
discharges of Crystal Lake  area  wastewaters and from larger discharges
of effluent which would  follow  population growth.

3.   ECONOMIC  IMPACT

     The estimated user  charge  for the Facility  Plan  Proposed Action was
$175 per  year for each  residence or residential  equivalent in the new
sewer service  area around  Crystal  Lake.   This  charge  would  amount to
1.9% of  the permanent residents'  average  annual  income.  Crystal Lake
Proposed  Sewer  Service  Area homeowners  would pay an initial $1500 for
stub fee*  and connection  charge.   In addition,  the homeowner would pay
for installation of a house  sewer connecting his household plumbing with
the public sewer.

     The  effect  of these  sewerage costs  could be  to encourage seasonal
and fixed  income residents  to  sell their properties or  to  convert from
seasonal use to permanent residency.

4.   INDUCED GROWTH AND  SECONDARY IMPACTS

     While  the   high  costs  of  wastewater   collection  might force some
current  residents  to move,  the  availability  of  sewers  in  the Crystal
Lake watershed   would make  possible  construction of  new dwellings in
greater number  and in higher  densities  than is  presently feasible.  The
potential  for   significant   future  development  is   indicated  by  the
substantial  number of  undeveloped platted shoreline,  second  tier and
subdivision lots in the  watershed.

     The  rate  and  type   of development  supported  by  a central  sewer
system   could   have  undesirable   impacts.    In   particular,   housing
construction  on steep slopes  could accelerate soil erosion which, in
turn, would  increase nutrient impacts  to  Crystal Lake  or Betsie Lake.
In  addition,  the density and  type of future development feasible with  a
central  sewer  system  could  be  considerably  different from  what is
presently  typical of the Crystal Lake area.
C.   NATIONAL PERSPECTIVE ON  THE RURAL  SEWERING PROBLEM

     These EIS issues, that have been discussed above,  are not unique to
the  proposed plan  for  wastewater management in the Crystal  Lake  Study
Area but  are typical of concerns raised by a large number of wastewater
projects  for rural and developing communities that have  been submitted
to  EPA for funding.  The scope of the problem has grown in the last few
years  as  controversy  has  mounted  over  the high  costs and  possible
impacts  of  providing conventional  sewerage  facilities  to   small  com-
munities across the country.
                                    16

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1.  SOCIOECONOMICS

     To  assess  the  magnitude of  the  cost  burden  that many  proposed
wastewater collection projects would impose on small communities and the
reasons for the high costs,  EPA studied over  250  facilities  plans from
49  states  for  pending projects for communities  under  50,000  population
(Dearth 1977).  EPA  found  that,  even with substantial State and Federal
construction grants,  the costs of  conventional sewering  are sometimes
beyond  the  means  of  families in  rural and semi-rural  areas.   This was
particularly  true  for  those  communities  where  the  completely  new
facilities proposed  would  result in  annual user  charges  of more  than
$200 per household.

     The Federal government has developed criteria to identify high-cost
wastewater  facilities  projects  (The  White  House  Rural  Development
Initiatives 1978).   Projects  are  considered to place a financial burden
on  rural  community  users  when annual  user  charges (debt  service  plus
operation and maintenance)  would exceed:

     o    1.5% of median household incomes less than $6,000;
     o    2.0% of median household incomes between $6,000 and $10,000; or
     o    2.5% of median household incomes over $10,000.

Annual user charges  exceeding these  criteria would materially affect the
households' standard  of living.  Federal  agencies  involved  in funding
wastewater  facilities will  work  with  the  community  to  achieve  lower
project costs through a change in the project's scope or design.  If the
project's  scope  or  design  is not changed, the  agencies will work with
the community until  they are assured that the community is aware of the
financial impacts of undertaking the high-cost project.

     It  is  the collection  system that  is  chiefly  responsible  for the
high costs  of conventional  sewerage  facilities for small communities.
Typically,  80% or  more of  the  total  capital  cost for newly  serviced
rural areas is  spent for collection system.  Figure 1-5  indicates  that
the  costs per  residence for  gravity  sewers increase  exponentially at,
population  density   decreases.    Primary  factors  contributing   to  this
cost/density relationship were found to be:

     o    greater length of  sewer  pipe  per dwelling  in  lower-density
          areas;

     o    more problems  with grade, resulting in  more  lift stations or
          excessively deep sewers;

     o    regulations or criteria which set eight inches as the  smallest
          allowable  sewer pipe diameter; and

     o    inability  of  small communities to spread  capital costs  among
          larger populations sewered previously.

     In  addition  to  the comparatively  high costs  of sewers,  facilities
were sometimes found to be more expensive than necessary due to:
                                   17

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                               Figure  1-5
  40




S 30



I
£

I 20
                TO
                                  Cost (Vmonth) = 43e ~° ' (p/a'
                             4      6     8     10    12

                            Population Density, persons/acre

                            Monthly Cott Of Gravity Sewers
                                                         14
Dearth,  K.H.   1977.  In proceedings of EPA national conference on
    less  costly wastewater  treatment systems for  small communities,
    April 12-14,  1977, Reston,  VA.
                                   18

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     o    oversophistication in design, with accompanying high chemical
          usage,  large  energy  requirements,  and costly maintenance and
          operator expense,  when simpler methods would  do.

     o    use  of  expensive  construction materials  such as non-locally
          produced brick and block  and  terrazzo when a prefab steel and
          concrete building  would perform satisfactorily.

     o    abandonment  of  existing  treatment  works   without  economic
          justification.

2.   SECONDARY  IMPACTS

     Installation  of centralized  collection  and  treatment  systems in
previously unsewered areas  can  have dramatic effects on development and,
hence, on the  economy,  demography and environment  of rural communities.
These  effects  can  be  desirable,   or  they  may  substantially  offset
community objectives  for water resource improvement,   land use planning
and environmental protection.

     In  broad  terms,  a community's  potential  for recreational, resi-
dential, industrial,  commercial or institutional development is deter-
mined by economic factors   such as the availability  of land, capital,
skilled  manpower  and  natural   resources.   However,  fulfillment  of the
potential can be  limited by the unavailability  of facilities or services
called infrastructure elements, such as  water supply, sewerage, electric
power  distribution  and transportation.   If   a  missing  infrastructure
element  is supplied,  development  of one type or  another may take place,
depending upon prevailing  local economic  factors.   Such development is
considered to  be  "induced  growth"  and is  a  secondary  impact  of the
provision of  the  essential  infrastructure element.

     Conflicts between  induced  growth  and  other  types  of  existing or
potential development  are  also termed secondary impacts as are  induced
growth's effects  on  existing  water  resources, land  use,  air quality,
cultural  resources,   aesthetic features and  environmentally sensitive
areas.

     Secondary  impacts  of  new  wastewater  facilities  may  be  highly
desirable.   For  example,  diversification  of the  local employment base
may be possible only when sufficient wastewater collection and treatment
capacity is  provided for commercial or industrial  development.   On the
other  hand,   new  commercial   or  industrial   development  may   not  be
compatible  with   existing   recreational   or  agricultural   interests.
Residential  development accompanying expansion of  the employment base
may take place on  prime agricultural land,  steep slopes or wetlands, or
may otherwise infringe on valued natural features.

3.    THE  NEED   FOR  MANAGEMENT  OF  DECENTRALIZED  ALTERNATIVE
     SYSTEMS

     A promising  alternative  to expensive  centralized  sewer systems in
rural  areas   is  a  decentralized  wastewater   management  system.  Both
engineering  and  management are  integral parts  of such  a  system,  and
                                    19

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"decentralized  alternatives,"  as  used  in  this EIS,  incorporate  both
engineering and management elements.

     Briefly, the  engineering  element  consists  of the use  of  existing
and new on-site  systems,  rehabilitation or replacement of those systems
where necessary, and  construction  of small-scale off-site systems where
existing on-site systems are not acceptable.

     The management  element consists  of continuing supervision  of the
systems'  installation,  maintenance,   rehabilitation   and  appropriate
monitoring of the systems'  environmental impacts.

     While  other  factors  such as  soil  characteristics,  groundwater
hydrology  and   lot  configurations   are  highly   important,   adequate
management may be  critical  to  the  success of decentralized alternatives
in many communities.  Similarly, lack of adequate management undoubtedly
contributed to past  failures of many on-site wastewater facilities and,
therefore, the  lack  of  trust  in  which they are  held by  local  public
health officials and consulting engineers.

     Historically,   state  and  local health officials were not  empowered
even to regulate installation  of on-site systems  until after World War
II.  They  usually  acted  in only  an  advisory capacity.   As the  conse-
quences of  unregulated use of  the  septic tank-soil  adsorption systems
became  apparent  in the  1950s  and  1960s, health officials were granted
new authority.   Presently most  health officials have authority for per-
mitting  and   inspecting or denying  new  installations,   and   they can
require renovation  and replacement of  on-site  systems.   However, their
role in the operation and maintenance of on-site systems remains largely
advisory.   There is  seldom  either  a budget  or  the authority to inspect
or monitor a system.

     In the   1970's,  the Congress  recognized  the need  for continuing
supervision  and  monitoring of  on-site systems  in  the  1977  Clean Water
Act.  Now, EPA  regulations  implementing that Act require that,  before a
construction  grant  for  on-site  systems may be made,  the  applicant must
meet a number of requirements and must:

     o    Certify  that  it will be responsible  for properly installing,
          operating and maintaining the funded systems;

     o    Establish  a comprehensive program  for regulation and inspec-
          tion of  on-site  systems  that will include periodic testing of
          existing  potable  water wells  and,  where a  substantial number
          of  on-site  systems  exists,  more  extensive  monitoring  of
          aquifers; and

     o    Obtain assurance  of unlimited access to each individual system
          at  all reasonable times  for  inspection, monitoring,   construc-
          tion,  maintenance, operation, rehabilitation and  replacement.

     In   some   cases,   implementation   of   these   requirements  by
municipalities may be hindered by  lack  of state  enabling  legislation for
small waste  flow management districts  and by lack of adequately  trained
                                    20

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manpower.   The municipality may have no  control  over  the  former and be
at a disadvantage because of  the  latter.  Other implementation factors,
over which municipalities should have control, are discussed in Section
III.D of this EIS.
D.   PURPOSE AND APPROACH OF THE  EIS AND CRITERIA FOR
     EVALUATION  OF ALTERNATIVES

1.   PURPOSE

     This   EIS   documents   EPA's    review   and   analysis   of   the
application for EPA Step  II  funding of the Facility Plan Proposed Action.
Based upon  this  review,  the Agency  will take one  of several  actions:

     o    Approve  the  grant  application,  possibly with recommendations
          for design changes and/or measures to mitigate impacts of the
          Facility Plan Proposed Action;

     o    Return  the   application with  recommendations  for  additional
          Step I analysis;

     o    Reject the grant application; or

     o    With the applicant's  and State's concurrence, approve Step II
          funding   for  an  alternative to  the  Facility Plan  Proposed
          Action,  as presented  in  this EIS.

     The review and analysis  focused on the issues identified in Section
I.B   and   was  conducted  with   an   awareness   of   the  more   general
considerations  of rural sewering problems   discussed  in Section  I.C.
Major emphasis has been  placed on developing and evaluating alternative
wastewater management  approaches  to be compared  with  the Facility Plan
Proposed Action.

2.   APPROACH

     The review and analysis reported in this EIS  included  a series of
tasks, which  were undertaken in  approximately the  following sequence:

a.   Review of Available Data

     Data presented in  the Facility Plan  and other sources were reviewed
for applicability in development  and/or  evaluation of the Plan Proposed
Action  and   of   the   new   alternatives  developed  for  the  EIS  (EIS
Alternatives).  Sources of data are listed in this Bibliography.

b.   Segment Analysis

     As a  basis for revised  population projections  and for development
of alternatives the Proposed Service  Area was partitioned into a number
of segments.  The number of  dwellings in each segment was counted from
black  and  white  aerial  photographs.   Available information on soils,
depth to groundwater,  water quality problems, environmentally sensitive
                                   21

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areas and land use  capabilities was tabulated  for  each  segment  and the
tabulations  used to make preliminary estimates of the need for off-site
wastewater disposal.

c.   Review of Wastewater Design  Flows

     Available population projections  were revised on the basis  of the
segment house counts.  New EPA  guidelines  for  estimating  design  waste-
water  flows  were  then  used to  revise the  year 2000  wastewater  flow
projections.

d.   Development of Alternatives

     First,  technologies  that might potentially reduce project costs or
minimize  adverse  impacts while  still  solving  existing problems  were
examined.    Four   categories   of   alternative  technologies  —   flow
reduction,  low-cost  sewers,  decentralization,  and land application --
were considered according to their functions in a wastewater management
system.   Next,  several  specific areawide  alternatives  were  developed,
combining   the   alternative   technologies   into   complete   wastewater
management  systems  that  would  serve  the  Proposed Service  Area.   The
technologies and the alternatives are described in Chapter III.

e.   Estimation  of Costs for Alternatives

     In order to assure comparability of costs between the Facility Plan
Proposed Action and EIS  alternatives,  all  alternatives were designed to
serve  a  fixed design year population.  Total  present worth  and  local
user charge  estimates  were  based upon unit  costs  listed  in  a separate
engineering report (Arthur Beard Engineers, Inc. 1978)

f.   Evaluation  of the Alternatives

     The new alternatives were developed with a  knowledge of the local
environmental  setting  and  with the  understanding that  they will  be
evaluated under criteria  from several disciplines.  The general criteria
for  evaluating  both  the Facility Plan  Proposed Action  and the  EIS
alternatives are listed in Section  I.D.3 below.

g.   Needs  Documentation

     The need for  improved treatment of Frankfort's and Elberta's  waste-
water is clear and is  not at  issue  in this  EIS.  However, the effects of
lakeshore on-site  systems  on  Crystal  Lake,  groundwaters   and  public
health had  not  been clearly documented in the  Facility Plan.  Because
determination  of   eligibility   for  Federal  funding   of  a  substantial
portion  of  the  Facility Plan  Proposed Action  will  be  based  on  the
documentation  of   these  effects,  several   supplemental  studies  were
conducted:

     o    an aerial survey  of  visible septic  tank system malfunctions
          using low-altitude  color and infrared photography by  EPA's
          Environmental Photographic Interpretation Center;
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     o    estimation of  the  existing Crystal  Lake  nutrient budget  and
          empirical modeling  of the lake's  eutrophication  status;

     o    a  sanitary survey  of lakeside  residences conducted  by  the
          University of  Michigan  Biological Station to evaluate  usage,
          design and condition of  on-site systems;

     o    a  "Septic  Snooper"  survey  to locate and  sample septic tank
          leachate  plumes  entering  Crystal  Lake from  nearby  on-site
          systems; and

     o    evaluation  by  the  Soil   Conservation   Service   of  soil
          suitability for on-site  systems.

     The results of these needs documentation studies were not  available
for  consideration  in  the  initial  development  of  alternatives.   The
results  of  each   study  have  required  continuing modification  of  the
alternatives as initially designed and have been the  basis for  necessary
refinements  in  the determination  of  the eligibility of  any new  sewers
around Crystal Lake for Federal funding.

3.   MAJOR CRITERIA  FOR EVALUATION  OF ALTERNATIVES

     While  the  high  cost  of  sewering rural  communities is  a  primary
reason  for examining alternative  approaches to wastewater management,
cost is not the only criterion.  Trade-offs between  cost and other major
impacts will have  to  be  made.  The various  criteria  are  defined below.

a.   Cost

     With  some  exceptions for innovative technologies, EPA construction
grant  regulations  allow  funding  of   only  the most   cost-effective
alternatives.   Cost  effectiveness  has been  measured here as  the  total
present worth of  an alternative,  including capital  costs  for facilities
needed now,  capital  costs  for facilities required later  in the  20-year
planning period,  and operation and maintenance costs for  all wastewater
facilities.   Salvage  value  for facilities  expected to  be in  service
after 20 years has been deducted.   Analyses of cost  effectiveness do  not
recognize differences between public and private expenditures.

     The  responsible municipality or  sanitary  district will  recover
operation, maintenance and local  debt retirement  costs through periodic
sewage bills.   The local economic impact  of  new wastewater facilities
will be  felt  largely  through associated residential  user  charges.  Only
publicly  financed  costs were  included in  residential  user charges.
Salvage value was not factored into residential user  charges.

     No  assumptions were  made  here  about  frontage  fees  or  hook-up
charges that might be levied  by the municipalities.   Therefore, the user
charges  reported  here  for  the alternatives  are not  directly comparable
to  those  reported in   the  Facility  Plan,  where  each  newly  sewered
residence would pay $1,500 in connection and stub  fees.
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     Some  homeowners  may  incur  costs  that  they  would  have  to  pay
directly  to  contractors.    Installation of  gravity  house  sewers  on
private  land  and renovation  or replacement  if  privately  owned on-lot
systems  for seasonally  occupied dwellings  are not eligible for Federal
funding and are  seldom  financed by municipalities.  These private costs
are identified for each alternative.

b.    Significant  Environmental  and  Socioeconomic   Impacts

     The  system  selected  for the  Proposed  Service  Area will impact on
environmental  and  socioeconomic  resources  within   the   Study  Area.
Following  a  comprehensive review  of possible impacts  of  the Facility
Plan Proposed Action and  the  EIS alternatives, several types  of  impacts
were determined  to  warrant in-depth  evaluation  and discussion in this
EIS.  These impacts  are classified as follows:

     o    Surface Water Quality  Impacts,

     o    Groundwater Impacts,

     o    Population and  Land  Use  Impacts  including Infringement on
          Environmentally Sensitive Areas,  and

     o    Economic Impacts.

c.   Reliability

     Reliability  criteria  for the alternatives include both  ability to
remedy existing water quality problems and  prospects of protecting water
quality in the future.   This  first criterion was  applied in  the  analysis
of  surface and  groundwater   impacts  of  the  alternatives  presented in
Chapter  IV.   That analysis assumed  that the collection, treatment and
disposal   units   of  each alternative  would operate  effectively  as
designed.   The   second  criterion   recognizes  that   all   structural,
mechanical  and  electrical facilities are subject to failure.  Types of
possible  failures and  appropriate  remedies  and preventive measures were
reviewed  for selected components of the alternatives.

d.   Flexibility

     The   capability   of  an   alternative  to   accommodate  increasing
wastewater flows from future  development  in the Proposed Service Area is
referred  to  as  its  flexibility.   In order to demonstrate  the  relative
levels  of investment  for different alternatives, all  were  designed and
costed  to provide service for  the  same population  --  the  design  year
population projected in Chapter II.  However,  factors  such  as the amount
of  land  that  could  be  developed using on-lot  systems  or the ability to
increase  the capacity  of a  treatment plant  might  have a  significant
effect  on future development  in the  Study Area.   The  capability of the
alternatives  to  accomodate  increased wastewater  flows is  reviewed in
Chapter  III.  The effects of the alternatives' flexibility  on population
growth are predicted in Chapter IV.
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                              CHAPTER  II
                        ENVIRONMENTAL  SETTING
INTRODUCTION

     The abundant water  resources  and  their many recreational  opportun-
ities make the  Crystal  Lake  Study Area a pleasant place  to  live  and  an
inviting vacation spot.

     The centerpiece  of the  region  is  Crystal Lake, more than 8  miles
long, very deep and very clear.   Framed by wooded morainic cliffs,  it  is
one  of  the  major scenic  attractions  of  northern  Michigan.  The  sur-
rounding landscape ranges  from  sand  dunes and rolling terraces to  steep
hills and  ridges rising 300  feet  above lake level.   Marshes  and  (wet)
woodlands are home to a  variety of animal and plant  life.   The  Lake is a
notable cold water fishery, "managed" for game fishing.

     Part  of the  free-flowing  Betsie  River,  which  passes  through the
Study  Area,   has merited  designation  by  the State  of  Michigan  as   a
"natural river,"  and  preservation  of its aesthetic values is thus  safe-
guarded.  The link between the  River and Lake Michigan is Betsie  Lake,
which is  not only an important recreational  asset  but  also  furnishes
harboring,  docking and mooring for Great Lakes shipping.

     Lake Michigan, which  moderates  weather and  climate in the area and
brings  commerce  to   its  port,  offers  more recreational opportunity.

     Still another outstanding  resource  is  Round Lake and its  environs,
which have been  included in  the Sleeping Bear Dunes  National  Lakeshore
Park.

     The original  hardwood forests have long since been  logged.   Early
settlers cleared the  land, and agriculture predominated in the  region
for  many years.   Today  there are  patches of woods,  and  prime agricul-
tural land  in row crops or  orchards,  but now agriculture employs  only
7.2% of the  permanent population.   The largest single employer is  Pet,
Inc., but  service and  retailing,  oriented  largely  toward vacationers,
are the major occupations.

     The  Crystal Lake  area  is a well-established   recreation center.
Boating, swimming, sailing and  water skiing are  popular,  as  is fishing.
The  Betsie River,  a  year-round  fishing stream, is a  spawning ground for
trout and salmon and  contains other game species as  well.   Just  to the
north  are  a  fine salmon  fishery  and  a  wilderness  area, and  wildlife
offers recreation to  both  hunter and observer.   Hang gliding,  other air
sports and, in the winter,  nearby skiing add to the  diversity of recrea-
tion available.

     The Study  Area   also  serves as a  gateway and  a service  area for
visitors to these other  recreational  attractions  as  it lies between them
and  major population  centers  to the  south.   It is a  role  that  is  likely
to  grow,  expecially  with  the planned  expansion  of  facilities for the
Sleeping Bear Dunes Park.

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     The vacation population  now approaches,  and may surpass the  Study
Area's year-round population  by  the  end of the century,  when a  total  of
12,000 is projected.  The  only city in the area, Frankfort,  had a per-
manent population of 1,822 in 1975.   No income data  are  available on the
seasonal population, but information on Benzie County indicates  that the
range of incomes of the permanent population  is below the State average
while the  proportion of  retired or  elderly persons is  higher  than the
State average.   Throughout  the  area,  residential  structures  are  pri-
marily single-family dwellings.

     Evaluation of  the  courses of action open to EPA must start from  an
analysis of the existing situation.   This chapter offers  an inventory  of
baseline conditions, divided into such categories as soils, groundwater,
surface water,  and  biology.   Social  and economic aspects of the  human
environment are discussed, as is  the functioning of  wastewater treatment
facilities presently in operation.

     Use was  made  of existing data,  but it was necessary to undertake
additional  field  work  in  order to  obtain better  information and  to
resolve  such  key  issues  as  the need to  sewer Crystal  Lake's  entire
shore.   The new  studies  included:   a sanitary  survey;  a  sampling  of
leachate plumes from  nearby septic  systems; an aerial survey of visible
septic  tank malfunctions;  a soils survey;  estimation of  nutrient  loads
entering Crystal Lake; and modeling of the Lake's eutrophication status.
In general, data given  in the tables  are  not  repeated  in the text, and
readers wishing  more information should  use  the Appendixes  for fuller
explanations and details.

     Research has  revealed striking contrasts between Crystal  Lake and
Betsie  Lake.   The  watershed  acreage  that  drains into  Crystal   Lake  is
only twice  as  large as  the surface area  of that lake;  for Betsie Lake,
this  ratio  is 627:1.   Similarly,  it  is  estimated  that  water  entering
Crystal Lake  remains  for 63 years,  but water  entering Betsie Lake flows
out  within  2  days.   Although its depth  and  water  retention time make
Crystal  Lake   a  "nutrient trap,"  and  although there   are  some  algal
growths near  portions of  the shore,  its  quality is  excellent.  Betsie
Lake, despite its heavy outflow, is eutrophic,  and  it may be difficult
to correct this condition.
A.   PHYSICAL  ENVIRONMENT

1.   PHYSIOGRAPHY

     The landscape of the Crystal Lake Area has its origin in the events
of  the  glacial age  that  shaped the entire northern part  of  the United
States.  The major  features  in the Study Area  that  were formed by that
glaciation are the following:

     o    Lake  Michigan  --   the  area's  western  boundary.   Mean  lake
          elevation is 580 feet above mean sea level (msl).

     o    Crystal Lake -- the center of the Facility Planning Area,  with
          a  surface area  of approximately 9700  acres.   It  is  roughly
                                    26

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          rectangular in  shape.   Its  long  axis is 8.14  miles,  running
          northwest to southeast.

     o    Lake-bed  sands,  outwash*  materials,  sand  dunes and  exposed
          lake  terrace  --  primarily  to  the east  and  west of  Crystal
          Lake.  Relatively  narrow lake  terraces  are on  the  north and
          south shores.

     o    Morainic hills and  ridges  -- north and south of Crystal Lake.
          With  elevations  of  over 900  feet above msl,  the  hills  and
          ridges are  the highest  points  in the Study  Area.  Some slopes
          in moraine areas exceed 30%.

     o    The Betsie  River  --  to  the  south  of  Crystal  Lake.   The River
          widens  into  Betsie  Lake  prior  to  entering Lake  Michigan.

     Other features  of  the  area  include the broad, flat  floodplains of
Round Lake, Long  Lake,  and  Rush Lake  to  the north of Crystal Lake.  At
one time a pond was formed in the floodplain of the Betsie River, in the
southeast  corner  of  the  Study Area,  by  construction of  Homestead Dam,
but it disappeared when the dam was removed.

     An interesting  feature  of the Crystal Lake shoreline  is  the sandy
lake  terrace  on the  north and south,  which was exposed  in 1873 by the
inadvertent lowering of the  water level, thereby providing a strip of
land on which roads and houses have been built.

     The  town  of Beulah  lies  on  the  lake-bed  sands  and  outwash plains
east  of Crystal  Lake;  there  is  also agricultural use.   The  towns of
Frankfort  and  Elberta  are  located in relatively  level areas  north and
south  of  Betsie  Lake,  and  the  rolling  topography  of the dunes area
between Crystal Lake and Lake Michigan  has  also  attracted residential
development.  Benzonia, at  the southeast  corner of Crystal Lake, is the
only major area developed on the moraines.

     The entire Study Area is drained by the Betsie River, which empties
into Lake Michigan through Betsie Lake.

     Topographic relief of the Study Area is illustrated in Figure II-l;
topographic  features that  are sensitive  to development,  e.g., slopes
greater than 15%, are identified there.

2.   GEOLOGY

     Sediments   of   glacial   origin,  characterized  by   sandy,  hilly
moraines,   alluvial  and  eolian  sands,   and  glacial  outwash  overlie
Devonian limestones and shales in the  Study Area.  The bedrock limestone
of  the  Traverse formation  generally borders Lake  Michigan and  is ap-
proximately 1700 feet thick (see Figure II-2).  It underlies most of the
Study Area, extending to the eastern limit of Crystal  Lake.  Immediately
east  of the  Traverse  limestones  and lapping  over them  are  the black
Antrim  shales  which  average  as  much  as  100 feet  in thickness (Martin
1957).  The surficial geology of the Study Area is shown in Figure II-3-
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3.   SOILS

     The  soils  in Benzie  County were  formed  primarily from materials
deposited by glaciers.   The major soil  associations  shown in Figure II-4
generally reflect  the  surficial geology  carved  during glacial advance
and retreat.  The  characteristics  of  these  associations are as  follows:

     o    Nester-Iosco-Emmit  Association  —  Well  to  intermediately
          drained  shallow  loams  and   sandy  loams  developed  along the
          Betsie River floodplain.

     o    Wexford-Emmit-Kalkaska Association — Well drained, deep, dry
          sands on the sand moraines in the  area.

     o    Kalkaska-Rubicon  Association -- Well drained, deep, dry  sands
          on outwash plains to the east of Crystal Lake.

     o    Eastport Association  --  Poorly  drained, deep sands  character-
          ized by high water table and occasional  pockets of peat accumu-
          lations .

     o    Bridgeman  Association --  Well drained,  very deep  dune and
          lacustrine sands  developed  along  the lake Michigan shoreline
          west of Crystal Lake.

a.   Soils   Suitability  for  Septic  Tank  Absorption  Fields

     Suitability of  soils  for septic tank  absorption fields  is  based
primarily on slope, permeability, depth to seasonal  high water table and
hydraulic  conductivity.   The  role  of  these  factors  in determining
whether or how well effluent can percolate through the  soil is discussed
in Appendix A-2.   Appendix A-3 shows  ranges for  these parameters  which
place slight, moderate  or  severe limitations on soils for on-site dis-
posal systems.

     The  Soil Conservation  Service (SCS)  is currently  in the  process  of
performing a soils survey for Benzie County.   The  SCS has indicated that
currently  available  information  on  soils  is   limited  in  scope and
accuracy  and  should  be used  for  general  planning purposes  only  (by
letter, Steve Utic,  SCS).   A discussion of  the available soils  data can
be found in Appendix A-l.

     In order  to provide  a  general indication of  soils suitability  in
the Study Area,  the SCS used  the existing  soils  data to  formulate the
Land  Resources  Inventory  Map  (1972)  shown  in  Figure II-5.   The SCS
emphasized  that  the  existing  data  are  neither   complete  nor  very
accurate.

     The  Land Resources Inventory Map shows  extensive  areas  that are
limited in suitability by slopes (S) ,  wetness, (W) and  slow permeability
(T).   Soils designated  "L" on Figure II-5 are most  suitable  for on-site
systems or  cluster  systems.   Generally these soils  have slopes of less
than  12%  and  rapid permeability, but some wet soils and steeply sloping
soils  are known to  be  present.   "L"  soils  appeared to be  suitable  for

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cm-site systems provided that 1) these systems were not located on steep
slopes  or  wet soils  or 2)  systems  were designed to  account  for these
limitations.  Since the extent and location of these wet and steep soils
were not known, EPA requested that SCS field check selected "L" soils to
determine their  suitability  for on-site systems along the shoreline and
on land with a minimum set back distance of 100 feet from shore.

     Sites set back from lake.   The  "L" type  soils  included  suitable
sites for  cluster  systems  on land set back  from  the shore.  Within the
"L" soils were  found  scattered areas with steep slopes, particularly to
the north  of Crystal Lake.   Pockets  of wet soils were  also  found,  but
they are rare  and  mostly limited to  the area  adjacent to the southeast
shore (by letter, R. Larson SCS, I December 1978).  Steep slopes are the
major soils  limitation for  on-site  systems located more  than  100 feet
from the shore.  These  soils could be used  for on-site or cluster sys-
tems provided that the systems were designed to prevent sidehill seepage
of effluent.  On sloping  ground, drop boxes in a serial system provided
the best method of distributing the effluent.

     Shoreline Sites.   Soils borings taken by the SCS in Autumn 1978 (by
letter,  R.  Larson,  1 December 1978) from shoreline sites showed that all
74 sites  sampled were  unsuitable  due to  a seasonal  high water table,
although for some  sites,  a  hazard  to  nearby  water supplies  or slow
permeability were the  limiting factors.   Figure II-6 shows the approxi-
mate location of the  soil  borings and the  specific  limitation for each
site.   Table II-l summarizes the results by township.

     The Health  Department,  however,  has found that soils  on  over half
of  the  vacant   lots  in  the  Proposed   Service  Area  evaluated  between
1972-1977 were suitable  for  septic tanks.  The distribution of suitable
sites in the lakeshore townships is also shown in Table II-l.

     In general, suitability  was limited by depths to the seasonal high
water table  (<4  feet).   Less frequently, poor  permeability due  to high
clay content was the limiting factor (Sections 15, 16 and 21 of Benzonia
Township and Sections  15  and  19 of  Crystal  Lake  Township)  (GT-L-BHD
December 1977)

     The SCS and the  Health Department  use  somewhat different criteria
in determining soils suitability.  The Health Department does  not. deny a
permit  application  for a  septic tank on highly  permeable soils.  SCS,
however, considers  highly  permeable  soils to be  a  severe  limitation if
the systems  are  located near operating wells.   However, this  difference
alone does  not  account  for  the large discrepancy between SCS  data and
the data from the Health Department.  Most of the sites determined to be
unsuitable by SCS  had a seasonal high groundwater table; this is an im-
portant criterion used by the Health Department, as well.  The SCS indi-
cated that  the  seasonal high water table was  difficult to determine in
many  instances;  since Crystal  Lake  was  lowered  some 100  years  ago,  a
natural soils profile has not had sufficient time to develop (by letter,
R. Larson 1978).  Therefore,  one explanation for the discrepancy may be
that the seasonal  high water table may  not  be as high as was suggested
to SCS in their  surveying.
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                                 Table II-l

           SOILS SUITABILITY FOR ON-SITE SYSTEMS AROUND CRYSTAL LAKE


 SCS Ratios of Selected Lakeshore Site Soils  (See Figure II-6):
   Township
Seasonal High Water Table   Limitations for Other Sites
Benzonia
   North Shore
    South  Shore

 Crystal Lake



 Lake  Shore
   11 out of 15 (73%)


    4 out of 4 (100%)

   22 out of 38 (58%)



   12 out of 17 (71%)
All others pose a threat to
nearby water supplies
Steep slope, slow percolation
and hazard to nearby water
supply

All others pose a threat to
nearby water supplies
By letter, Richard L. Larson, Soil Scientist, SCS, 1 December 1978.
 Grand  Traverse  -  Leelanau  -  Benzie District Health Department  Evaluation  of
 Site Suitability  for  On-Site Systems  1972_- 1977:
Benzonia
Suitable
Unsuitable
Total
8
22_
30
(27%)
(73%)

Crystal Lake
22
_4
26
(85%)
(15%)

Lake
9
5
14
(64%)
(36%)

Total
39 (56%)
31 (44%)
70
By phone, W. Crawford,  Sanitarian,  GT-L-BHD.   28 July 1978.
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     Despite the  extent of unsuitable  soils  along the lakeshore, very
few existing systems  experience  the problems  that might be  anticipated
from unsuitable soils.  (See Section II.C for  discussion of this point.)

b.   Soils Suitability for Land Application

     Major soils  characteristics limiting  land  application include per-
meability,  depth  to  groundwater  and  slope.   Soils  suitability varies
with the  type  of  land application  process  (rapid  infiltration, overland
flow or slow rate);  Appendix A-4 shows suitable  soil  characteristics  for
the  major  land   application  processes.   Based  on the  Land Resources
Inventory  Map  (1972)  (Figure II-5)  the  most suitable  soils are those
designated  "L",  the nearly level  well drained,  sandy  soils.   SCS  (by
letter, R.  Larson,  SCS,  1  December  1978) performed  a  soils survey on
potential  land application  sites in "L"  type  soils of Crystal Lake (see
Figure  II-7  for   site  locations).   The survey indicated that the soils
were sands  and loamy  sands,  with a seasonal high  groundwater table more
than 6.0  feet  below the ground  surface.   The  survey  also indicated that
these  soils  were  rapidly permeable  and  may  be  more suitable for rapid
infiltration than spray irrigation.  Further on-site  testing  would be
required  to confirm  the  suitability  of these   soils.   Steep  slopes
located  on these  sites would  require extensive  earthwork  to  be made
suitable.   Therefore,  application  sites  would  be limited to  level  or
slightly sloping areas.

c.   Prime Agricultural  Lands

     The  Soil  Conservation  Service,  of the United States Department of
Agriculture, has  set  forth  general  guidelines for a  national program of
inventorying prime  and  unique farmlands  (SCS  1977).  Prime and unique
farmlands  have been designated  as  those  lands which  can produce present
and future food and fiber supplies  with the least  use of energy, capital
and labor  and  with  minimal  environmental impact.   Figure II-8 shows  the
extent of prime agricultural lands  within the  Study Area.

4.   ATMOSPHERE

a.   Climate

     Lake Michigan has a very decided effect upon  the area's  weather  and
climate.   The prevailing west and  southwest  winds tend  to moderate  the
temperature, resulting  in warmer winter temperatures and cooler summer
temperatures than occur further  inland.   Precipitation also is moderate.

     Climatological data collected  in Frankfort  are sparse, so data from
the nearest US  weather station,  in  Manistee, Michigan, 30 miles south of
the Study Area,  were also  utilized  in  developing the  temperature and
precipitation normals, which are  given in Table  II-2.

     Summer  temperatures  often reach 90°F during July and  August but
very  seldom rise above  it.   Winter  minimum  temperatures  are  commonly
                                    37

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below 20°F.  The mean  date  for the last freezing temperature  (32°F)  is
May  15,  while  the  mean  date  for   the   first  32°F   temperature   is
October 10.  The growing season lasts  approximately  150  days.

     During  the  summer  months,   precipitation  occurs  primarily   as
scattered  showers   and  thunderstorms.   Annual   snowfall   averages   75
inches, with  one inch  or  more of  snowfall  occurring at least 30 days
during  the  year, according to  the US Geological Survey (USGS)  (1970).
Mean  annual  relative  humidity is  70%,  and the mean annual  dew point
temperature is  37°F (USGS  1970).   Prevailing wind directions and speed
are shown in Table  II-2.

b.   Noise

     Outside of  highway or  road noises  and motorboat noises, the Study
Area has no known intensive noise sources.

c.   Odors

     Inasmuch as no letters from local residents  complaining about odors
have been  reported, it is  assumed that no objectionable odors of long
duration  are  present  in  the  Study Area.    During  the   recent  sanitary
survey  (University  of  Michigan  1978)  six  of  the  249 residents inter-
viewed mentioned odor  problems  of short duration  associated with ST/SAS
operation during wet weather or heavy  use of their systems.

d.   Air  Quality

     The  State  of  Michigan  does  not  maintain monitoring sensors   in
Benzie County, but  data  collected at  nearby stations  in Manistee County
and  Wexford  County  indicate  that  the   air  in the  County is  of high
quality and that National  Ambient Air  Quality Standards  (Appendix B) are
being met.

     Benzie County  is  part of  the Upper  Michigan  Air   Quality Control
Region.  Maintenance  of the air  quality within the  County is the re-
sponsibility of  the DNR's  Air  Quality Division,  District Office No.  9,
in Cadillac.
B.   WATER RESOURCES

1.   WATER QUALITY MANAGEMENT

     Water resource management  is  a  complex of many elements, in which
the Federal government, the State and the locality all  have  an interest.
To  name  just  a few of  these  elements  --  irrigation, municipal water
supply, maintenance  of navigable  waters  and protection of the  produc-
tivity of  the soil  -- illustrates the broad range of  activities under
this  heading.   Among  the  most  important,  however,  is preservation  or
restoration of the quality of US waters.   In the  Federal Water Pollution
Control Act (PL 92-500, 1972) and the Clean  Water Act that amended it  in
1977  (PL  95-217)  Congress  outlined a framework  for comprehensive water
quality management  which applied  to  groundwater as well as  to  surface
waters.

                                   41

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a.   Clean Water Act

     Water quality  is  the responsibility of the United  States  Environ-
mental  Protection Agency  (EPA)  in  coordination  with the  appropriate
State agency,  in  this  case the Michigan Department of Natural Resources
(DNR).   However,  with passage  of  the  Clean  Water  Act,  all  Federal
agencies were  instructed  to  safeguard  water quality standards in carry-
ing out  their  respective  missions.   As the lead agency,  EPA coordinates
the  national  effort,  sets  standards,  and  reviews  the  work of  other
agencies, some of which are assigned responsibilities in line with their
traditional  missions.   For example, the  Army Corps  of  Engineers  main-
tains its  jurisdiction over dredging permits in  commercially navigable
waters  and  their  adjacent wetlands  and in coastal waters but  now must
also  consider  water quality.   The Coast  Guard keeps its  jurisdiction
over oil spill cleanup.   The Act officially draws  certain  other agency
activities  into the water pollution control effort:   for  example,  it
authorizes Federal  cost-sharing  in agricultural  projects   designed  to
improve  water  quality  by  controlling  farm runoff.  In the  case of the
Soil Conservation  Service (SCS),  these new responsibilities may  be  in
addition to,  or as the case may be,  may dovetail with  SCS  programs  to
reduce  soil  erosion,  or to construct headwaters  impoundments  for  flood
control.

     In delineating the responsibilities of the  various levels of govern-
ment  for water quality,  Congress  recognized the  rights of  the States
with regard to their waters.   It authorized aid  to the States in funding
the development of  plans  for control of pollution, development of State
water  quality   standards  (which may  be  more  restrictive  than  Federal
standards),  and research.   When  a  State meets  certain  criteria,  it  is
certified by EPA  as the  entity responsible  for  administration of the
activity in  question.   The EPA may deny certification, and in all cases
it  retains  power  of  enforcement  of   established  standards,  State  or
Federal.   The  State of  Michigan is one  of the  states  which  has been
granted certification by EPA.

     Among the goals and deadlines set in the Clean Water Act are these:

          "it  is the national goal that the discharge of pollutants into
          the  navigable waters be eliminated by  1985...

          "an  interim  goal of  water quality which provides for the pro-
          tection and  propagation of fish,  shellfish, and  wildlife and
          provides  for  recreation in  and  on   the  water   [is  to]  be
          achieved by July 1, 1983".

     This  landmark  legislation  requires  that publicly  owned  treatment
works  discharging  effluent  to  surface  waters  must  at least  provide
secondary  treatment,  i.e., biological  oxidation of  organic  wastes.  It
directed  that  municipalities  must provide the  "best  available  tech-
nology"  by  1983 and that in  appraising  their  options  localities must
address  both  the  control  of  all major  sources  of stream  pollution
(including combined  sewer overflows and  agricultural, street  and other
surface  runoff) and  the cost effectiveness of various control measures.
The use of unconventional technologies must also be considered.

                                    42

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     The  key  provisions  on  water  quality planning  stipulate  that to
receive aid a  State must provide a continuing  planning process.  Part of
Section 208 requires the  States to inventory all the sources of pollu-
tion of  surface  and ground waters,  both point* and non-point*, and to
establish  priorities  for  the   correction  of  substantial water quality
problems within a  given area.   The 208 plans  are intended  to provide an
areawide and,  taken together,  a statewide, framework  for the more  local
decisions on treatment  facilities.

     Section 201  of the  Act  (under  which the Crystal Lake area appli-
cation for funds was made)  authorizes EPA to make  grants  to localities
toward the  improvement  or construction  of facilities for treatment of
existing water quality  problems.   EPA may determine whether an  Environ-
mental Impact Statement  is  required  on a proposed project (see Section
I.B), and  even where the State has been certified and assumes responsi-
bility for  water  quality, EPA retains authority  to  approve  or reject
applications for construction  funds for treatment facilities.

     The local political jurisdiction has traditionally been responsible
for  meeting  the  wastewater  treatment  needs  of  the  community.   Local
jurisdictions  now  have  the benefit  of Federal and State  assistance in
meeting water  quality standards and goals.

b.   Federal Agency  .Responsibilities   for  Study Area  Waters

     EPA

          Administers the Clean Water Act

          Sets Federal  water quality standards

     EPA Region V

          Administers the  grant program  described  above for the  Great
          Lakes Region.

          Provides partial  funding for preparation of the Crystal  Lake
          Area Facility Plan.   Region V's responsibilities in  the  con-
          struction grant program in general and specifically toward the
          application made in the Facility Plan are discussed in Section
          I.B.

     US Army Corps of Engineers

          Controls dredging and construction  activities  in commercially
          navigable  streams,   their   100-year  floodplains  and  adjacent
          wetlands through a permit system.

     US Department of Agriculture

          Under the Rural  Clean Water Program will provide cost sharing
          for  soil  conservation  practices  designed to improve  water
          quality.   (This program  will  probably  be  assigned   to  SCS.)
                                    43

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     Soil  Conservation Service  (SCS)

          Agency's mission is to control wind and water erosion, to sus-
          tain the  soil  resource base and to  reduce  deposition of soil
          and  related pollutants into the water system.

          Conducts soil  surveys.  Prepared Land Resources Inventory Map.
          Drew up guidelines for inventorying prime  or unique agricul-
          tural lands.

          Works with farmers and other land users  on erosion and sedi-
          mentation  problems

          Gathers  information at the county level as part of program of
          study and  research  to  determine  new methods  of eliminating
          pollution  from agricultural sources.

          In the Study Area  has performed some stream bank stabilization
          on the Betsie  River  and built a sediment basin (trap) in Cold
          Creek  approximately  300  yards  upstream  from  the  Creek's
          entrance to Crystal Lake.

     Fish  and  Wildlife Service

          Provides   technical  assistance  in  development  of  208 plans.

     US Geological Survey

          Has   in the past  monitored surface  water  flows  in the Betsie
          River but  does not do so in the Study Area  at present.

c.   State  Responsibilities  in the  Crystal  Lake  Study Area

     Pertinent Michigan  Laws

          Environmental  Protection Act  (P.A. 127 of 1970).  Provides for
          legal action  by  the Attorney General or  any person or legal
          entity for protection of the  air,  water,  and  other natural
          resources  and  the  public trust therein.

          Natural Rivers Act of 1970 (P.A. 231 of  (1972).   Protects the
          public trust in Michigan inland lakes and streams and protects
          riparian  rights.    Is implemented  at the  State  level.  For  a
          discussion of  pertinent provisions,  see  Section II.E.4.

          Soil Erosion and  Sedimentation Control Act  (P.A.  347 of  1972).
          Provides  for   control of soil erosion and sedimentation.   (See
          Section II.E.4 for discussion of provisions.)  Is administered
          at  the  county level.  The Soil  Conservation district admini-
          sters the  Act  in  the  case  of  agricultural activities.
                                   44

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     State Agencies

     Department of Natural Resources (DNR)

          Is  responsible  for establishing  water quality  standards  for
          the surface waters of the State appropriate to several classi-
          fications, and  for  regulating  discharges  of waste that affect
          water quality,  including those from  sewage treatment plants.
          (See Appendix D-l for classification of Study Area streams and
          lakes  and Appendix  D-2  for  associated  water  quality  stan-
          dards . )

          Has  authority  to issue  permits to discharge  pollutants into
          surface waters  under the National  Pollutant Discharge Elimi-
          nation System  (NPDES).   The  Water Resources Commission,  which
          reports  to DNR,  sets  permissible  discharge  levels  and  may
          approve applications  for permits.   Details of permits granted
          to  Frankfort City  and  Elberta for  discharge  of  wastewater
          treatment effluent  to  Betsie  Lake and to Beulah are contained
          in Appendix D-4.

          Administers Natural  Rivers  Act.  DNR  has  issued zoning  regu-
          lations for the Betsie River Natural River  (see Appendix D-3)
          and has, with citizen participation, devised a management plan
          for that River.

          Administers Inland Lakes and Streams Act.

     Northwest Michigan Regional Planning and Development Commission

          Has  prepared  a plan  for Michigan's Region X,  which includes
          the  Crystal  Lake Study  Area,  with guidance of EPA  and DNR,
          pursuant to Section 208 of the Clean Water Act.

     "Clean Waters - A Water Management Plan for Northwest Michigan" has
been approved  by  the State, subject to  conditions  centering  around the
need for more  work.   Within Benzie County, Betsie  Lake  was rated first
as a  "plan of study  area," a higher priority than  assigned  to Crystal
Lake because  the  former  is eutrophic and because of the extensive work
done on  the latter  (including  this EIS).  The  Commission was named as
Coordinator for Lake Management Activities in the region.  It works with
lake associations and develops tools to help them assess the problems of
their lakes.   The  Commission  plans some groundwater assessment and also
some work on non-point sources of nutrients -- agricultural, stormwater,
duck feeding, excessive lawn fertilization,  and on-site systems.

     Michigan Department of Public Health

          Has  authority to  regulate on-site sewage disposal systems and
          makes  initial   determinations   on  subdivisions,  campgrounds,
          pr*mnn£» voi a 1 rl£»\r*=»1 r»rtm£>nt~ c  £*fn
          commercial developments, etc.
                                    45

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d.   Local  Agencies
       Grand Traverse-Leelanau-Benzie District Health Department
      (6T-L-BHD)

            Has authority to  regulate individual residential on-site waste
            disposal systems.  Has  authority delegated by the State Health
            Department to  regulate  non-residential  on-site disposal sys-
            tems.

            See Section II.C.3 for discussion of sanitary code applicable
            in the Study Area.

       Frankfort City, Beulah and Elberta

            Own and operate municipal wastewater treatment plants.  Types,
            conditions and operations of these facilities are described in
            the Crystal  Lake  Area  Facility Plan  and in Sections I.A.3.a
            and b, above.

       Benzie County

            May enforce  Soil Erosion  and Sedimentation Control  Act for
            non-agricultural  activities
  2.   GROUNDWATER USE

  a.   Municipal  and  Individual Use

       The public water supplies  for  Frankfort  City, Elberta, Beulah, and
  Benzonia are obtained from  wells, which tap the  groundwater in the sand
  deposits  of  the  glacial  moraine.   The supply  of  water  is  more than
  adequate to serve  domestic  needs  through the  year 2000.   (Wilbur Smith
  and  Associates  1974).   However, the  County  Development Plan indicates
  that the  existing water  supply  systems are  inadequate with respect to
  distribution capabilities and storage  capacity for emergency situations
  and  future population demands  (Wilbur Smith  and  Associates 1974).  The
  number of wells and the  capacity of  the holding tanks  for municipalities
  in the Study Area are shown in Table II-3.
                                      46

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                              Table  II-3

                 MUNICIPALITIES USING GROUNDWATER FOR
                  DRINKING SUPPLIES  IN THE  STUDY AREA

                                       Depth  of Wells      Capacity of Holding
Municipality       Number of Wells         (feet)           tanks (gallons)

Frankfort city           2              70  and 100          2 tanks -
                                                           60,000
                                                           and  125,000

Elberta                  2              70                  1 tank -
                                                           capacity
                                                           unknown

Beulah                   1              150                1 tank -
                                                           50,000

Benzonia                 2              125                1 tank -
                                                           35,000

                              By  telephone,  28  July  1978, Mr. William
                              Crawford, Sanitarian,  GT-L-BHD.


  f  Annual pumpage for  the  city of Frankfort was reported to  be 102 x
10  gallons in  1976  with a daily maximum of  607,000 gpd  (Huffman 1977).
Pumpage records for the other municipalities  were  not  available.

     Most of  the  residents  around Crystal  Lake have individual  or group
wells.  There  are several  community well  systems along  the  south and
southwest shoreline and  two  community systems  on the north side of the
lake  (GT-L-BHD December 1977).

b.   Industrial

     Pet, Incorporated,  located  in  Frankfort City,  owns wells  that tap
local groundwaters for food processing operations.  During the peak food
processing months Pet,  Inc.  uses from 40,000 to  56,000  gallons  of water
per day for processing fruit.  (Williams  and  Works  1976).

c.   Irrigation

     Orchard owners and farmers in the area tap the  groundwater  aquifers
to irrigate their  orchards  and fields during drought conditions and to
provide  suitable drinking  water for  their  livestock.   The  amount of
groundwater used for these purposes  has not been  determined.

3.   GROUNDWATER HYDROLOGY

     Groundwater in the  Study Area  is found  under both water table and
artesian conditions.  Under  water table  conditions  no upper impermeable
                                    47

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confining layer exists  above  the aquifer.   Precipitation and wastewater
is  therefore  free  to  percolate  downwards  through  the  soil  to  the
saturated zone  in the aquifer,  the  top  of which is known as  the water
table.  However, under  artesian  conditions an impermeable layer such as
clay  overlies  the  aquifer,   confining  it  and  effectively  sealing  out
percolating waters  immediately above it.   Because artesian aquifers  are
confined, top  and bottom,  the water in them  is  under  pressure and will
rise  in  wells  to levels  above the top of  the aquifer,  sometimes above
land  surface.   Wastewater applications to  land  over aquifers  therefore
pose  threats to  water table aquifers,  but  generally not  to artesian
aquifers.

     Water  table  and  artesian aquifers  within  the  Study Area  are  not
clearly delineated.   As is customary in glacial deposits, except outwash
plains,  confining clay layers are irregularly distributed in  the Study
Area.  These layers may be thick and extensive in  some  areas but thin
and  of limited  extent in  others.   No  detailed  studies of  the local
aquifers  and their  characteristics  have been undertaken.  However,  the
Health  Department  reports  "The drinking  water  aquifers  in Benzonia
Township, for  the most part,  have at least a 10-foot clay barrier.  The
Crystal  Lake Township  and Lake Township  well  logs often  indicate no
protective  over-burden,  and wells of  generally  less depth."  (GT-L-BHD
December 1977).

     Since,  in most instances,  drillers  have not been recording pumping
rates  and  water  levels on well logs, the specific capacities  of  the
wells are generally unknown.  Well yields as reported by Leverett et al.
(1907) are  very  small, less  than 10 gallons per minute (gpm) except for
a  very  deep  well  (2200  feet)   in  Frankfort  which  yielded 480  gpm.
Limited data on  recent well  logs supplied  by  the  Benzie Health Depart-
ment indicate yields up to 15 gpm.   The moraine deposits of the area are
probably  poorly  sorted angular  materials  varying  in  size from boulder
through  gravel  and sand  to   silt   and  clay with  resulting  low water
yields.   The outwash   deposits  to the southeast of the  Study Area are
likely  to  be  better   sorted  with  consequently  higher  yielding wells.

     The  average depth and  the   range  of  depths  for  the wells  in  the
various lakeshore areas are shown below.

                                              Depth  (ft)
     Township (s)	Location	Range	Average
     Lake              Northwest         20-350          81

     Lake/Crystal      West              20-159          67
     Lake

     Crystal Lake      Southwest         30-313          68

     Benzonia          Southeast         27-160          69

     Benzonia          Northeast         10-166          47

                                    (University of Michigan 1978)
                                    48

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     Evidence  of  some  hydraulic  continuity  of  the  aquifer(s)  with
Crystal  Lake  exists  in the  form of underwater  springs  in the  north-
eastern  part  of  the lake  (Gannon  1970).   Based  upon  the  location  of
groundwater plumes entering Crystal Lake mainly on the northeastern and,
to a lesser extent the southeastern shores, Kerfoot (1978) has  suggested
the  flow pattern shown  in Figure  II-9.   He  proposes that  groundwater
levels to  the  east  of the lake are  higher than the lake  level which is
in turn  higher than  groundwater  levels west  of the  lake.   The general
direction  of groundwater  flow is  therefore into the lake  at the eastern
end and out of the lake at the western end.

     The depth to groundwater and the thickness and extent of  confining
or protective  clay  layers are important factors  in  determining ground-
water yield and  protection of groundwater quality.  The hills  that sur-
round Crystal  Lake  consist of loosely consolidated drift  with  irregular
beds of clay.   Clay layers are thin and irregular at high  elevations and
thick at lower elevations  (Leverett 1907).  As was  indicated in Table
II-3  the municipal  wells  in  the  hillside  townships  are  generally deep
and the water table in these morainic regions  is at a low  level.

4.   GROUNDWATER QUALITY

     The natural groundwater  quality in the Study Area was investigated
by Leverett  (1907).   Well water is generally very hard,  ranging as high
as 360  ppm (CaCO ).   Maximum chloride concentraction is  about 34 ppm,
and  iron is generally  absent from the water.  The  water supplied from
these wells is excellent for drinking but is not good for  laundry unless
softeners are used.

     More recently,  studies were undertaken by Gannon (1970) and Kerfoot
(1978)  to  learn  whether  groundwater  supplies were  being contaminated
with  leachate  from  septic tanks.   Gannon et  al.  (1970)  surveyed 165
wells around  Crystal Lake  for total and  fecal coliforms  and nitrates
(NO ).  The final results showed that all wells tested were negative for
coliforms.   Forty-three  wells tested positive  for nitrates; twenty-two
of these showed  nitrate-nitrogen  levels  greater  than 2  milligrams per
liter  (mg/1),  six showed  levels  greater than 4 mg/1, and one exceeded
the  US  Public Health  Service Drinking  Water  Standard of   10  mg/1.
Although the samples that tested positive were evenly distributed around
Crystal  Lake,  "a  significantly  higher percentage  of  the  north shore
samples  had  nitrate-nitrogen  concentrations  greater  than  2  mg/1."
(Gannon  1970)    All   samples  whose  concentrations  of nitrate-nitrogen
exceeded 4 mg/1 also came from the north shore.

     A follow-up survey of the north shore wells was subsequently under-
taken.   Locations whose  concentrations  of  nitrate-nitrogen exceeded 1.0
mg/1  in the  preliminary  study were sampled.   Figure  11-10  shows the
average  and maximum  concentrations  for  sampling  points with highest
levels of  nitrates.   The  locations  of highest concentrations correspond
to areas of high population and high ST/SAS  density, suggesting a cor-
relation between population density and high nitrate levels.   Only two
samples, however, showed nitrate levels that equalled or exceeded
                                    49

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                            HEAVY ARROWS INDICATE DIRECTION OF FLOW
              Source:  Kerfoot 1978
                   OVERVIEW OF GROUNOWATER FLOW
                 ARROWS INDICATE  DIRECTION OF FLOW
        .ALTERED GRADIENT
NATURAL GRADIENT
L. MICK /..Il'^^^cr - - c
             V  ALTERED
              ^ GRADIENT
              VERTICAL SCHEMATIC OF GROUNDWATER FLOW
                    (VERTICAL SCALE  EXAGGERATED)


        Figure II-9:    Groundwater Flow  Patterns for Crystal Lake
                                   50

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51

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the  Drinking Water  Standard.   The generally  low  levels  of  nitrates
elsewhere  indicate  that groundwater contamination was not  widespread.

     Data  showing  the  localized effects  of septic  tank leachate*  on
interstitial* groundwater  and  surface  water of the Lake  were  collected
during a  1978 survey  of  the  Crystal Lake shoreline employing  a  Septic
Leachate  Detector*,  dubbed "Septic  Snooper"*  (Kerfoot 1978)  (Appendix
C).  Septic  tank effluent  plumes entering the  Lake were located and the
interstitial groundwater associated with each leachate  plume  was sampled
one foot  below the  lake bottom.   Concentrations  of nitrate,  ammonia and
total phosphorus  were measured.

     Despite the  proximity of each sampling point to the ST/SAS, none of
the samples taken along the northeast,  southeast  and southwest shoreline
indicated violations of the Drinking Water Standard for nitrates.   While
there is  a  possibility that the interstitial groundwater samples do not
accurately  reflect  true groundwater quality, the  nitrate concentration
data are  consistent  with  Gannon's findings (1970)  for  nitrate levels in
wells along the  northwest, southeast  and southwest shores.   Unfortun-
ately, interstitial  groundwater samples were not  collected  in effluent
plumes along the  northeastern shore where well  water nitrate  levels were
found by Gannon (1970) to be the highest.

     Although phosphorus levels in the  groundwater plumes are low, there
may  be  sufficient phosphorus  loading   to  cause  localized algal  blooms
along the  northeast  and  southeast  shore where  groundwater  inflow  is
significant.  These plumes may channel  nutrient-rich water to the vegeta-
tion, in effect acting as a hydroponic  culture.   However,  ST/SAS may not
be the sole source  of phosphorus for the algae.   Phosphorus  in drinking
water is  not a health hazard  to humans; the only  concern is  excessive
loading of  nutrients  into  the Lake.  This issue  is further addressed in
Section II.B.6.

5.   SURFACE WATER HYDROLOGY

     Cold  Creek,  Crystal  Lake,   the  Betsie River  and Betsie  Lake are
major surface  water resources  located in the Study Area.   Cold Creek
originates  approximately five  miles  east of Benzonia and is  the primary
tributary entering Crystal Lake.  The Betsie River originates in western
Traverse  County,   flows southwest  into  Benzie   County  and  then into
Manistee  County.   Upon nearing  the southern end  of Crystal  Lake, the
River  receives  the  overflow  of that  lake.   Continuing westerly, the
River  empties  into  Betsie  Lake  and  eventually  Lake  Michigan  via
Frankfort Harbor.  The total water system drains  almost the entire Study
Area, with the exception  of  a small area to the  north of Crystal Lake
(see Figure  11-11).

     Physical characteristics pertaining to the hydrology of the surface
waters serve to  describe and differentiate the lakes and streams  in the
Study Area.   Specific  hydrologic and morphologic characteristics  of the
lake  or  stream not only form the surface water system in which chemical
and  other factors  operate and interact but are themselves major factors
in  that  interaction.    Size  of  drainage basin,  tributary   flow, lake
volume and hydraulic retention time directly influence the quantity and
quality of  surface water resources.

                                    52

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53

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a.   Size  of Drainage Basins

     Betsie Lake's drainage basin is  more  than six  times  that  of  Crystal
Lake (245  square  miles  vs.  32 square miles):   the  larger watershed  acts
as  a  significant  catchment  of precipitation, which  is  transferred as
runoff  to  that  lake.   Crystal Lake  occupies a larger  portion  of  its
total watershed  than does Betsie  Lake:   Betsie Lake's  drainage basin-
to-lake surface area ratio  is 627:1  while that of Crystal  Lake  is  2:1.

b.   Tributary  Flow

     There are two major  tributaries  in  the  Study  Area:  Cold Creek and
Betsie River.

     There are no continuously recording  stream flow  gauges  in the Study
Area within  the Betsie  River watershed.   However,  because collection of
stream  flow  data  has  been  intermittent  at  several locations  on  the
Betsie River, approximate hydrologic  characteristics  of  the streams and
lakes could be derived.

     Cold Creek.   Cold Creek  is  an intermittent  stream that occurs  on  a
plateau composed  of  moraine  and  outwash  plain,.  It becomes a  permanent
stream with an average  flow of 8.2 cfs (0.23  m /s)  at Beulah.   Principal
contributors  to   stream  flow are  surface water  runoff  or groundwater
input.

     Betsie River.  Fifteen measurements  of stream  flow were made during
the National Eutrophication  Survey from  October  1972 to  October  1973 at
the outlet of Betsie Lake and also on the Betsie  River  approximately  2
miles above  Betsie Lake.   These  data plus normalized monthly  and annual
flows for  the two stations  were  reported by EPA ./1975).   The  average
annual  flow  was   determined  to  be 349 cfs  (9.88 m /s)  at  the inlet of
Betsie Lake.

     Outflow from Crystal Lake joins  the  Betsie River.  Flows  where  they
join were  measured four times a year from 1944  to 1950  by the  US  Geo-
logical Survey.   Outlet  flow was  also measured during 1976 and  1977 by
Tanis (1978).  His information showed that maximum  outlet flows occurred
during and after  the spring thaw in the  months  of April, May and June.
Minimum  flows,  including  two instances   of  zero  flow,   occurred during
December  and January.   Minimum  flow  conditions  may  persist  through
February  and March, but the  data were   not  conclusive  on this point.
Analysis of  44 flow  measurements  by  Tanis (1978)  over a  one-year period
indicated that the average outlet flow was 13.5 cfs (0.38 m  /s).

c.   Lake  Hydraulic Retention Time

     Assuming complete mixing, the retention time  of a lake is the  time
required  for natural processes   to  replace   the  entire  volume  of  its
water.   Betsie Lake  has  a  relatively short  retention  time  of  about  2
days (Knutilla 1974) while  Crystal Lake  has  a far  longer retention  time
of  63.1  years  (Tanis 1978).  Hydrological and morphological  factors --
total tributary  flow and volume  —  account  for  the difference. Table
II-4 summarizes the physical characteristics  of these lakes.

                                   54

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                              Table  II-4

       PHYSICAL CHARACTERISTICS OF BETSIE LAKE AND  CRYSTAL LAKE
   Parameter




Lake surface area (in acres)




Mean depth (ft. (m))




Maximum depth  (ft.(m))




Volume (acre - ft.)



                 2   2
Drainage area  (mi (km ))




Inflow (cfs (m3/s))




Retention time (years)
Betsie Lake




   250




   6 (1.8)




   22 (6.7)




   1543




   245 (630)




   349 (9.9)




   0.006
Crystal Lake




   9792




   63 (19.2)




   180 (54.9)




   616,896




   32 (82)




   13.5 (0.38)




   63.1
                                   55

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6.   SURFACE WATER USE AND CLASSIFICATION

     Surface  waters  in  the  Study Area,  although used  primarily for
recreation,  also are  used to  assimilate wastewater  effluent,  harbor
commercial ships and pleasure boats,  and provide  habitats for fish and
wildlife.  These waters are not  used  for  domestic water  supply.

     The State  of  Michigan has  classified uses  of  its surface waters
(Appendix D-l) and assigned appropriate  classifications to each body of
water.  Water quality  standards  for  the  classifications and uses appear
in Appendix D-2.  For  a  lake  or stream classified  for two or more  uses,
the more restrictive  standards apply.

a.   Lakes

     Crystal  Lake  and Betsie Lake  are  classified B-I  for  total body
contact  recreation.  In  addition to  swimming areas, both lakes support
valuable  fisheries   (see  Aquatic  Biology,  Section  II.D.I).   Further,
Betsie Lake has non-recreational uses, as reported  in Table II-5.

b.   Streams

     Some  of  the  streams  in the  Study  Area have  been given multiple
classifications.  As  an  example,  the  Betsie River has been  classified
C-I,  cold  water  fish,  and  that portion  from the Manistee/Benzie County
line to the outlet stream of Crystal  Lake,  has been further proclaimed  a
"natural river"  under  Michigan's Natural Rivers  Act (Public Act 231 of
1970).   Subsequent to  the Act,  the  Michigan Department of Natural Re-
sources  established  zoning,  effective  June  11,  1977,  to preserve the
values  of  the   natural  river  district,  protect  its  resources,  free
flowing  conditions  and  water  quality,  and  to   prevent  ecological,
economic or flood damages.   (See Appendix D-3.)

7.   SURFACE WATER QUALITY

     A  general  discussion  of  changes  in lake water quality may be  found
in Appendix E-l.   In  the present section  the existing  water  quality of
Crystal  Lake  is  discussed first,  followed  by a  discussion   of Betsie
Lake.   Both discussions  are presented in two main parts.  The first of
these involves tributary-related considerations,  e.g.  concentrations and
loadings  of  contaminants.   Contaminant  loads from direct municipal and
industrial  discharges  and  from  tributary background  and   non-point
sources  are quantified separately in this part.

     The  second  part  of  the discussion involves  lake-related  considera-
tions,   e.g.  spatial,  seasonal  and  long-term  trends in  lake  water
quality.   Those  sections deal with dimensional characteristics of lake
chemistry  and biology, focusing primarily on major algal growth nutrient
and  phytoplankton* biomass  levels,   because the  latter  materials are
expected  to  change as  a result  of  the  proposed  wastewater  management
program.
                                    56

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                                  Table II-5
                  NON-RECREATIONAL WATER USES OF BETSIE LAKE
Type of Use

Wastewater
  Treatment


Wastewater



Harbor
Habitat
     User(s)

Frankfort City



Elberta



Viking Car Ferry



Tanker "Saturn"

Boat Marinas

Coast Guard

Fish and Wildlife
        Additional Information

Primary treatment plant (Design flow -
0.26 mgd actual flow - 0.266 mgd
Residential and industrial wastewater)

Primary treatment plant (Design flow -
0.10 mgd actual flow - 0.13 mgd
Residential wastewater)

Commercial water transport boat from
Frankfort, Michigan to Kewaunee,
Wisconsin

Asphalt tanker

Jacobson's, at Frankfort; Elberta

Mooring facilities near Frankfort

Hunters, fishermen, and non-consumptive
users
   Williams and Works, Crystal Lake Area Facility Plan, 1976.
   By phone, S. T. Sherman (US Coast Guard, BM-2),  1978.
                                      57

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     An evaluation of spatial and seasonal trends in major nutrients for
phytoplankton growth is  fundamental  to  an understanding of variation in
plankton population.  In  order  to determine if changes in water quality
would  result from  the  proposed  sewer project,  the relation  of  these
trends to  the annual cycles  in the  lake must be  studied.   Inasmuch as
the vertical  distribution  of chemical and biological species is closely
related to seasonal phenomena, spatial and seasonal characteristics will
be discussed  together.   A brief discussion of the biological character-
istics of  each lake and summaries of  specialty studies  (where  appli-
cable) is presented.

a.   Crystal Lake

     Tributary-Related Considerations.   The  average concentrations  of
some water quality  parameters at the mouth of Cold  Creek (the inlet of
Crystal Lake) during the summer months of 1969 were 0.07 mg P/l as total
phosphorus and 0.03 mg P/l as orthophosphate,  8.1 mg/1 dissolved oxygen,
and pH of 7.8 (Gannon 1970).

     The average concentration of total phosphorus measured at the mouth
of Cold Creek in 1976-1977 (Tanis 1978)  was 0.09  mg P/l, and the average
concentration of  soluble orthophosphate was 0.02 mg P/l.   Figure 11-12
presents the  month-to-month  variation in Cold Creek's phosphorus levels
from July  1976  to July  1977.  According to the study, the most signifi-
cant  contributions  of  phosphorus  to  Cold  Creek  originate   from  the
Village of Beulah and the surrounding area (Tanis 1978).  Tanis believed
the sources of phosphorus to be:

     o    Beulah's storm water  runoff,  which  is  routed directly to Cold
          Creek

     o    Sediment  carried via  runoff  from  the  muck soil  adjacent to
          Beulah

     o    Possible leaks or seepage from the present wastewater disposal
          systems.

     The average  concentration  of total phosphorus measured by Tanis at
the outlet of Crystal Lake during the same period was 0.01 mg P/l, con-
siderably lower than the level at the inlet (mouth of Cold Creek).  This
result indicates  that a  significant  amount of phosphorus  has been re-
tained by the Lake.

     In Cold  Creek,  total coliforms  range from 900 MPN/100 ml to 11,000
MPN/100 ml,  while fecal coliforms ranged from 50 MPN/100 ml to 200 MPN/
100 ml during the summer months of 1969 (Gannon 1970).

     Nutrient Loading Characteristics.  Nutrient  loads to  Crystal Lake
originate  from  its tributary (Cold  Creek),  precipitation,  septic tank
leakage and  non-point source runoff.   The nutrient load from Cold Creek
was  calculated by  multiplying  monitored river  concentrations by  the
specific  daily  flow as  given by  Tanis  (1978).   The   focus  of  the
(loading) calculations is on phosphorus because this element is believed
to be the limiting nutrient most likely to be affected by the wastewater
management project.  The  Cold Creek  flow, phosphorus concentrations and
phosphorus loads are plotted  in Figure 11-12.

                                   58

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w
Ik
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   0.07
    0.06
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  FIGURE H-12:  FLOW, PHOSPHORUS CONCENTRATION AND PHOSPHORUS
                 LOADS IN THE COLD CREEK (1976-1977)
                                59

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     Some patterns were observed in the seasonal variation of phosphorus
loads from  Cold Creek.   Phosphorus  loads were  closely  correlated with
flow.   During periods  of high  flow,  concentrations  increased  because
higher  non-point  source runoff had increased, and  the associated phos-
phorus  load  also showed  a  dramatic increase.   From  these  results,  an
average  total phosphorus load  of  1,533  Ib P/yr  (679  kg/yr)  was calcu-
lated  for the  period  from  July  1976 to June  1977.   The  result also
indicates  that non-point sources  are important  contributors  to  Cold
Creek's phosphorus load.

     As mentioned earlier, precipitation  is  a major source of nutrients
for Crystal Lake because the lake's surface area is large in relation to
its drainage area.  A combination of snow and rainfall samples collected
during the 1976-1977 study (Tanis 1978) produced a mean concentration of
0.032 mg  P/l  as total phosphorus.  The total  precipitation in the same
period  amounted to  24 inches (61 cm), according  to Tanis (1978).  As a
result,  the total phosphorus load due to precipitation during the study
period was 1,690 Ibs P/yr (767 kg/yr).

     In  this  EIS  phosphorus  inputs from septic tank systems were calcu-
lated  using  assumptions  developed  by  EPA  (1975):   0.25  lb/capita/
year  of total phosphorus will leach  from soil disposal  system to the
lake.  In the Study Area, there are 511 homes within 300 feet of Crystal
Lake  currently  served by on-site systems, as indicated by aerial photo-
graphs  and  planning maps.   Using the unit  loading and  the population
characteristics  derived above,  the  phosphorus input  currently  contri-
buted from  septic  tank leakage is approximately  263  Ib/yr (120  kg/yr).

     Phosphorus loads to Crystal Lake from the drainage area immediately
surrounding the lake were estimated using regression models developed by
Omernik  (1977)  and  approximated overland runoff flows.  A detailed des-
cription  of  the model  and  the  methodology  used in  this  study  are in-
cluded  in Appendix E-2.  The total phosphorus  load  attributed  to non-
point sources from the  immediate drainage area is 465  Ib/yr (210 kg/yr).
Table  II-6  summarizes  the   phosphorus loading  levels to  Crystal Lake
together  with the areal  loading and  percentage  loading  for each cate-
gory.
                              Table II-6
                TOTAL PHOSPHORUS LOADS TO CRYSTAL LAKE

                     (Ib/yr)        (kg/yr)        (g/m2/yr)       %

Precipitation        1690            767             .019        42.8

Septic Tanks          263            120             .003         6.7

Cold Creek           1533            695             .017        38.8

Non-Point Source
 Runoff-Immed.
 Watershed            465            210             .005        11.7
     Total           3951            1792             .044        100.0
                                    60

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     Cold  Creek and  precipitation have  been  identified  as  the  major
nutrient sources to  Crystal  Lake.   These two sources supply over 80% of
the total  phosphorus  load  to the lake.  The above estimated septic tank
load represents 6.7% of the total load.  Recent data from Kerfoot (1978)
indicate  a significantly  lower  phosphorus  load  from septic  tanks  (23
kg/yr) .   This  low  level  may  be due to the sampling time (November 1978)
when  the population  was  substantially  lower  than the annual  average
population  equivalents.   Nevertheless, the  septic tank loads  in Table
II-6 can consequently be considered a conservative estimate.

     Lake Water Quality.   Water  quality  data have been collected during
two  extensive   studies  of Crystal  Lake by  the University  of Michigan
(Gannon  1970)  and  Tanis  (1978),  respectively.  The  earlier study indi-
cated that  levels  of some key water quality parameters such as ammonia,
nitrate,  orthophosphate,  and  total phosphorus in the open  water  were
below the   detection  limits  of  the  instrumentation available  at  that
time.   The primary  productivity   rate  (at  which  available  inorganic
carbon is converted to organic material by phytoplankton photosynthesis)
was measured  and  found  to range between  169 to  188  mg  C/m /day.   The
recent survey by Tanis shows  that the water quality in the open water of
Crystal Lake is relatively good and may be considered one of the highest
in Michigan (see  the  key  water quality  parameter values  tabulated in
Table II-7).   Tanis  (1978) also reported  the  primary productivity rate
in the  summer  of 1977 at  139 mg C/m  /day, which  is lower than the rate
measured by the University of Michigan in 1969.  There is no indication
in any  of  the  results  that  the  quality of  Crystal  Lake  water deterio-
rated significantly  over  the last  seven or eight years and the deterio-
ration  of   open  lake waters,  if  any,  appears to be progressing  at  a
relatively  slow rate.

     Deterioration of the  lake  has only been  observed  along the shore-
line  in localized  areas  where  nutrient influx is a problem.  Concerns
have  become accentuated along portions  of  the north  shore near Beulah
and also along the southwest shore  (Tanis  1978).  Growth of algae in the
forms of Cladophora  attached  to rocks and  other hard  surfaces at the
shoreline  has  been consistently  observed during the summer months.  The
results  of a  special dye  study  to  determine  the cause  of shoreline
pollution  proved  to be   inconclusive  (University  of Michigan 1970).
Recent  results  from  Kerfoot (1978),   who  measured  the  leachate plumes
from  septic tanks  in Crystal  Lake,   indicate nutrient  flux into  the
shoreline  waters.  A high correlation existed between  the location of
emergence  of  plumes  and attached plant  growth,  particularly Cladophora
(Kerfoot  1978).   Groundwaters obtained near  the  peak concentrations of
the  outflow of  the  observed plumes  contained sufficient  nutrients to
support attached algae and aquatic weed growth.

     In general, Crystal Lake water quality concerns have not been asso-
ciated  with public health,  as  only  a  few  cases  of coliform bacterial
contamination have been  reported by the Tri-County Department of Public
Health  (GT-L-BHD)  (Tanis  1978).   By showing fecal coliform levels lower
than  the  200  MPN/100  State Standard,  Kerfoot's   (1978)  results concur
with  previous   studies.   Fecal  coliform   counts  in the  surface waters
directly affected  by leachate  plumes  were well below the 200 MPN/100 ml
allowable in total body contact recreational waters.

                                    61

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b.   Betsie Lake

     Tributary-Related Considerations.   Various water quality parameters
were  monitored  in  the  Betsie River  by  the Environmental  Protection
Agency  (EPA  1975).   The  average  concentrations of water  quality para-
meters for the Betsie River during the study period,  the summer of 1973,
were 0.02 mg  P/l  total phosphorus, 0.01 mg P/l orthophosphate, 0.057 mg
N/l  ammonia,  0.68  mg N/l  total  kjeldahl nitrogen  (TKN),  0.18  mg  N/l
nitrate plus nitrite.  According  to the NES study, non-point sources of
nutrients are responsible for significant contributions of phosphorus to
the  river.   For this  reason,  it  was suggested that point  source phos-
phorus inputs to the Betsie River and Betsie Lake should be minimized to
the greatest extent practicable (EPA 1975).

     Nutrient  loads  to  Betsie Lake originate  from  tributary  (Betsie
River),  precipitation,  surface water  runoff  and municipal  wastewater
treatment plants.   Data  collected in 1972 (EPA 1975) have been analyzed
and loadings have been summarized in Table II-8 below.   Once again, only
phosphorus  loadings are  tabulated  since phosphorus  has  been identified
as the limiting nutrient for algal growth (EPA 1975).
                              Table II-8
             TOTAL PHOSPHORUS LOADS TO BETSIE LAKE (1972-73)*

                              (lb/yr)      (kg/yr)     (g/m2/yr)     %

Tributaries (non-point
 source) Betsie River         14,240        6,460         6.38      51.5

Minor tributaries and
 immediate drainage (non-
 point source)

Municipal STP's

Precipitation

               Total

13

27

150
,200
40
,630

68
5,990
18
12,530

0
5
0
12

.07
.92
.02
.39
*EPA.
0.
47.
0.
100.
1975
5
8
2
0

     Data  from  the National  Eutrophication Survey  (EPA  1975)  in Table
II-8 indicate an average total phosphorus load of 14,240 Ibs P/yr during
the period from October 1972 to October 1973.  The Betsie River exerts a
significant  influence  on  Betsie  Lake's  condition.   Two major  point
sources --the Elberta and Frankfort municipal sewage treatment plants --
furnish  another significant  portion  of  the  nutrient loadings  to  the
lake.

     EPA  (1975) estimated  that 40  Ibs P/yr  is contributed by direct
precipitation  to Betsie  Lake.  This  load  is  relatively insignificant
compared  with  other  contributions.    Other nutrient  sources of Betsie

                                    63

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Lake  such as  septic tank  leakage and  industrial  wastewater were  not
documented (EPA 1975).

     EPA  (1975) also  estimated  the total nitrogen inputs to Betsie Lake
at  701,150  Ibs/yr   of  which  588,590  Ibs/yr  is  discharged into  Lake
Michigan.

     Lake-Related Considerations.   Betsie  Lake  was  sampled  three  times
during the 1972 eutrophication  study.   Data were collected  at  one open
water station  at  three  different  depths.  The average water quality can
be  summarized  in  terms of  the following  physical, chemical and bio-
logical  characteristics:    145  mg/1  of  alkalinity;  304|Jmhos  of  con-
ductivity; 1.0 m of Secchi disc depth; 0.026 mg P/l of total phosphorus;
0.175 mg  N/l of  inorganic nitrogen; and 4.6  |Jg/l  of chlorophyll a.   As
indicated, the open  water  quality can  be described  as  nutrient-rich,
productive and, therefore, eutrophic (EPA 1975).

     EPA  conducted an algal  bioassay  to determine the limiting nutrient
for  algal growth.  The  results showed that Besie  Lake  was phosphorus-
limited  at the  time the  assay sample  was collected on September 15,
1972.   The  lake  data  indicated  phosphorus  limitation  in  June  and
November  of  1972  as  well (EPA 1975).   Based on this finding, the effort
of  assessing  potential  eutrophication has  been concentrated on  phos-
phorus (see Section IV.A.I.a).

     Because the lake was monitored only once, it is not possible to say
how  Betsie Lake has  changed since the EPA  survey in 1972.  However, it
is  significant to  note  that the lake  is  shallow,  has a short hydraulic
retention  time and  a  large  drainage  basin-to-lake  surface area ratio.
Should point source  discharge to  Betsie Lake be  minimized,  the trophic
status of the lake  would be likely  to improve  slightly.   If existing
discharges  should  continue  unabated,  the  combined effects  of  lake
morphology and hydrology,  non-point   source  nutrient and  point source
nutrient  loads are  likely to result in the continued degradation of the
quality of Betsie Lake's water.

     A list  of studies  of water quality of Crystal Lake is contained in
Appendix E-3.

8.   Flood Hazard  Areas

     Figure  11-13 delineates the  flood hazard  areas located along the
shorelines of  the Betsie River and the five lakes in  the Study Area (HUD
1975, 1976).   The areas delineated show the 100-year floodplain, i.e. a
flood of such magnitude  can be expected  to occur  with  a frequency of
once  every 100 years.  In reality such a flood could occur at any time.

     The  flood hazard areas  along the Betsie River are protected by the
Betsie River Natural River  Zoning Act.  That act precludes any cutting,
filling or building  on  the land in the floodplain and requires a minimum
setback distance of 200 feet.

     Under  the existing  sanitary  code and  zoning  ordinances  for the
townships  around  Crystal Lake,  a  minimum  setback distance  of  50 feet
                                    64

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65

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from the lakeshore is  required  for  any construction activities.  Because
Crystal  Lake  is  not  fed by any  large-volume streams and  because  the
ratio of its watershed  area  to lake  surface area is only 2:1, the flood
hazard area  is  very narrow  -- almost non-existent along  parts of the
lakeshore.   Consequently the 50-foot requirement is adequate to protect
flood-prone areas along  the  Lake.
C.   EXISTING SYSTEMS

     There are three centralized  collection and treatment systems within
the  Study  Area.   They serve the City of  Frankfort  and  the Villages of
Beulah and Elberta.  These  systems have been  discussed  in the Facility
Plan and are  summarized  in  Chapter I.  Their  location and the extent of
the areas they serve are  shown  in Figure 1-3.

     The Townships of Crystal Lake, Lake and Benzonia and the Village of
Benzonia are not  served by a centralized treatment system; wastewater is
treated by on-site  systems.   When the Facility Plan was prepared,  very
little  information  was  available  on the  existing  on-site  systems on
which  to  base an evaluation  of their adequacy.   Three  studies  were
undertaken during preparation of  this EIS  to provide  information regard-
ing the type, the  nature and frequency of problems,  and the adequacy of
these  systems  in meeting the  wastewater  treatment needs  of  the  Study
Area.

1.   SUMMARY OF DATA ON EXISTING SYSTEMS

     This discussion briefly summarizes the  studies that were recently
undertaken to evaluate existing  systems.  Results  of these studies are
discussed  elsewhere  in   this  EIS  as  well  (surface   and  groundwater
quality, soils analysis).

a.   "Investigation  of Septic Discharges into Crystal
     Lake"  (William  Kerfoot 1978)

     This  study  was undertaken  in  November  1978  to determine whether
groundwater plumes  from   nearby  septic  tanks  were  emerging  along the
lakeshore  causing  elevated  concentrations  of nutrients.   Septic  tank
leachate  plumes  were  detected  with an  instrument referred  to  as  a
"Septic Snooper."   The instrument is equipped with analyzers to detect
both organics and  inorganic chemicals from  domestic wastewaters;  it is
towed  along the  shoreline to obtain  a profile of septic leachate plumes
discharging to the  surface  water.  Surface and groundwater sampling for
nutrient  and  bacteria (surface  water  only)  were  coordinated  with the
septic leachate profile  to  clearly identify the source  of the leachate.

     The "Septic  Snooper" detected 90 plumes of wastewater origin enter-
ing  Crystal  Lake.   This corresponds to  approximately  18%  of  the 500
existing  lakeside  systems,  i.e.  those within  approximately 300 feet of
the  lake.   The  location  of these  plumes  is  shown in  Figure 11-14.  A
high correlation  was found  between the location of the plumes and the
attached  algal  growth.   While  there  is  sufficient   breakthrough  of
nutrients to  the  surface water to support algal growth  in the immediate
                                   66

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67

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vicinity of  plume  emergence,  overall lake  water  quality has  not  been
significantly impacted by  septic  leachate  plumes.   Appendix  C contains
the Kerfoot study.


b.   "Sanitary  Systems of  Crystal Lake,  Benzie County,
     Michigan:   An On-site  Survey"   (University  of Michigan,
     1978)

     The sanitary survey of lakeside on-site  systems  in Crystal Lake,
Lake and Benzonia Townships was  conducted  during  September and October
of  1978.   This  survey provided information regarding the  types  of on-
site systems, the nature and  extent  of problems with these systems, and
the nature and extent of violations  of the existing sanitary code.   The
technical report on  the sanitary  survey  is included in Appendix  F-l.
Table II-9  summarizes some  of  the  significant data.

     The results indicated that over  50% of the systems were violating
the sanitary code.    Despite the  large number of violations, very few of
the systems  had  recurring problems  with backups  or ponding.  Attached
algal growth was associated with  34% of  the  homes  surveyed,  although
only about 10% of the  sites had heavy algal growth.  Heavy algal, growth
was most frequent on  the northeast shore.

c.   EPIC  Survey  (EPA 1978)

     An aerial photographic survey was conducted by EPA's Environmental
Photographic  Interpretation  Center   (EPIC)  to  locate   failing  septic
systems  throughout  the  Study Area  and  to locate  patches  of aquatic
vegetation along Crystal Lake.  The  results of this study are shown in
Figure  11-15.  Very  few surface  failures  of   septic tank  systems  were
located in the Study Area.  The  failures that  were detected were mainly
in  and  around  Benzonia  Village.   Photographs  indicated  that  the north-
eastern and  eastern  shores  had the densest growth of submerged vegeta-
tion, although  field verifications were not  done.   Very little growth
was observed on the  northwestern  and  western shores.

     The aerial  photographic  survey  was   conducted  during  the summer;
foliage may have prevented the detection of some malfunctioning systems.

2.   TYPES OF SYSTEMS

     Based on  data  obtained  during  the  sanitary survey (University of
Michigan 1978),  98%  of  the 1,090 residences  in the unsewered parts of
the  Proposed Service Area  are estimated to have  septic tanks and some
type  of subsurface  absorption system (ST/SAS).   The remaining 2% have
permits for  holding  tanks  only.   Fifty-eight  percent of the  ST/SAS em-
ployed  a drainfield,  41% employed a  drywell and only 1% of  the systems
had no  soil absorption system.

     No information  is  available  on  the types  of  on-site systems in use
in  Benzonia.  There  are, however, about  279 homes using on-site treat-
ment systems in the Village.
                                    68

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3.   COMPLIANCE WITH THE  SANITARY CODE

     In 1964, GT-L-BHD  issued  the  first  sanitary code for the  townships
along the Crystal  Lake  shoreline.   Prior to this, there  were  little  or
no restrictions  regarding  the  construction and use of  on-site  systems.
Although the Health Department  began issuing permits  in 1964,  it was not
until  1971   that  site  evaluations  and   installation inspections were
begun.  Consequently, the  sanitary  code  was not enforced prior to 1971.
In 1972, the  code  was  revised  to incorporate more stringent measures  to
ensure  adequate  treatment  of  household  wastewaters.   Notably,  the re-
visions  provided  for   denial  of  a permit  if  the  site  did  not meet
criteria established  for suitable  soils  and depth to  groundwater.   In
addition, the revised  code  increased isolation distances between septic
systems and  surface water  from  25  to 50 feet.  The  vertical  distance
between the  drainfield  and  the high water table was  also increased to 4
feet.   "Selections  from the  Sanitary Code of Minimum Standards" and the
Code are attached as Appendixes F-2 and F-3 respectively.

     Since the  Health Department began  performing site  evaluations  in
1972, 44% of  the sites in the Proposed  Service  Area  have been found  to
be unsuitable.  A 1978 soils survey conducted by SCS  indicated  that 100%
of the  soils  examined  were unsuitable.  The discrepancies in  these data
are discussed in Section II.A.3.a.

     At  sites where  the soils  are unsuitable  because of slow perme-
ability or high  groundwater  table,  a holding tank permit  may  be issued
in lieu of  a septic  tank permit.   The  various permits  issued  for the
lakeshore townships between 1970 and 1977 are summarized in Table 11-10.
The trend has been towards an increased  issuance of  permits for holding
tanks and pump  systems.  Drywell permits are no  longer  granted because
there is an increased potential for groundwater contamination  with these
deeper systems.
                              Table 11-10
              PERMITS ISSUED IN THE PROPOSED SERVICE AREA
                BY GT-L-BHD BETWEEN 1970-1977 INCLUDING
                     REPAIRS AND NEW INSTALLATIONS
                                   Crystal
                    Benzonia        Lake          Lake      Total

Drainfields          103             79            90        272
Holding Tanks          6              6             3         15
Pump Systems           3              2             5         10
Drywells              10             10           	9_        32
                     125             97           107        329

                                                  Crawford 1977
                                    71

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     Because the  1964  sanitary code was  not enforced  and  because the
1972 provisions  are  even more  stringent,  many  of the existing systems
are in violation of the sanitary code.  Of  the 249 homes surveyed in the
sanitary survey, 53% did  not  comply with regulations.  Violations fall
into one or more of the following categories:

     o    Septic tank less than 15.3 meters
          (50 feet) to  the lake                        11%

     o    Septic tanks  less than 15.3 meters
          (50 feet) to  the well                        23%

     o    Septic tanks  smaller than recommended
          size (septic  tank size was not  available
          for 37% of the homes)                        41%

     o    Systems with  drywells                        40%

     o    Soil absorption systems too small
          to meet regulations  (30% have no
          record)                                      39%

     No information was available  on violations  of  the sanitary code  in
the Village of Benzonia.

4.   PROBLEMS  CAUSED BY  EXISTING ON-SITE  SYSTEMS

     Despite the fact that more than half the systems  do not comply with
existing regulations,  very few  are  causing  potential public health  or
water  quality problems.   Where problems do occur  they have generally
been  associated  with older systems.  Many of these  were  poorly  main-
tained before  1971 when site  inspections were begun.   Many  backups were
associated  with  systems that  had  rarely (if ever)  been pumped or that
had roots  growing  in the  drywells.  Nearly 80% of  the systems that are
undersized  are  older than 10  years; similarly those older than 10  years
have  more   violations  of   the  distance  requirements  from wells  or the
lakeshore.

     The distinction  should be  made between nuisance  or community im-
provement problems on  the one hand, and  public  health and water quality
problems on the other.   Public health problems may result from recurrent
backups, ponding  of  the effluent on the  soil surface, and contamination
of  the groundwater supply  in excess of drinking water standards.  The
existing  systems around  Crystal  Lake  have  been  examined   to determine
whether  they  are  contributing  to public  health  and  water  quality
problems.

a.   Ponding

     Ponding may  result if percolation  of effluent through  the soil  is
too slow, if the system was installed to  close to the soil  surface  or  if
a high groundwater table prevents percolation through the  soils.
                                    72

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Ponding may  also  result from hydraulically overloading otherwise  suit-
able  soils;  continuous  inundation  of  the  soil may  lead to  clogging.
Only 3% of the systems surveyed have had problems with ponding  more than
once; these problems may have resulted from  poor maintenance  rather than
unsuitable soils.   The  problems with  ponding  occurred with systems over
15 years  old;  several  of  these  had never been pumped until  1976-1978.

     EPIC, a branch  of  the Environmental Monitoring  and Support  Labora-
tory (EMSL),  conducted a survey (1978) to determine surface malfunctions
by aerial  imagery.   Only  two  surface malfunctions were  detected  along
the  lakeshore  (Figure  11-15)  but  several failing  systems  were found  in
and  near  the Village of Benzonia.   Soils in the area have a  relatively
high  clay content,  which  may contribute  to  ponding  (Leverett  1907;
Crawford  1977).  Some  sections  of  Crystal Lake  Township (Figure  11-15),
distant from the lakeshore, had several surface  malfunctions,  suggesting
a high clay content in these soils  as  well.

b.   Backups

     Several of the  systems  around  Crystal  Lake have  backed  up on  occa-
sion  as  the  result of  hydraulic  overloading,  roots growing into  the
drywell,  pump  failures  or  lack of septic tank  maintenance.   Unsuitable
soils  may cause  backups  as  well,  if  the  effluent cannot  percolate
through the  soil.   Based on results of the sanitary  survey,  20% of the
existing systems have had backups.   Only about 6% of  these backups  could
not  be attributed  to an occasional  hydraulic  overload or a  maintenance
problem that has since been corrected (e.g.  roots in  the drywell  or pump
failure).   The causes  of recurring  backups  in 5% of  the  systems is not
clear.  These systems were  generally old, and  information  on  the  size of
the  septic  tank or  soil absorption system  was  lacking.   Most of  these
systems are  drywells,  although this  may be only coincidental.  Never-
theless, the data  indicate that  recurring problems with backups  are not
common in the Proposed Service Area.

c.   Groundwater Contamination

     In view of the  large  number of septic  tanks using a  drywell as the
soil absorption unit and because  several septic tanks are too close to
the  wells  to meet  regulations,  there is concern about potential  ground-
water contamination with nitrates.   However, a study  conducted by Gannon
(1970)  (see  Section II.B.4  for  more detail)  indicated that  concentra-
tions of  nitrates  in wells along the western, northwestern and southern
shores of  Crystal  Lake  were considerably below  the drinking  water  stan-
dard of 10 mg/1.   Only two samples, taken from  adjacent wells  along the
northeastern shore, showed  concentrations of nitrate  equal to or  greater
than  the  standard.   The source of  nitrates in  these wells  can  only  be
assumed to be  nearby  on-site  systems since no follow-up evaluation  of
the wells was reported.

d.   Surface  Water Quality Problems

     Septic tanks do not seem to be contributing significantly to  water
quality  deterioration.    Crystal   Lake   receives  a   sufficiently  low
nutrient input to maintain  an oligotrophic status.  Septic tanks  contri-
                                    73

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bute  a  small  percentage  of  that input  compared to  non-point  source
runoff  (see  Table  II-6  and discussion in  Section II.B.7.a).  Kerfoot
observed that  only  18%  of  the lakeshore homes were leaching  detectable
nutrients into Crystal Lake.   These  data  indicated that the per  capita
phosphorus load  (based on  a population of 574 during November  when  the
survey was  taken)  was 0.036  kg/cap/yr (0.08 Ib/cap/yr).  In  contrast,
the  National  Eutrophication  Survey  estimated that  phosphorus  loads,
leaching  from  septic  tanks into  surface  waters generally average 0.11
kg/cap/yr (0.25 Ib/cap/yr).   Even if  this  higher load were  realized from
all lakeshore  homes,  septic tank leachate would contribute a  maximum of
6.7% of the total phosphorus input to Crystal Lake.

e.   Other Problems

     Other problems exist which do not pose  a potential  health threat or
the  potential for  water quality  degradation.   Odors  associated with
septic tanks  are considered  a  nuisance.   However, this problem  occurs
infrequently in  the lakeshore  townships.  Only six residents  or 2.5% of
those surveyed in the University  of Michigan sanitary survey in 1978
complained of odor problems.

     Attached algal growth (Cladophora) is also  a  nuisance  problem.   The
growth has not been found  to be indicative  of overall  lake eutrophica-
tion; the  main problem with  the  algae is that the growth is  aestheti-
cally   displeasing   and   may  interfere   with    certain  recreational
activities.

     Available data  on  the extent and distribution of  Cladophora vary
depending upon how the survey  was conducted.   Results  of a  study per-
formed  during the  sanitary survey indicate  that  Cladophora  growth  is
associated with  34% of the existing homes  and  septic   tanks.  By con-
trast, Tanis detected Cladophora growth by aerial  photography  along only
5% of the  homes  (Figure  11-16).  This method can  only detect  relatively
dense patches  of  growth, while  the sanitary survey located even  slight
patches by visual inspection.

f.    Problems   in  Individual Sections  Around   Crystal   Lake

     The  information  reviewed  above  suggests that  even though many
systems do  not comply with regulations,  groundwater and  surface water
quality   are  generally  good  and  that problems  with  existing systems
could be minimized by proper maintenance.  However, the  various sections
of Crystal  Lake  are  each  unique, and  their on-site  systems  should be
considered individually.

     Northeast Shore.    Data  presented   in   Table II-9  (see Section
Il.C.l.b  above)   indicate   that  the   northeast  shore  has  the  greatest
number of systems that do not meet regulations (62%).  This area is more
prone to failure and water pollution  problems than other lakeshore areas
for three reasons:

     o    The  area  has  a high  seasonal groundwater table (see Section
          II.B.3) and many  systems could  not meet regulations even with
          upgrading.
                                    74

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75

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     o    It is the most  densely populated shoreline area (38 homes per
          shoreline mile).

     o    It has the most systems violating the regulations on distance
          to lakeshore and distance to wells (Table II-9).

     Despite the  potential problems related to high groundwater table,
and the  number of  undersized  systems,  only 13% of  the  on-site systems
along the northeast shore have had recurring problems with backups and
ponding.   Only  1  of 9  problem systems was less than 10 years old.   Many
of the  older systems  are undersized and  were not  maintained  properly
prior to  1971.   There were  a  number of other  systems  that experienced
backups  and ponding   on  one  occasion;  however,  these   problems  could
clearly be attributed to poor maintenance or overuse.

     Leaching  of wastewater-related  nutrients to lake  water  is  most
extensive on the northeast  shore.   Growth of  Cladophora attributed to
the leaching of nutrients from septic tanks was associated with 69% of
the homes surveyed  along  the northeast shore,  although  only 24% of the
algal growth was heavy.   Kerfoot estimated that  34%  of the phosphorus
leached  from septic tanks  came  from the  northeast  shore (1978).   Poor
soil absorption capacity,  the  large number of  homes  close to the shore
and  the  high  groundwater table  encourage the leaching  of nutrients.
However,  as  was mentioned previously, nutrient loads  are significantly
less than would be expected based on NES data.

     Groundwater  quality  along   the  northeast  shore  is  discussed in
Section  II.B.4.   It is unlikely that drywells alone are responsible for
the localized nitrate contamination of groundwater observed by Gannon in
1969 (Gannon 1970).  (Two wells indicated nitrate concentrations greater
or equal to  10  mg/1.)   Drywells make up  a large  percentage of the soil
treatment units along other parts of the  lakeshore  where nitrate con-
centrations  in  well water  were  found to  be  low.   Several factors may
contribute  to  high groundwater nitrate levels; these  include the loca-
tion of septic  tanks close to the wells,  the high groundwater table, and
the undersized  systems, as well as the use of drywells.

     Southeast.   Soils along  the  southeast  shore  are  generally well-
drained  and more  suitable  for  on-site  treatment.   Of  the  39 systems
surveyed, only  2 had  more than  an occasional problem  with backups or
ponding.   There is no clear indication that these problems resulted from
unsuitable soils  rather  than improper maintenance.  For 59% of the sys-
tems,  failure  to comply  with  the  sanitary code  results primarily from
widespread  use  of  drywells  and a  large  number of  undersized systems.
Very  few systems  violate  the regulations  concerning  distance  to the
lakeshore since a  privately  owned greenbelt  has  prevented development
close to the lake.

     Despite the  large number  of drywells  and  the fact that 15% of the
systems  are  located within 15.3 meters (50 ft.) of a well, no wells were
observed with   concentrations  of  nitrate  in  excess  of 4.0 mg/1 (Gannon
1970).
                                    76

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     Although most of  the  homes are set back at least 100 feet from the
shoreline, dense patches of Cladophora growth are associated with 10% of
the  homes and an  additional 24%  of  the homes  have slight patches  of
Cladophora growth along the adjacent shoreline.  EPIC (1978) was able to
detect only a few patches of aquatic vegetation, further suggesting that
the  growth  along this  shore is generally  sparse.   Kerfoot  (1978)  ob-
served a  high concentration  of septic  tank  effluent plumes  along  the
southeast shore.  The  nutrient  load was, however, very unevenly distri-
buted  (see  Figure 11-16) with  most of the plumes coming  from a narrow
unsewered section of Beulah.

     Northwest.  Although 54% of  the  existing systems do not meet regu-
lations,   recurring  problems  with  backups  were  reported  for  only  one
septic tank  of  the  61  surveyed during  the  1978 sanitary survey.  A few
additional systems backed  up on one or two occasions, but these backups
were clearly associated with poor maintenance or overuse.

     Although  16%  of  the  systems  surveyed were  less than  50  feet from
the  lake  and 48% of the systems were  undersized, Cladophora  growth is
scarce along the northwest shore.

     This area has a high seasonal population, which partly accounts for
the  low nutrient  influx and consequently for  the low Cladophora growth
observed  (Tanis  1978;  EPIC  1978;  University  of Michigan  1978).   The
northwest shore  was  found  to contribute 24% of the wastewater-related
phosphorus  load  to  Crystal  Lake.   In  contrast, the  northeast shore,
which  has  20%  less   shoreline,  was  found  to  contribute  34% of  the
phosphorus load (Kerfoot 1978).

     The northwest shore had the fewest systems that violate the regula-
tions  concerning  distance  from wells.  Despite  numerous drywells  and a
high percentage of undersized systems groundwater contamination does not
appear to be a problem.

     Western Shore.   Of the systems along the western shore, 46% violate
the  existing sanitary  code.  This  area has  the smallest  percentage of
undersized  systems.    However,  based  on  the sanitary  survey, only  2
systems  of   the  24  have had recurring  problems  with backups.  The  22
systems  that  experienced  backups  on  occasions  were  generally poorly
maintained;  roots growing in the drywells were the most prevalent causes
of occasional backups.

     Available data indicate that Cladophora growth is minimal along the
western shore.   Aerial photography detected  only one  patch of aquatic
vegetation on  the western  shore (EPIC 1978).   The sanitary survey indi-
cated  that  Cladophora   grew  along  the  shoreline  adjacent  to  5% of  the
homes  on  the western shore but that none  of  the growth was heavy.  Per
capita  phosphorus  discharges  are  lowest  along  the  western  shore;
although  the western  shore  accounts  for approximately 9%  of  the  total
residences,   only about  1%  of  the total  phosphorus  from  septic  tank
leachate comes from this area.  This can be explained by the groundwater
flow  patterns,  which  encourage septic  tank  effluent from  the western
shore to flow towards Lake Michigan rather than into Crystal Lake.   (See
Figure II-9.)
                                    77

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     Contamination of groundwater with  nitrates  is not a problem  along
the western shore despite  the  large number of systems that violate  the
regulations  concerning  minimum  distance  to wells  and/or regulations
concerning use of drywells.

     Southwest Shore.   The southwest shore has the  fewest  number  of sys-
tems  that are in violation of the  sanitary code.  This  area has  the
smallest percentage  of drywells,  although they still  account for  a  large
number of violations.   Other major violations include undersized  systems
and systems located  too close to  wells.

     While there have been occasional problems  with backups because  of
poor  maintenance  (i.e.,  systems  that needed pumping or contained  roots
in the drywell) only 3 systems  of the 56 surveyed had recurring problems
with backups or ponding.

     Available data  indicate that Cladophora growth is prevalent  along
the southwestern shore.   Cladophora growth was observed along the shore-
line adjacent to 34% of the homes during the sanitary survey, and 16% of
this growth was dense (University of Michigan 1978).  Aerial photography
detected  several  beds of  aquatic vegetation (Tanis 1978;  EPIC  1978).
Housing density is  quite  high  along the southwest shore with  35 houses
per shoreline mile  (lakeshore  average is 16 houses per shoreline mile).
Nevertheless,  phosphorus  loadings  monitored  by  Kerfoot  (1978) were
significantly less than  those  detected  along the northeast shore with a
similar housing density  (2.3 kg  of phosphorus per  mile on the  northeast
shore compared to 1.1  kg/mile  on the southwest  shore).  Lower nutrient
loads along the  southwest  shore  may be  attributed  to:  a)  fewer  systems
close to  the  lake;  b)  presence of sandy, well-drained  soils in contrast
to wet  soils  along  the  northeast; and c) a lower year-round population.

     Village of Benzonia.  The  only data available  on the  performance of
septic  tanks  in  the Village  of Benzonia  are   those  from EPIC  aerial
photographs (1978).   This  survey  detected 5 surface  malfunctions in  the
Village.  This corresponds  to  approximately 2%  of  the  existing systems.
No information is available on problems with backups.  While it  is pro-
bable that many of these systems  do not  meet regulations with respect to
sizing, ponding may  be  the result of poor  soil  absorption capacity, as
well.   It is known  that thick clay  barriers do exist in areas  of  the
Village and  consequently  effluent may not readily  percolate through  the
soil.
D.   BIOTIC RESOURCES

1.   AQUATIC  BIOLOGY

a.   Crystal  Lake

     The  low  nutrient levels that characterize  oligotrophic  lakes  such
as  Crystal  Lake support  very little plant growth.  A  study  of Crystal
Lake water  quality  conducted in 1969, showed that there were  only a few
species  of aquatic  macrophytes* and  that  they were  nowhere  abundant
(Gannon  1970).   At  that time bullrush was the dominant emergent aquatic
                                    78

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plant; bullrush  growth was  found  along the  southeastern  shoreline and
less  extensively  along the southwestern and  western  shores.   Submerged
plants included chara, water star grass and curly pondweed.  In the area
where Cold Creek  discharges  into Crystal Lake,  large  beds of chara and
potamogeton  (pond  weed)  were found (Michgan  DNR,  various  years).   Cold
Creek  receives  high  nutrient loads  from  non-point  source  runoff and
leaks  or seepage  from the  present  sanitary systems;  as a  result  it
supports abundant  plant growth  within its own bed and  where it enters
Crystal Lake.

     The  filamentous  algae,  Cladophora,   has  been  observed  growing
attached to  rocks in  front  of  the cottages  along the  shore  of Crystal
Lake.  In Crystal  Lake,  where the nutrient supply is naturally low, the
presence of this growth is a strong indication of nutrient contamination
from localized sources (Tanis 1978; Gannon 1970; Kerfoot 1978).

     Tanis (1978) conducted an aerial survey of Crystal Lake in 1976 and
found  that  about  5%  of  the existing lakeshore  homes had  Cladophora
growth along  the adjacent  shoreline.   The level  and frequency of the
growth were  reported  to  be comparable to that observed in 1969.  Figure
11-16  indicates  that  the  heaviest growth  occurred  along  the northeast
shore.

     In  a   recent  sanitary  survey  (University of  Michigan  1978)  the
extent and distribution  of Cladophora growth were determined by on-site
investigations, which  permitted  even  slight patches of Cladophora to be
detected.  The study  indicated  that,  of the  sites  investigated (23% of
the  residences  in the  Proposed  Service Area  around  Crystal  Lake), 35%
na<*  Cladophora  growth although  only  about 11% of the  growth was  cate-
gorized  as  heavy.   Table  11-11  shows the  distribution of  growth with
respect to the shoreline area.
                              Table 11-11
                   DISTRIBUTION OF CLADOPHORA GROWTH
                ALONG CRYSTAL LAKE SHORELINE AS PERCENT
                         OF SITES INVESTIGATED

                         Slight        Moderate             Heavy
Shoreline                Growth         Growth              Growth
Northeast                 14              31                  24
Northwest                 15               2                   7
West                       05                   0
Southwest                 11               8                  16
Southeast                 24              10                  10

                                   (University of Michigan 1978)
     In agreement  with Tanis'  study,  growth was  found to be  heaviest
along the  northeast shore.   The  more frequent  growth reported  in  the
                                    79

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sanitary survey as compared  to  Tanis1  survey may have resulted from the
different  survey  methods  used  (on-site  survey  versus aerial  survey).

     Several studies  have tried  to correlate the  frequency of Cladophora
growth  with  certain  variables  related  to  septic  tank  performance.
Gannon  (1970)  observed  a  correlation between housing and  septic  tank
density  and  Cladophora growth.    The  sanitary survey  (1978)  found  that
Cladophora growth correlated best with proximity of systems to the  lake
shores,  length  of residence (seasonal  vs.  year  round), and  age  of the
system.  The  systems which  were  installed prior  to 1971  were not re-
quired to  conform to a sanitary code and  consequently the older systems
are frequently in violation of  the existing code.

     Kerfoot (1978)  observed a  correlation between Cladophora gro>wth and
septic  tank  leachate  plumes,   suggesting  that   septic tanks  are  the
localized nutrient sources supporting algal growth.

     Studies on the  macroinvertebrate*  populations in Crystal Lake  show
a  diversity  of  species  and  a  surprising  abundance  considering  the
limited nutrient supply  (Gannon 1970).  Macroinvertebrates are the  main
source of food for the large fish population in Crystal Lake.

     Such  clean water  organisms  as  the  mayfly  nymph,   the  caddisfly
larvae and amphipods  were found  in the littoral zone.  Benthic organisms
were very  abundant;  at a depth  of 70 feet, the density of organisms was
100 organisms/ft.   (Gannon 1970).

     Crystal Lake  supports a large  and valuable  fish population.   The
Lake is  particularly suited  to  cold water  species  and has been managed
for game fish  since  the 1920s.   The lake  has been stocked periodically
with rainbow  trout,  lake trout, brown trout, steelhead and splake.   All
species were stocked as recently as 1973 and trout were stocked again in
1975-1976.    Smallmouth bass, perch  and  largemouth bass  have  not  been
stocked since the 1930s and 1940s (Michigan DNR 1973).  These species do
not thrive as well as trout in the low water temperatures.

b.   Betsie River

     Betsie River supports  a much more abundant and diversified vegeta-
tive population than does Crystal Lake.  Detritus*  from decaying grasses
and vegetation  along the shoreline supply  the river with nutrients for
plant  growth.  Dense filamentous  algae and weed beds have been observed
at  various  stream   segments  (Michigan DNR  1973).   "Clean  water"  in-
vertebrates  such  as caddis  larvae, mayfly larvae  and  crustaceans are
natural  food  sources for the fish population as are the more population
tolerant worms (Michigan DNR 1973).

     The Betsie River  is a popular year-round sport  fishing  stream.   The
river  is  an spawning stream for  trout, chinook  salmon, coho and steel-
heads  (by  telephone,  Tom  Doyle,  Michigan  DNR,  November  1977; Michigan
DNR  1973).  A  1965  stream survey  (DNR)  showed  a  diversified resident
fish population.  Appendix Table  G-2 shows  fish  species collected during
this  study.  The  warm  temperatures  in the  Betsie River  do not favor
trout, but  several species of coarse or rough fish  are present.
                                    80

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c.   Betsie Lake

     No information on  the  aquatic  biology of Bestie Lake  was  available
other than  the  records  from the Michigan Department of  Conservation  on
fish  stocked  there.   Brown trout  and  rainbow  trout were  stocked  in
Betsie lake in 1972.

2.   WETLANDS

     Wetlands are highly productive  but  fragile  ecosystems,  where  flora
and fauna require saturated or seasonally saturated soils for growth and
reproduction.   Figure 11-11  shows the  location of wetlands in  the  Study
Area.  Wetlands  are found  along  the Betsie River, along  the  shores  of
Round Lake  and in  an  area  northwest  of Long Lake.  No wetlands  exist
along  the   shoreline  of Crystal  Lake.  Wetland  formation  is  probably
deterred here by wave action and the scouring action of  ice.

     The wetland  types  in  the  Study Area  are mainly wooded swamps and
cattail marshes.  These wetlands  are characterized in Table 11-12  with
respect to flora, fauna and their location.

     In natural  resource production and preservation wetlands  serve  to
assimilate pollutants by acting as  settling and/or filtering basins and
to  collect  sediments as  a  result  of  their  shoaling*  characteristics.
Wetlands also  act as a natural buffer  against  water quality  problems
associated with shore development.   Furthermore,  wetlands serve as  flood
water  retention areas  and  also  as prime  natural  recharge areas for
groundwater.

     Wetlands are currently  afforded Federal protection under  Executive
Order 11990, which mandates that no  construction  project granted Federal
funds may  adversely affect  wetlands unless  reasonable  alternatives  do
not exist.

     In the State of Michigan wetlands  are  under  the jurisdiction of the
Department  of Natural Resources.  The  extensive  wetland areas  along the
Betsie River  are protected from  certain  types  of development by the
Betsie River Natural River  Zoning Act  (Appendix  D-3).   Several Michigan
laws, including the Inland  Lakes  and Streams Act,  and the Soil Erosion
and Sedimentation Control Act,  also  protect wetland areas.

3.   TERRESTRIAL BIOLOGY

     As a result  of agricultural  and residential expansion,  the present
forest consists largely of second- or later-generation sugar maple,  elm,
yellow birch, beech and basswood; it also  contains a variable  admixture
of hemlock  and white pine  throughout,  as  well as  occasional  stands  of
aspen  and  birch.   Stands  of red pine  have been  planted  in some  open
areas and abandoned  fields  (Michigan DNR 1973).

     Wildlife  in  the  area   provides  many  hours  of recreation  for the
hunter, sightseer and naturalist.   White-tail deer, cottontail rabbits,
                                    81

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ruffed grouse and woodcock  are  common,  especially in the lowland brush
and coniferous areas along the Betsie River.   Beaver,  muskrat,  mink,  and
other small  mammals have been  observed  along the entire length of  the
Betsie River.   Squirrels,  chipmunks, woodchucks,  and an occasional  red
fox occupy the  woodlands  and  open fields above the Betsie  River.  Many
species of  small rodents such  as mice  and voles inhabit both lowlands
and uplands of the Study Area.

     The many streams  and  lakes offer numerous stopover points for both
ducks and geese on their autumn and spring migrations.  There  is a resi-
dent  flock  of Canada  geese  near Elberta; mallards,  black  ducks, blue-
wing  teal, wood  ducks  and coots are other common  waterfowl  hunted along
the  entire  Betsie  River (Michigan  DNR  1973).   A  list of vertebrates
whose ranges include the Study Area is provided in Appendix  G-l.

4.   THREATENED OR ENDANGERED SPECIES

     Michigan has  an active  endangered  and threatened  species program
complementing that  of  the  Federal government and  has  published lists of
animal and plant  species  it would classify as endangered or threatened.
Michigan Public Act 203 of 1974, provides protection for species classi-
fied  Endangered*  or Threatened* on the  Federal list  or  listed and con-
firmed for protection  by the  State.  The Act authorizes a  full range of
conservation  management programs  for these  plants  and animals.    The
Michigan program  recognizes two other categories  -- rare or scarce,  and
peripheral -- but species in these categories have no  legal  status under
the Michigan Act  (Michigan  DNR 1976).  A list of  Endangered,  Threatened
or rare species  of  wild flora and  fauna  that  occur or may  occur in  the
Study Area is included in Appendix G-2.

     No species of  fish,  reptiles, or amphibians known  to  occur in  the
area  has  been  classified by  either the US  Fish and Wildlife Service
(FWS) or the DNR as Endangered or Threatened (by telephone,  Mr. Bernard
Ylkanen, District  Fisheries Biologist,  DNR, Cadillac Division,  26 June
1978).

     Although no  mammalian species  in  the area has  been classified by
the  State  or FWS as Endangered  (by letter,  Mr. Robert Huff,  District
Wildlife Biologist, DNR,  Cadillac Division,  5 July  1978; FWS  1978),  the
Study Area lies within the range of several species  of mammals listed by
the  State  as Threatened  or  rare.   According  to  Mr.  Huff, some of  the
smaller birds and mammals on the Michigan list may occur occasionally in
this  area,  but  up-to-date  population data are not available  for these
species.

     There is an  active bald  eagle nest on the headwaters  of  the Betsie
River,  and  an  active  osprey  nest  nearby  in Grand Traverse  County.
Neither nest is  in  the Study Area,  but  the  birds may find  prey in area
waters, which are  in  easy flying distance.   Both  species are  classified
by FWS  and DNR  as Threatened.  The area is also within the  range of  the
peregrine  falcon,   classified  as   Endangered,  which  may  visit  on rare
occasions.
                                    83

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     The  Study  Area  lies  within  the  range  of several  plant  species
classified by Federal and  State  agencies  as Threatened.   They were not
identified  during on-the-ground  surveys  conducted  in 1977  and  1978.
However, local residents have  identified  and confirmed the  existence  of
three such  plant species  in  the Study Area --ram's head lady slipper,
pitcher's thistle,  and  broom  rape  (by  telephone,  Mr. Rick Habert and
Mr. Arvid Tesker,  Frankfort City,  Michigan, 7  August 1979).   Because
there is some  danger in  disclosing the  locations of  rare plants the
sites have  not  been  publicized.   However,  the habitats  of these  rare
plants are outside any proposed construction area.

     Failure to  observe  most  of  these species  during the  surveys  does
not  dispel  the  possibility of their presence  in  the Study Area.  The
Michigan Endangered Species Program is  presently engaged in  inventorying
and mapping endangered,  threatened,  and rare animal  and plant  species  in
the  State.   If  this, or other studies  should reveal  the  presence  of  a
listed  species   during   on-the-ground  investigations,  the  appropriate
protective provisions of Federal  and State  laws would come  into  effect.
E.   POPULATION AND  SOCIOECONQMICS

     The existing information on population,  employment,  income,  poverty
level,  and housing  has been  published separately  for each  municipal
jurisdiction in the Study Area.  Taken together,  these  data  describe  the
"Socioeconomic Study  Area," an  area  that  is  somewhat  larger than  the
Study  Area.   The  "Proposed Service  Area,"  which is made  up of  those
areas proposed in  the  Facility Plan for sewering, is also  smaller than
the  Study  Area,  covering  only portions of  the  three Townships in  the
Study  Area,  Lake,  Crystal  Lake  and Benzonia  (see Figure 1-4).  Conse-
quently,  the  published information  cited  in  this  section  generally
describes, but  cannot precisely  reflect  characteristics of  the actual
populations  of either  the  Study  Area or  the  Proposed Service  Area.

1.   POPULATION

a.   Historic Trends

     Historic trends in permanent (year-round) population for the Socio-
economic  Study Area and for Benzie County as a whole are  presented by
decade  from  1940  to 1975 in Table  11-13, which  reveals  that 87% of  the
population growth  in the  County during this  period  took  place in  the
three  townships  of the  Socioeconomic Study Area.  The  region approxi-
mating  the Proposed Service  Area had an average annual growth  rate of
1.4%,  with  the  highest absolute  change  in population   occurring  in
Benzonia Township.

     More  recently,  between  1970  and  1975,  average  annual rates  of
growth  of  the  permanent   population  of  some political units  of  the
Crystal  Lake Study Area  have been higher  than 1.4%,  illustrating  the
increasing popularity  of Crystal Lake as a year-round residential  area.
The  exception was  Crystal  Lake Township,  which  showed almost no  net
change  in permanent population in that period.
                                    84

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     There are no data available on the seasonal population of the Study
Area before  1972.   In that year,  it was estimated that the  Study Area
attracted over 6,200  seasonal  residents.   This population  grew to 8,300
in  1975   (Wilbur  Smith and  Associates 1973;  Grand  Traverse Area  Data
Center 1975,  1977), reflecting  an average annual growth rate  of  almost
10%.  Of  the  1975  total,  48% of the  seasonal  population resided  within
the Proposed Service Area.

     The  permanent/seasonal population split  varied considerably  among
jurisdictions.   Frankfort City,  Elberta  Village  and  Benzonia Village
were each composed  almost entirely of permanent population.   Lake Town-
ship and  Crystal Lake Township,  on the other hand, had large  seasonal
populations,  89% and  82%, respectively, of their total in-summer popu-
lations,  plus the  highest increases  in absolute  numbers.   These  in-
creases underscore  the attractiveness  of  the two areas for  recreation
and second-home development.

b.   Population Projections

     The  assumptions  and  methodology used in  preparing the  projections
for the Proposed Service  Area  are provided in Appendix H.   The popula-
tion projections  are based on historic housing and population character-
istics and trends.  Other factors  that influence actual growth, such as
aesthetics,   availability   of  services  and  housing sites,  changes  in
housing types, and regional economics, were  not incorporated.

     The total in-summer  population of the  Proposed Service  Area  in the
year 2000 is  projected to be approximately 12,500, a  47%  increase over
the 1975  figure.  The average  annual growth rate for the 28-year  period
from 1972 to  2000  is  expected to be 1.5%,  slightly higher  than the his-
torical rate  of  1.4%.  The  largest absolute  increase in  combined per-
manent and seasonal population is projected  for Crystal Lake  Township --
nearly  2,000  additional  persons  or  83%  by 2000  -- while  Benzonia
Village,  Beulah  Village  and the  City of Frankfort are expected  to  in-
crease by only 10-20% in  that time.

     Summary  estimates of  permanent and seasonal population and average
annual growth  rates for the  years 1975 to 2000 for the Proposed Service
Area are  presented  in Table  11-14.  This information  is given by minor
civil divisions in Table H-2  in Appendix H.

                              Table 11-14

               POPULATION  PROJECTIONS AND AVERAGE ANNUAL
       GROWTH RATES FOR CRYSTAL LAKE PROPOSED SEWER SERVICE AREA

Population                         Average Annual      Absolute Change
Component	1975    2000    Growth Rate (1975-2000)   (1975-2000)

o Seasonal     4,098   6,742           2.0%                 2,644
o Year-round   4,420   5,748           1.1%                 1,328
o Total        8,518  12,490           1.5%                 3,972
                                    86

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     Because the  various  communities within  the  Proposed Service Area
are not expected  to  grow  at equal rates, each locality's percentage of
the total population will  change  slightly  over this period.   Also, for
the entire Proposed Service Area,  the proportion of  permanent population
is projected to decrease from 52%  of  the  1975  total  in-summer population
to 46% in the year 2000.

     In summary,  all  the  communities  are  expected to  grow  during the
planning  period.   Population  growth  will  be  greatest in  those com-
munities that are  presently  the most populous.   However, the 1975 dis-
tribution  of  population  within   the Proposed   Service Area  is  not
projected to change greatly  by  2000, and the  permanent/seasonal popula-
tion  split  and the relative  size of  the  population  in each community
will change only slightly.

2.   CHARACTERISTICS  OF THE POPULATION:  EMPLOYMENT AND INCOME

a.   Permanent Population

     This  section presents  information  on the  income   levels,  poverty
population,  elderly  population and  employment characteristics  of the
Study Area.   These characteristics  were chosen  because of their  rele-
vance to  the financial  impacts  of wastewater treatment  alternatives on
households in the area.

     The Crystal Lake Socioeconomic Study area is  characterized by rela-
tively low  income  levels  for the  permanent  population.   The mean  family
income was $9,163 in 1970 in the Study Area  and $8,659 in Benzie County,
75% and 71% respectively,  of the  mean income  for  the State of Michigan.
In that year,  the most  recent for which data are  available, only 37.8%
of the families  in the  Study Area had incomes over  $10,000, as compared
to 57.1% of families  in the State (US Census  1970).  Despite the rela-
tively  low  income  level   in  the  Socioeconomic Study Area,  however,  a
comparatively small  proportion  of the population fell   below Federally
established  poverty  levels  --  6.0%   as  compared  to 7.3%  of  the  State
population  (Table  11-15).  An  important  factor in the income levels of
the area  is its  predominantly  rural character and relative remoteness
from large employment centers.

                              Table 11-15

                     POVERTY STATUS-FAMILIES 1970

                         Number of Families     Percent  of Families
	Area	        Below Poverty Level   Below Poverty Level

Michigan                      160,034                 7.3
Benzie County                     245                 11.2
Study Area                        102                 6.0
Benzonia Township                  43                 4.3
Crystal Lake Township              12                 9.9
Frankfort City                     42                 8.9
Lake Township                      5                 4.9

US Census of Population and Housing,  Fifth  Count Summary Data, 1970.
US Census of Population - 1970,  Supplementary  Report issued December
1975.
                                   87

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     Retirement population  (age  65 and  over)  made  up 177o of the  Study
Area's population  in 1970, as compared  to  8% of the State of  Michigan
(Department of  Commerce,  Bureau  of Economic Analysis 1970).  Many per-
sons  in  this  retirement age group  are  living on low or  fixed  incomes.

     Service  occupations  have represented  a  steadily  increasing  pro-
portion of Benzie County employment since 1950.  By  1970,  such vocations
formed  the largest  employment  sector,  accounting  for  28.3%  of  all
employed  persons.   Increases  in  the  service  and  retail trade  sectors
have been the  response to the growing  importance of  tourism  in the  area;
much  of  the total  retail sales in Benzie County have been attributed to
the tourist industry.   Tourist expenditures  as a percentage of retail
sales  grew from  26% in  1967  to  45% in  1972 (Michigan Department  of
Commerce  1975).   Employment in agriculture  has declined since  1940  to
only  7.2%  of  the  labor  force in 1970.   The  only large  industrial  plant
in the Study Area is Pet, Inc.

b.   Seasonal  Population

     Most  seasonal  residents in the  Crystal  Lake  Area  appear  to  come
from  other parts of Michigan.   A  survey  of summer  visitors to Benzie
County by the  Data Research Center (1978) indicated  that 64.3% came from
southern Michigan, 10.1%  came  from Canada,  13.0% came from Great  Lakes
states other  than  Michigan,  and  5.8% came from other areas.   The survey
also  indicated  that most  seasonal  visitors come to  the  area regularly
and that  the  aesthetic  quality of the area,  its  location convenient to
metropolitan  centers  in southern  Michigan,  and the  presence  of friends
and relatives are major attractions  (by telephone,  Nancy Hayward,  Data
Research  Center,  February  1979).   Establishment of the Sleeping  Bear
Dunes National Lakeshore Park has contributed to a large recent  increase
in  seasonal use  of the  area and is expected  to bring about further in-
creases in the near future.

     No  direct  data  on  the age,  income, or occupational characteristics
of  summer residence owners  in the Study Area  or Proposed  Service Area
are available.  The  value  of the seasonal homes  in the  area  (generally
in  the $50,000 to  $60,000 range  in  1979) indicates  that most  seasonal
residents  are upper  or upper  middle  income.  From  the limited  data
available,  it  appears  that seasonal residents  generally  have higher
per-family and  per-capita  incomes  than permanent residents  of the  area.

3.   HOUSING

      In  1970,  the  Crystal  Lake Socioeconomic Study Area contained  3,647
dwelling  units.   Of  these  units,  1,946  (53%)  were  occupied year round,
and 1,701  (47%) were occupied on a seasonal basis.  More than 82% of the
permanent  dwellings  in the  Study  Area  were  owner-occupied in  1970 and
over  half  (55.6%)  were  built before  1940  (Table  II-16).  Median values
of permanent  residences in Benzie County were considerably lower than in
the State  of  Michigan in 1970:   $10,882 vs. $17,589.  These  lower values
reflect  the rural  nature of the area,  the  age of the permanent housing
stock, and the lower level of family  income.

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                          Table 11-16

HOUSING CHARACTERISTICS OF THE SOCIOECONOMIC STUDY AREA (1970)



                               Number               Percent

 Total Dwelling Units          3,647

 Permanent                     1,946                 53.3

 Seasonal                      1,701                 46.6

 Of the Permanent Units:

    Occupied Units             1,574                 80.9

    Vacant Units                 372                 19.1

 Of the Occupied Units:

    Owner-Occupied             1,304                 82.8

    Renter-Occupied              270                 17.2

 Age of Permanent Housing
   Stock:

    Built after 1965             184                  9.5

    Built between 1939 and
      1964                       680                 34.9

    Built before 1940          1,082                 55.6
    US Census of Housing.   1970.   Summary Data.
    US Census of Housing.   1970.   Fifth  Count  Summary Data.
                               89

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     Dwellings outside presently sewered  areas  were counted from aerial
photographs in 1976.   The count revealed that there were 1,093 dwellings
in the presently  unsewered  parts  of the Proposed  Service Area  and that
about 500  or 46%, of these were within 300 feet of Crystal  Lake.   The
study also  indicated that  there were  about 100 vacant lots  within 300
feet of the Lake which could be developed with septic tanks.

     Despite  continued county-wide  growth,  in the four years  from 1974
to 1977 issuance  of  septic  tank permits for  the  Crystal  Lake area fell
26% from the  previous  four  years  (Health Department 1977).   Reasons for
this change have  not been explained but it is presumed to be due to the
more stringent permit requirements  implemented in 1972.

4.   LAND  USE

a.   Present Land  Use

     Current  use  of  land in  the  Study  Area is shown  in Figure 11-17.
Major uses include the following:

     o    Small urban  centers,  including the communities of  Frankfort,
          Benzonia,  Beulah, and Elberta with a core of residential and
          commercial  uses

     o    Single family  seasonal and permanent  residential  areas around
          Crystal Lake,  Lake Michigan,  Long Lake,  and along major roads

     o    Agricultural areas devoted to row crops and orchards

     o    Woodlands

     o    Open  land   consisting of  wet  woodlands,  wetlands arid  sand
          dunes.

     The patterns  of non-agricultural  development in  the  Crystal Lake
region  have  been shaped  by  a  combination of   topography,  aesthetic
amenities,  transportation  and  such  characteristics  of  the soils  as
slope, drainage and permeability which determine the suitability of land
for development.   Outstanding  recreational  opportunities  and scenery —
lakes, streams, woods and hills —  have stimulated considerable residen-
tial development.  Although building  to the north and  south  of Crystal
Lake is limited  by steep slopes to a single tier in some  locations, off
the  Lake  there  are  grid patterns  of  development  on the  rolling sand
dunes west  of Crystal Lake  and in  the  Village  of Beulah at the eastern
end.

     Most  commercial areas  are in village  centers  or along  the main
highway, US 31.   Commercial development elsewhere  includes  local con-
venience  stores  such as  groceries  and  tourist-oriented  facilities in-
cluding lodging.   Industrial  areas  occupy a small  portion of  the Pro-
posed Service Area along US Route 31.  The largest industrial establish-
ment in the area is Pet,  Inc.
                                    90

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91

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     The greatest potential for future commercial  development within  the
Proposed Service Area exists  along  the land adjoining  the  access  routes
between the Sleeping Bear Dunes National Lakeshore Park north of Crystal
Lake and  the more populous areas to  the  south of the Study Area.   In-
creased  tourism  in the  Lakeshore  Park and  expanding  permanent  and
seasonal populations are  expected to  swell  the volume of  traffic  along
US Route 31  and Michigan Routes 22  and 115.  The  area  also includes  the
Betsie River,  designated "a  natural  river" by the  State   (see Section
II.B.I, II.B.6 and Appendix D-3).

b.   Growth Management Policies and  Regulations

     Development within  the Study  Area  is  regulated by State, county,
and local  ordinances.  The  most important regulatory measures  affecting
development in lakeshore areas are:

     o    The  Inland Lakes   and  Streams  Act,  Michigan State  Act  346
           (1972);

     o    The Soil Erosion and Sedimentation Control  Act, Michigan State
          Act 347 (1972);

     o    The  Comprehensive  Development  Plan  for  Benzie County;  and

     o    Zoning ordinances for the Townships  of  Benzonia, Crystal Lake
          and Lake and the Village of Beulah.

     The Inland Lakes  and  Streams  Act sets general guidelines and  re-
quires persons wishing to build on submerged lands, i.e., on areas lying
below  the  ordinary high  water  mark,  to obtain a  permit.    Should  it be
necessary, DNR may sue in the circuit court of  the appropriate  county to
enforce compliance with the terms of the permit.

     Under the Soil Erosion and Sedimentation Control Act,  all  construc-
tion activities  that would disturb  one or more acres  of  land,  all con-
struction  activities  within  500 feet  of  the  shore of a lake,  river or
stream, and  any construction  activity that would  cause sedimentation in
surface  waters  are  regulated through  a  permit  system administered by
designated  county  agencies,  in this  case  the Benzie  County  Community
Development Department.   The  Act  imposes  limitations upon  tree cutting,
removal  of vegetative cover,  and  cut  and  fill operations. Mitigating
measures to  control runoff  from  construction sites must  be taken,  and
designated officials  may enter  and inspect sites at  reasonable  times.
The  DNR must  conduct an on-going  appraisal  of  soil erosion  control
programs to ensure compliance; a permit may be  revoked upon a  finding of
a  violation  (R 323.1704  Permit Requirements,  Rule 704(1),  Michigan 1974
Annual Administrative Code Supplement).

     The Comprehensive Development Plan for Benzie County classifies  the
following  types  of areas  as environmentally sensitive:

     o     Excessive slope areas
     o     Dune  formations and major sand areas
     o     Areas  with other soil limitations
                                    92

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     o    Marshland areas
     o    Riverine areas
     o    Lake Michigan and inland lake shorelines.

     In the Plan, these areas were combined into a "zone" that traverses
other land use boundaries.  Although this special critical area designa-
tion  does  not dictate  how land may  be used,  it  does  set restrictions
that must be considered in planning any future developments.  In any en-
vironmentally sensitive areas already under development, the Plan stated
that  new  development must  be  designed to  minimize impact  on environ-
mental quality.

     In the County's Plan, most of the land surrounding Crystal Lake was
designated as  medium density residential.  This  category set expansion
areas of  "suburban" density  for  major growth  centers  based on antici-
pated population  levels  for each village or area.  A range of densities
from  1  unit  per  3  acres  to  1  unit per  acre  (near the  major  growth
centers) was established for these developmental buffer areas, which are
intended to  provide adequate  land for single  family development  of  a
lower density  than in  villages without encouraging the spread of higher
densities into the rural areas of the County.

     Most of  the  remaining  land  in the Study Area,  largely rural, has
been  designated   rural/agricultural  density residential.   Densities  in
this  category  were set still lower --  at  less  than 1 unit per 3 acres.
These  densities   are  designed  to  discourage  haphazard  development  of
prime agricultural lands and  to  encourage denser  development near the
villages, which often already have public services.

     Benzie County allows townships and villages  to  adopt local  zoning
ordinances  which  support  county  zoning   within  their  jurisdictions.
Varying  ordinances are  in  effect in  Benzonia Township,  Crystal  Lake
Township,  Lake Township  and  the  Village  of  Beulah.   The  only  zoning
district  common   to  all areas is  the one-family  residential district.
Even  within  this  district minimum lot  sizes,  shoreline  setbacks, and
permissible uses  differ  (see  Table 11-17).  Furthermore,  Crystal  Lake
Township allows  only single  family dwellings  and  accessory buildings,
but  harvesting of  forest products in  residential areas  is permitted.
Lake  Township also  allows  churches,  schools,  and non-commercial re-
creational facilities  in residential  areas.   Benzonia Township  is the
least restrictive  of the local jurisdictions:  allowing multiple-family
dwellings, resorts and tourist homes in residential  areas.   The  varia-
tions  among  township  ordinances  present  possible  problems  in  future
planning  and  provision  of  sewer  capacity in  the  Crystal  Lake  area.
Provision of  sewers  might attract condominium type development to those
areas in which it is permitted.

     The variations  among the townships'  definitions  and allowances  of
uses may present a problem in future planning for the Crystal Lake area.
It may be necessary for the townships to coordinate their growth manage-
ment  activities  in order to ensure that continuing development activity
will be consistent with established water quality objectives for Crystal
Lake.
                                    93

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                               Table  11-17
                 MINIMUM  SHORELAND ORDINANCE STANDARDS
Township

Benzonia



Crystal Lake
Lake
  District

Residential
Agricultural-
Residential

Residential
Commercial-
Resort
Summer Camp-
Recreational
Retail

Residential
Lot Size
(Sq. Ft.)

  6,000
  6,000
  8,500

  5,000
  Building Setback
from Shoreland (feet)

Front Building Line*
          5

          5

          5
          5
 15,000
*Front Building Line is defined as the average distance from the lakeshore
  to the front wall or portions thereof of all dwellings fronting on the same
  lakeshore, which are within 100 feet of both sides of the proposed building.

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c.   Recreation

     The  Crystal Lake  area is  a well-established  recreational  center
based upon diversified scenic and sports amenities.   Crystal Lake  itself
is  a center  for sailing,  water  skiing,  fishing  and  swimming.    Lake
Michigan is also a water sports center.   Betsie Bay is a marina for Lake
Michigan  craft  and  is  the  site of the historic  Betsie  Bay Lighthouse.
The Platte River, just  to the north of the  Proposed Service Area is an
outstanding salmon  fishery.  A variety of non-water based  recreational
opportunities are  also  found  in  the  area.   These  include  facilities
based  on the  rolling  topography  of the  area and  manmade  sightseeing
attractions.    Crystal  Mountain Ski  Resort  attracts winter  visitors,
while  the annual National   Soaring  and Gliding  Festival  at  Frankfort
attracts  summer  visitors.   Other tourist  attractions include tours of a
paper  factory  and a  pottery factory.   Benzonia, Beulah, and  Frankfort
have a  total  of 14  motels  (Western Michigan  Tourist Association  1978).

     The  most  important factor  in future  recreational  development and
tourist visitation to the  Crystal Lake area  is the Sleeping Bear Dunes
National  Lakeshore,  located immediately north of  the  Proposed Service
Area.   The National  Lakeshore  was first proposed in 1950 and designated
by  Congress  in  1970.   The  Park was formally  established in  1977.   The
Park is  still  in its early  stages of development,  and  much of the land
within the Park boundary is still privately held.   The establishment and
development of  the  Park have been the  subject of a  great  deal of con-
troversy.  Many local citizens opposed establishment of  the Lakeshore,
while  proposals  for wilderness  areas  (1974) and a  scenic  corridor and
road (1977) have also been controversial.   The Platte River Wilderness,
just to the  north  of the  Crystal Lake area, is one of  six wilderness
areas  proposed   in  the  National Lakeshore.   The  National  Park Service
favors  the designation  of  the Platte River area  as a wilderness.  Such
designation would make  pressure  from  population growth  in the Crystal
Lake area especially critical.  One alternative development  plan for the
Park includes a scenic corridor and low speed scenic highway (comparable
to the Blue Ridge Parkway) for the Crystal  Lake Highlands area (National
Park  Service  1978).    A  study  produced  in   1977  defining the  scenic
corridor  and highway  was   issued  in  1977   but  was withdrawn  by  the
National  Park  Service  as  a result of  local controversy  and lawsuits
(League of Women Voters  1978).

     Total visitation at  the Sleeping Bear Dunes Lakeshore  in 1978 was
estimated  at  800,000 visitor  days.   Enough  land has been  purchased by
the  Park Service in  the  last  few years  to  permit  development of more
extensive  hiking and skiing  trails.   As a result,  visitation has been
increasing by  about  10% per  year.  Development  of a  visitor center,
interpretive center,  and  scenic corridor  route are  still at  least 8 to
10 years  away,  however,  because of budgetary limitations (by telephone,
Mr. Max Holden,   Sleeping  Bear Dunes National  Lakeshore,  9  April  1979).
A  study by the  Upper Great Lakes Commission (1972),  although somewhat
out-of-date,  did classify  the  portion of the  Crystal Lake  area west of
US Route  31  as  an area  of "high development potential"  as the result of
creation  of  the National Lakeshore.  However, traffic  generated  by the
National  Lakeshore  in  the  Crystal Lake area is not  believed to  be a
problem in the foreseeable future.

                                   95

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5.   ARCHAEOLOGICAL AND HISTORICAL RESOURCES

     One site within the Study Area, the Mills Community House, has been
listed on  the National  Register of Historic Places.   Built in 1900 as
the women's dormitory of Benzonia  College, it is a two-and-a-half-story
structure located on the southeast  corner of Michigan and Walker Avenues
in the Village of  Benzonia.  The building  was  remodeled in 1925 and is
now used as a library and community center  (by telephone, Mrs. Sherwood,
the  Historic Conservation  and  Recreation Service,  1  February 1979).

     Four possible archaeological sites within the Study Area boundaries
have  been  recorded  by  the  Great  Lakes  Branch of  the  University of
Michigan, Museum of Archaeology.   Three of these, in Lake Township, may
have been early  villages.  The  fourth, in  Crystal Lake Township, may be
an Indian  mound  or series of mounds.  According to  John Halsey of the
Michigan State History  Division,  the  actual  locations and  compositions
of the  sites are  not  known,  and  remains  may  have been destroyed  long
ago.   Mr.  Halsey has indicated  that  an archaeological  survey  will be
required by his agency prior to  any construction to verify the existence
of any sites  that  may be impacted  by  the selected alternative  (by tele-
phone, 24 January 1979).
                                    96

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                              CHAPTER III

                            ALTERNATIVES
A.   INTRODUCTION

1.   GENERAL APPROACH

     New  alternative  systems were  developed  for wastewater  collection
and treatment in  the  Proposed  Crystal Lake Service Area.  This  chapter
presents  eight  "EIS  Alternatives".  It  compares designs  and  project
costs to  those  of the Proposed Action of  the  Crystal  Lake Area Facility
Plan (Williams  and Works,  et al.  1976), described in Chapter  I, above.
Chapter  IV  assesses  the environmental and socioeconomic impacts of all
these systems.

     The  EIS  alternative  has focused on those aspects and implications
of the proposed wastewater management plan for the Proposed Service Area
which (a) have  been  identified as major issues or concerns,  or  (b) were
not adequately addressed in the Facility Plan.

     Chapter  I  of this EIS,  emphasized that  an important issue is the
overall need for the project proposed in the Facility  Plan.   Documenting
a  clear  need  for  new  wastewater  facilities  may,  on  occasion,  be
difficult,  requiring  evidence  that  the  existing on-lot  systems are
directly  related  to  water  quality  and public  health problems.  Such  a
need  is  shown  when  one  or  more   of  the following conditions  exist
(Illinois Environmental Protection Agency 1977):

     o    Standing pools  of  septic  tank effluent or  raw  domestic sewage
          in  yards or public areas  where direct  contact with  residents
          is likely.

     o    Sewage  in  basements   from  inoperable or  sluggish  sewage
          disposal systems.

     o    Contaminated  private wells  clearly associated with sewage
          disposal systems.

     The  Proposed Service Area exhibits  some indirect evidence of the
unsuitability of site conditions for on-site soil disposal  systems.  The
evidence  includes  high groundwater,  slowly permeable soils, small lot
sizes, proximity to lakeshores and substandard setback distances  between
wells and private wastewater facilities.  Available information on  these
factors  were, in fact,  used early  in  the preparation of this  EIS to
develop  the decentralized  alternatives  designated EIS Alternatives 3,  4
and 5.
                                    97

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     Indirect  evidence  is  insufficient to  justify  Federal  funding,
however.   Federal  water pollution  control  legislation and  regulations
require documentation of actual water quality or public health problems.
Section  II.C  summarizes  the  extensive  efforts  mounted  during  the
preparation of this  EIS  to document and quantify  the  need for improved
facilities around Crystal Lake.

     The dollar cost of the Facility Plan Proposed Action  and its impact
on  area   residents  make   cost   effectiveness   as   serious   as   need
documentation.  Since the collection system accounts for the major share
of  the  construction  costs  in the Facility  Plan Proposed  Action,  the
extent  of sewer  lines needed and  the  use  of newer  technologies  for
wastewater  collection have  been  investigated  in  detail  here,  as  have
alternative wastewater treatment systems.  The technologies assessed are
listed below:
             WASTEWATER MANAGEMENT COMPONENTS AND OPTIONS
Functional Component

Flow and Waste Load
Reduction
Options
Collection of Wastewaters
Wastewater Treatment
Processes
Effluent Disposal
Sludge Handling
     household water conserva-
     tion measures
     ban on phosphorus
     rehabilation of existing
     sewers to reduce
     infiltration and inflow

     limited service area
     pressure sewers
     vacuum sewers
     gravity sewers

     conventional centralized
     treatment plus chemical
     treatment to reduce
     phosphorus concentrations
     land application
     on-site treatment
     cluster systems
     rotating biological
     contactor

     subsurface disposal
     land application
     discharge to surface
     waters
     greywater recycling

     anaerobic digestion
     dewatering
                                    98

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Sludge Disposal                         -    land application
                                            landfilling
                                            composting

     Next,   appropriate   options   were   selected  and   combined   into
alternative systems.  Design criteria in the pertinent  state  and  local
codes, given  in  Appendix F, were  followed. The  alternatives  were  then
compared.   The last  section of this  chapter  considers implementation,
administration and  financing of the alternatives.

2.   COMPARABILITY OF  ALTERNATIVES:   DESIGN  POPULATION

     The various alternatives for  wastewater management  in  the  Service
Area must  provide  equivalent  or comparable levels of  service if  their
designs  and   costs  are  to  be  properly  compared.   In  the  following
comparison  of   alternatives the  design population of  12,490 has  been
assumed (see  Section C.l.c below and Appendix H).

     The same year  2000 design population has been used as the basis for
all  the  EIS  alternatives and the  Facility Plan  Proposed Action in the
interest of equitable comparison;  it  must be  recognized, however,  that
each  alternative  carries its own  constraints  and that  the  wastewater
management system chosen may determine much of  the Crystal  Lake area's
actual population in the  year 2000.

3.   COMPARABILITY OF  ALTERNATIVES:   FLOW  AND  WASTE
     LOAD  PROJECTIONS

     Design  flows  for  centralized  treatment  facilities and for  the
cluster systems  are based on a design  domestic sewage flow of 60  gpcd in
residential  areas  for  both permanent  and  seasonal   residents.   This
figure increases  to 70  gpcd  for Frankfort, Benzonia Village  and Elberta.
The  reasons  for  these  per  capita  design flows  are outlined  in  Section
C.l.b  of  this  chapter.   Infiltration  and  inflow  (I/I) into  gravity
sewers  was   added   to   the calculated   sewage   flow   in   appropriate
alternatives.

     The design flow used in the Facility Plan  for the Proposed Action
was  100 gpcd, including  I/I.  To compare costs properly in  this  EIS, it
was  necessary to re-calculate flows  for the Proposed Action  using  flows
developed for the EIS alternatives; this was done.
B.   COMPONENTS  AND OPTIONS

1.   FLOW  AND WASTE REDUCTION

     Methods that  reduce  the flow or  pollutant  loads can provide  the
following benefits to a  wastewater management program:

     o    Reduce  the  sizes  and  capital costs  of  new sewage  collection
          and treatment  facilities;
                                   99

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     o    Delay the time when future expansion or replacement  facilities
          will be needed;

     o    Reduce  the  operational  costs  of pumping  and treatment;  and

     o    Mitigate the sludge and effluent  disposal  impacts.

     In the Proposed Service Area residential  flow reduction devices  and
a ban on phosphorus detergent are techniques that may be used  to  achieve
these benefits.

a.   Residential Flow Reduction

     Appendix  I  discusses  a  number  of   residential  flow   reduction
devices.  Of  these, dual-flush  toilets  and flow-restriction devices  for
shower  heads  and faucets  reduce  flow  the   most  for  the  least  cost.
Proper  use  of these  devices  can  reduce  consumption of water by  an
estimated  16  gpcd.  EIS Alternative  2  (see  Section  III.C.2.e)  was  re-
designed and  recosted  using a design flow based  on  44 gpcd to evaluate
the cost-effectiveness  of  widespread  use  of these devices.  Section  C.5
discusses  the engineering  and economic significance  of flow  reduction.

     Briefly,   use  of  these  devices  in   sewered   residences  saves
sufficient  capital costs  to be  cost-effective  locally.   Use  of flow
reduction  devices reduces  water  supply  and   heating costs.   If  these
savings  are  added  to  applicable  savings  in  operation  and maintenance
costs, the Crystal Lake homeowner could  save  of $112 annually.  Appendix
1-1 reviews the technical basis of these savings calculations.

     Flow  reduction  devices  are  also useful  with on-  or  off-site  soil
disposal  systems.   Such  systems  may  last   longer  because   hydraulic
loading   is  reduced.    Because   no   long-term  evaluation   has  been
undertaken,  the increased   lifespan  and  the  resultant  economic  benefit
cannot  now  be  quantified.   Installation of these  devices   should  be
attractive  to residents, reducing their own  water supply and hot  water
heating costs as well as wastewater disposal costs.

     Several  other  flow  reduction  measures  providing  even  greater
reductions  in  sewage  generation  are available.  As  an example,  some
residences  require  holding  tanks  because the soils  are  unsuited  to
subsurface  wastewater  disposal  and other methods  of  disposal  are  not
available.   In such cases,  wastewater  flow  may  be  reduced  to  15 - 30
gpcd by the following methods:

     o    Reduce  lavatory  water usage by  installing  spray  tap faucets.

     o    Replace  standard toilets with dual  cycle  or other  low volume
          toilets.

     o    Reduce   shower water  use  by  installing  thermostatic mixing
          valves  and  flow  control  shower  heads.  Use of showers should
          be  encouraged  rather than baths whenever possible.
                                    100

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     o    Replace  older  clothes  washing  machines  with those  equipped
          with  water-level  controls   or  with  front-loading  machines.

     o    Eliminate  water-carried  toilet  wastes   by  use  of  in-house
          composting toilets.

     o    Use recycled bath and laundry wastewaters to  sprinkle lawns in
          summer.   The  feasibility  of  this method  would  have  to  be
          evaluated on  a trial basis  in the planning area  because  its
          general applicability is not certain.

     o    Recycle  of  bath and laundry wastewaters  for  toilet flushing.
          Filtering and disinfection of bath and laundry wastes for this
          purpose  has  been  shown  to be   feasible  and  aesthetically
          acceptable   in  pilot  studies   (Cohen   and  Wallman   1974;
          Mclaughlin   1968).    This   is  an  alternative   to  in-house
          composting  toilets  that  could  achieve the  same  level  of
          wastewater flow reduction.

     o    Commercially  available  pressurized toilets  and  air-assisted
          shower heads using a common air compressor of small horsepower
          would  reduce  sewage volume  from  these  two  largest household
          sources up to 90%.

b.   Michigan  Ban on Phosphorus

     Phosphorus  is  frequently the nutrient  controlling  algae growth in
surface waters and is therefore an important influence  on lake or stream
eutrophication.  Enrichment  of  the waters with  nutrients encourages  the
growth of  algae and  other microscopic plant life; decay of the  plants
increases biochemical  oxygen demand,  decreasing dissolved oxygen in the
water.   Addition of  nutrients  encourages higher  forms  of  plant  life,
thereby hastening  the  aging process  by which a  lake evolves into a  bog
or  marsh.   Normally,  eutrophication  is  a  natural process  proceeding
slowly over thousands  of  years.   However,  human  activity  can  greatly
accelerate  it.   Phosphorus and other nutrients, contributed to  surface
waters by  human wastes,  laundry detergents and   agricultural  runoff,
often  result  in over-fertilization,  over-productivity of plant  matter,
and "choking" of a body of water within a few years.  Section II.B.7  and
Appendix  E-4 discuss the process and  data pertinent for the  Crystal Lake
Study Area.

     In  1971  the Michigan legislature limited the  amount of phosphorus
in   laundry   and   cleaning  supplies   sold   in  Michigan  to   8.7%
(Michigan-Public Act  226,  Cleaning  Agent  Act).   To  reduce phosphorus
concentrations in wastewater further,  the Michigan Department of Natural
Resources  subsequently banned  statewide  the use  and  sale  of  domestic
laundry  detergents  containing more  than 0.5% phosphorus.  By May  1978,
according  to  monitoring data, influent phosphorus  concentrations  at 20
wastewater treatment plants had decreased from an average of 6.5  mg/1 to
4.3 mg/1  (by  telephone,  Mr. Mike Stiffler,  DNR, Water  Quality Division,
1  August  1978).   These  figures  corresponded   to a  35% reduction  in
phosphorus  entering  the plants.  Figure  III-l  illustrates  these  data.
                                   101

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                                        102

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     Treatment plants and on-site  disposal  facilities  in  the Study Area
could  experience  a  similar  reduction  in  phosphorus   concentration.
However, such characteristics of the  Crystal  Lake  area as  the number of
residential laundry facilities may  differ  from those in the communities
where data were  collected.   Clearly,  the  extent of phosphorus reduction
can only be determined  by  a survey of the  characteristics of the Study
Area.   One  approach to the  reduction of  phosphorus  is to require that
household detergents be free of  phosphates.

     Reduction of phosphorus  by  control of detergents  will not achieve
the  effluent  discharge limits  of  1  mg/1   set  for   Betsie  Lake (see
Appendix   D-4  for  Effluent  Limits),    Consequently,   provision  of
facilities  for   phosphorus   removal  i^v treatment  plant  operation  is
required.  The phosphorus ban would ndt affect on-site systems because
the  effluent  limitation only applies j to  treatment  plants discharging
into surface waters.

c.   Rehabilitation  of Existing Sowers  To Reduce Infiltration
     and Inflow
     Infiltration/Inflow Analyses condu
the  Facility  Plan  revealed  that infiltration
sewer   systems   and  that  combined  s
significant inflow.   Rehabilitation of
beginning with sewer  system  evaluation
in  the  Facility  Plan.   The  costs  and
rehabilitation effort are incorporated
Action.
 ted in Frankfort  and Elberta  for
        was  substantial in both
ewers  in  Frankfort  result   in
  sewers  in both  municipalities,
 surveys  (SSES), were recommended
 irojected flow reduction for  the
 n all  EIS  Alternatives  except No
     While  this EIS  is  not evaluating
of  sewage  from its  sewers  may be  one
loads  and  bacterial contamination  in
should be investigated.

2.   COLLECTION

     The collection system proposed in
cost $14 million  --  76% of the total cost of the proposed  action  —  and
is the  single  most  expensive  portion o
not all parts  of  collection systems ar
alternatives for Beulah,  leakage
 of the causes for high nutrient
  Cold  Creek.   This possibility
 he  Facility Plan  is  estimated to
f  the  sewerage  facilities.  Since
;  eligible for Federal and State
funding, the costs  of  the collection system impact the  local  community
more  than  other  components  of  the  project.   There  is,  therefore,
considerable incentive  at  local,  state  and national  levels to  choose
less expensive  alternatives to conventional sewer systems.

     Alternative means  of wastewater collection are:

     o    pressure  sewers   (including  grinder  pumps  or  STEP  systems);

     o    vacuum sewers; and

     o    small diameter gravity sewers (Troyan and  Norris  1974).
                                   103

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     An alternative collection  system  may economically sewer areas with
site conditions that increase the cost of conventional sewerage,  such as
shallow  depth to  bedrock,  high  groundwater table,  or hilly  terrain.
Housing  density  also  affects   the  relative  costs  of  conventional  and
alternative wastewater collection techniques.

     The  alternative  most  extensively  studied  is  collection  by  a
pressure  sewer  system.   The principles  behind  the  pressure  system and
the  gravity  flow system are  opposite  to each other.   The  water system
consists  of  a  single  point of  pressurization  and a  number   of  user
outlets.   Conversely,  the  pressure sewer  system has  inlet points  of
pressurization and a single outlet.   Pressurized wastewater is generally
discharged to the treatment facility or to a gravity sewer.

     The  two  major  types  of pressure sewer systems are the grinder pump
(GP)  system  and the  septic tank effluent  pumping  (STEP)  system.   The
differences between  the two  systems  are in the on-site equipment and
layout.   The  GP system employs individual  grinder  pumps to  convey raw
wastewater to the  sewer.   In the STEP system septic tank effluent from
individual households is pumped to the pressure  main.

     The  advantages of pressure sewer systems are:

     o    elimination of infiltration/inflow;
     o    reduction of construction cost; and
     o    use in varied site and climatic conditions.

The  disadvantages  include   relatively high operation  and maintenance
cost,  and the requirement  for  individual home  STEP systems  or grinder
pumps.

     Vacuum  sewers  provide similar advantages.   Their major components
are vacuum mains, collection tanks and vacuum pumps, and individual home
valve  connection systems.   A recent review  of  vacuum sewer technology,
however,  noted  significant  differences among design of four major types
of current systems (Cooper  and Rezek 1975).

     As   a  third  alternative  to  conventional  gravity sewers,  small
diameter  (4-inch)  pipe  can be used if septic tank effluent, rather than
raw  waste,  is  collected.   Such  pipe  may  result  in lower  costs  of
materials,  but  the systems retain some  of  the  disadvantages of larger
sewers.   The  need for deep excavations and  pump  stations is unaffected.

     This document  analyzed  the   reliability,  site  requirements,  and
costs  of the alternative  sewer systems  considered  for the Crystal Lake
area.   The  STEP-type  low-pressure sewer   system  was  found  the most
advantageous  of  the  three alternatives.    A  preliminary  STEP system
serving   residents  around  Crystal  Lake  was,  therefore,  developed  to
determine the differences  in  project costs  if  it were substituted for
the   gravity  system  specified  by   the  Facility  Plan.   Assumptions
regarding the  design and  cost of  the  low pressure  sewer  system are
listed  in Appendix J-l.  Figure III-2  illustrates the  arrangement of the
STEP  system house pump and  sewer line  connection.
                                    104

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3.   WASTEWATER TREATMENT

     Wastewater treatment options  include  three categories:  centralized
treatment prior  to  discharge  into surface water; centralized treatment
prior to disposal on land;  and decentralized treatment.

     Centralized  treatment  means  the  treatment  at  a  central  site of
wastewater collected  by a single system  and  transported  to  a central
location.  Centralized treatment systems may  serve all  or  a part of the
service  area.   Centrally treated  effluent  may be discharged to surface
waters  or  applied to the land; the  method and  site  of disposal affect
the treatment process requirements.

     "Decentralized   treatment"  defines  those  systems   processing  a
relatively small amount of  wastewater;  options include "package plants",
cluster  systems,  and individual septic systems.   This  EIS will assess
the  technical  feasibility,  relative costs, environmental  impacts, and
implementability in the Crystal Lake Study Area  of these  approaches to
wastewater treatment.

a.   Centralized Treatment —Discharge to  Surface Water

     The Frankfort and Elberta  primary  treatment plants cannot meet the
State  of Michigan's  effluent standards  for  Betsie   Lake.   Aside from
excessive hydraulic and organic loadings,  much of  the equipment, at the
two plants needs  repair  or  replacement.   In assessing the  potential for
expansion and upgrading of  these two  plants, the Facility Plan concluded
that   expansion   and   upgrading  of   the   plants  were  not  feasible,
principally because  of insufficient land  for  remodeling  or additions.
It  proposed   a  new  treatment  facility,  designed  around  rotating
biological contactors.  Such a facility, complete with suitable addition
of chemicals,  could  meet appropriate  effluent  limitations.

b.   Centralized Treatment — Land Disposal

     Land treatment of municipal wastewater uses vegetation and soil to
remove   many   constitutents   of  wastewater.    Several  processes  are
available  that  can   achieve  many  different  objectives  of treatment:
water   reuse,  nutrient  recycling   and   crop  production.   The   three
principal types of land application  systems are:

     o    Slow rate  (irrigation)
     o    Rapid infiltration (infiltration-percolation)
     o    Overland flow.  (EPA 1977)

     The quality  of  effluent  required  for  land  application in terms of
BOD and suspended solids is  not  so  high  as that for stream discharge.
Preliminary wastewater  treatment  is needed to  prevent  health hazards,
maintain high  treatment efficiency  by  the soil, reduce soil clogging,
and insure reliable  operation of  the distribution  system.  The Michigan
Department  of  Natural  Resources   (DNR)   requires   the  equivalent  of
secondary  treatment  prior to  land  disposal.   (Personal communication,
Steve Eldridge, DNR, 30 March  1978).
                                   106

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     A  recent memorandum  from  EPA may  alter  Michigan's  approach  to
pretreatment  prior  to  land   application.    To  encourage   both  land
treatment  and land  disposal  of wastewater,  EPA  has  indicated  that:

          "A universal minimum of secondary treatment for  direct surface
          discharge...  will  not be  accepted because  it is inconsistent
          with the basic concepts of land treatment.

          ...the  costs of the additional preapplication  increment needed
          to  meet  more stringent preapplication treatment requirements
          [than necessary]  imposed  at  the State or local  level would be
          ineligible for Agency  funding  and  thus would  be paid for from
          State or local funds."  (EPA 1978)

     Land treatment systems require  wastewater storage during  periods of
little or no  application caused by  factors such as unfavorable weather.
In  Michigan  storage  facilities for  the  winter months  are  necessary.

     The  EPA  policy   has  important  ramifications  for   land  treatment
alternatives.  By  allowing Federal  funding of land used for  storage and
underwriting  the  risk  of  failure for certain  land-related projects the
policy promotes their consideration.

     The  land application  component of  the  alternatives  in  this  EIS
includes  the  treatment and storage  facilities provided by the Facility
Plan (see Figure  III-3), but woodland spray irrigation  is the method of
final  disposal  in the  new  system.   Considerations in  selecting  the
method of land application  and a potential site are discussed  in Section
II.A.S.b.

c.   Decentralized Treatment

     Figure 1-4  shows  the  Facility  Plan proposed centralized  collection
and treatment of wastewaters for the entire Service Area.  The costs for
the  proposed wastewater   management  plan,  evaluated  in   terms  of
individual households, were  high.   Because most of those  costs were due
to  sewers,  this  EIS  examines  methods   of  wastewater  treatment  not
dependent on extensive sewer systems.

     Several technologies can provide decentralized treatment  at or near
the point of generation.  These are:

     o    Alternative toilets

               Composting toilets

               Toilets using  filtered and disinfected bath and laundry
               wastewater

               Waterless toilets  using oils  to  carry and store wastes

               Incineration toilets
                                   107

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108

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     o    On-lot treatment and disposal

               Septic tank and soil-disposal systems

               Septic tank  and  dual,  alternating  soil-disposal  system

               Aerobic treatment and soil-disposal system

               Septic tank  or  aerobic treatment  and  sand filter  with
               effluent discharge to surface waters

               Septic tank and evapotranspiration system

               Septic tank and mechanical  evaporation system

               Septic tank and elevated sand mound system

     o    Off-lot treatment and disposal

               Cluster  systems  (multiple  houses  served  by  a  common
               soil-disposal system)

               Community  septic  tank  or  aerobic treatment  and  sand
               filter with effluent discharge to surface water

               Small-scale  lagoon  with seasonal effluent  discharge  to
               surface water

               Small-scale    lagoon    with   effluent   discharge    at
               rapid-infiltration land application site

               Small-scale  lagoon  with seasonal effluent  discharge  at
               slow-rate land application  site

               Small-scale,    fabricated   activated   sludge   (package)
               treatment  plants  with  effluent  discharge  to  surface
               waters.

     To assess decentralized alternatives  first requires comparison with
centralized   alternatives.    The  feasibility   analysis,   design,   and
construction  cost  estimation of decentralized  alternatives is entirely
different from the centralized systems. Most decentralized alternatives
depend  to   a  large  extent  on  such   environmental  constraints   as
topography,  geology,  groundwater,  climate,  and soil  conditions  within
the Service Area.  (Conversely,  sewers are both feasible and reliable in
nearly  all  settings  where  construction  is  possible;  environmental
factors  primarily   affect   constructions   costs.)   In  addition,   the
selection   and   design   of   decentralized   alternatives   must   be
site-specific,  particularly with  respect  to  existing  buildings.   The
feasibility analysis  and design of  sewers may  be performed  with  less
site  data  than the  decentralized  alternatives because  standard  design
criteria are unlikely to be voided by site conditions.
                                   109

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     The  importance  of  site-specific  factors implies  that design  and
estimates of feasibility of  decentralized  alternatives  are  less  certain
than for  centralized alternatives.  Quantitative  statements will  not be
available until  the engineering  of  decentralized alternatives becomes
better   established  and  more  experience  in  their  management   and
monitoring has been gained.

4.   FLEXIBILITY

     Flexibility measures system ability  to accommodate  growth  or  future
changes  in  requirements.   This section examines  the flexibility  of  the
components  within each  alternative  and the  operational  restraints on
each  and design  of the facilities.   These are  discussed  in  terms of
their  impacts  upon  choices  of  systems  and decisions  of planning  and
design.

a.   Transmission and Conveyance

     For  gravity  and pressure  sewer  systems,  flexibility  is the  ability
to handle future increases  in flow.   The  ability  to  handle flows  greater
than  the original  design  flow  is  generally  low,  and an  increase in
capacity  is  an   expensive  process.    Also, the  layout  of  the  system
depends  upon  the  location of  the  treatment  facility.   Relocation or
expansion  of   a   finished  facility  would  require  costly redesign  and
addition of sewer.

     Both gravity and pressure  sewers  require  minimum sewage velocities
to  prevent  deposition  of  solids  which   could  cause  blockage.   The
velocity  of the  fluid  in gravity sewers  depends  mainly  upon pipe  slope.
Contour  of  the  ground  surface  largely  determines pipe slope and  depth,
and  consequently,  construction  costs.   Pressure sewers, however,  can
carry sewage uphill under pressure,  not depending upon slope to maintain
the  flow velocity;  they  offer the designer  somewhat  more flexibility
than gravity flow pipe.

b.   On-Site  Septic  Systems

     Septic systems are flexible in  that  they  can be custom  designed  for
each user.  As long as  spatial  and environmental  parameters  are met,  the
type of system can be chosen according  to individual requirements. This
flexibility is  useful  in  some  rural  areas where centralized  treatment
would be neither cost effective nor  desirable.

     Existing  septic  systems   can   be  expanded by  adding   tank  and
drainfield  capacity,  if suitable land  is  available.   Flow can then be
distributed to an added system with little disturbance  of  the existing
one.

     Cluster  systems  are  septic  systems  treating wastewater  from more
than  one  house,  usually  15  to  24.   The  flexibility  for design  and
expansion of  such a system is  somewhat less than for a standard septic
system.   Sizes of  cluster systems  range  from one-quarter  to  one-half
acre,  a  substantial increase  compared  to  a standard septic system  (of
about  1000  square feet).   Right-of-way requirements for  piping must be
                                   110

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considered because the  system  crosses  property boundaries  and  may  cross
public property.   The location of  other underground utilities such  as
water, electricty,  gas,  and telephone  must also be  considered in the
design.

     An  alternative  system  for  on-site  sewage treatment,  such  as  an
elevated sand mound,  is  required  where siting restrictions prohibit the
use of  standard septic  system  and centralized collection of  sewage  is
not available.   In  these  cases  future expansion may  be difficult  or
impossible.  Stipulations of the  health codes restrict  the potential  of
the alternative systems for alteration or expansion.

c.  Rotating  Biological  Contactor  (RBC)

     The use  of rotating biological  contactors to treat  wastewater  is
relatively new  in the  United  States.   The  RBC rotates circular  discs
covered  with  a film  of  aerobic  bacteria  in a basin  through  which
wastewater  flows.    The  disc   is  usually   40% submerged  for aerobic
treatment.

     RBCs  are  simple  to  operate.   They   are similar  in  theory   to
trickling  filters, used  in  the United States since  1908.   The  RBC  units
do  not  require  sludge  recycling,  nor maintenance  of  a  suspended
microbial  culture  like by  activated  sludge.   The  relatively simple
operation,  therefore, makes operational flexibility  high for RBC plants.

     The modular nature  of  RBC reactors makes expansion or upgrading  of
the plant  relatively  easy.   With  proper design of other  components and
proper planning of the facility layout, the  cost and effort required for
expansion  may be  relatively  small.   RBCs are therefore well suited for
projects to be constructed in phases over an extended period.

     RBCs  require  relatively shallow  basin  depths  (6-8  feet) -- another
advantage.   Less  structural  strength  is required for the  basin because
water volume per square foot of basin area is reduced.  Therefore,  there
is more  leeway in  choosing  a  site because  structural  requirements are
lower, and a greater  variety  of soil  types and ground  conditions are
available  for locating the RBC  units.

     There are several disadvantages to the  RBC reactor.   The many  discs
usually required limit design flows to the range of  0.1  to 20 mgd.  This
limitation results from the large requirements for land.   The mechanical
components  have relatively  low  salvage value,  and  converting the RBC
units to another  type  process  may be costly if these components can not
be reused or sold.

d.   Land  Application

     To  be   flexible,  a   land   application  system   should operate
efficiently under  changing  conditions,  and  should be easily modified  or
expanded.   These   factors  depend  largely  upon geographical  location.

     The ability to  handle  changes  in treatment requirements and waste-
water  characteristics  is a  specific  measure of flexibility for a land
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application facility.   Furthermore,  the level of treatment  provided  by
the land application system will in part determine whether it can handle
possible increases  in flows  in the future.  Wastewater  in  the  Crystal
Lake Study Area consists primarily of domestic sewage and future  changes
in composition of the wastewater are not likely to occur.  If industrial
wastewater  were  added  in the  future, pretreatment  at  the industrial
source may be required.

     Expandability  is an  important  element of  flexibility.   Efficient
and economical land acquisition for future flow  increases  depends  upon
the proximity of  the facility to populated areas,  design and layout of
the  system,  additional  transmission  requirements,  and the  type  of
application  system  used.   A  number  of  application  mechanisms   are
available --  spray,  overland  flow,  or rapid infiltration.  Sites can be
forest land, cropland, or open fields.  Attention must be paid, however,
to  characteristics  of   the  surrounding  land,  and  to   possible  future
changes  in  land   use.   Also,  requirements are  strict  concerning  the
hydraulic and geologic  conditions  of the proposed site.  When initially
planning the  facility,  all of the above mentioned  conditions should  be
taken into  consideration if  maximum flexibility for future expansion is
desired.

     Cost of  the  land accounts  for much of the  capital cost for a  land
application  facility,  and greatly affects  the possibility of expansion
or ease of discontinuing the site.   Because land normally appreciates in
value,  the  final salvage value  of  the site may be very high after the
expected 20-year  design  life.   If  the site  is  abandoned,  much of the
initial capital cost of the facility may be  recovered  by reselling the
land  at the appreciated price.  Note, however,  that the public: may be
reluctant because  of its former use to use the  land; this would depend
largely upon the appearance of the land at the time of resale.

     Finally,  operational flexibility  of  land  application  systems  is
highly  dependent  upon  climate.   When heavy rains  saturate  the  soil or
flooding occurs,  treatment efficiency  is  greatly  reduced.   Where  cold
temperatures  might make  land application  unusable,  storage facilities
are  required.   Very  cold  climates  require up to six months of  storage
capacity.   Rapid  infiltration  is  the only land  application technique
used successfully  in very cold  temperatures.

5.   RELIABILITY

a.   Sewers

     Gravity Sewers.  When possible,  sewer systems allow wastewater to
flow  downhill  by  force of  gravity.   This  type  of system, known  as
gravity  sewer,  is  highly  reliable.   Designed  properly,  such  systems
require  little  maintenance.   They  consume  no   energy  and  have  no
mechanical  components to malfunction.

     Problems  associated  with  gravity sewers  include  clogged pipes,
leading to  sewer backups; infiltration/inflow, increasing the volume of
flow  beyond the  design level;   and  broken or misaligned pipes.  Major
contributors  to  these   problems  are  improperly  jointed  pipes  and the
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intrusion of tree  roots  into the sewer, which tend to be more prevalent
in older systems.

     Where ground  slope  is  opposite to the direction of sewage flow, it
may  be  necessary  to pump  the  sewage  through  sections of pipe  called
force  mains.    The  pumps  add  a  mechanical  component which  increases
operation and  maintenance  (O&M)  requirements  and decreases  the  system
reliability.   To assure uninterrupted operation of the system, two pumps
are  generally  installed, providing  a  backup in  case one malfunctions.
Each is usually able to  handle at least twice the peak flow.   A standby
generator is usually provided to ensure operation of the  pumps in case
of a power failure.

     Because the flow through force mains is intermittent, solids  may be
deposited during periods  of no  flow.   In  addition,  when  the  pumps shut
off, the  sudden cessation  of flow  may cause the hydraulic  conditions
known as "water hammer" in the force main, a phenomenon marked by sudden
sharp surges in water pressure that may result in burst pipes.  However,
both deposition of  solids  and  water  hammer  may be  controlled through
proper  design  procedures.  The  reliability of properly  designed force
mains is comparable to that of gravity sewers.

     Pressure Sewers.  Pressure  sewers transmit  wastewater uphill when
ground  topography  does not  allow gravity flow.  Because  the  system is
always  under pressure  pumping is required to force  the wastewater into
the sewer

     Grinder Pumps.  Grinder  pumps  are used primarily to grind and pump
raw  domestic  sewage from  an individual house to  the collection  system
and  occasionally  for small  lift  stations.  They   are  either  of  the
semi-positive  displacement  or the  centrifugal type,  depending upon the
mode of operation.   The reliability of both types is  high.

     One problem may arise  during a power failure.  Standby power for a
grinder pump would not usually be  available at  an individual house and
the residence would be without sewage removal.  This  is a lesser problem
than  might  be  supposed,  for  a  power  failure  would  curtail  many
operations that generate wastewater.

     There were problems in  the  operation  of  the  first  generation of
grinder pumps  when pressure to  pump wastewater or power to grind solids
was  insufficient.   Modifications  have been  made in their  design and
construction,  and  the second generation  of these pumps  is  appreciably
more  reliable.   Periodic maintenance  is  required to clean  or replace
parts of the grinder pump.

     STEP Pumps.   It is  sometimes desirable to pump wastewater from an
existing septic  tank rather than directly from the  house,  using  septic
tank effluent  pumps*  (STEP)  rather than  a  grinder  pump.  In this way
difficulties associated with suspended solids are largely avoided.  STEP
pumps are  relatively  simple  modifications of conventional sump  pumps.

     The reliability of  STEP pumps made by experienced manufacturers is
good.   Newer entries  into the field have  not yet accumulated the oper-
ating experience  necessary to  demonstrate conclusively the  reliability

                                    113

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of their products.   In  the  event of failure of a  STEP  system,  an  over-
flow  line  may  be provided, which  permits  passage of  the septic  tank
effluent to the old drainfield  for emergency disposal.

     Pipes.  Pressure  sewer pipes  are  subject  to the same problems  as
force mains,  discussed  above.    As  with force mains,  proper design  can
prevent clogging  and breaking  of pipes, the most  common cause  of  sewer
problems.   Because  pressure sewer piping has no mechanical  components,
the reliability is high.

b.   Centralized Treatment

     Conventional.  The reliability of conventional wastewater  treatment
has been  tested by  time.   Most  unit processes  have been used  for many
years,  and there is consequently much information on their design  and
operation  in nearly  all climates.  In general,  the larger  the  treatment
facility,   the more  reliable its  operation,  because the  large volumes of
flow  require  multiple  units per  treatment process.   For instance,  a
large  facility  will  have  several  primary  clarifiers,   and  if  one
malfunctions,    the   remaining   units   can   handle  the   entire   load.
Therefore, difficulties  that arise  as  a result of failure of  a  single
unit process,  or of severe weather conditions such as  heavy rain or very
cold  temperatures,  are  less likely  to  affect operations.   Conventional
wastewater treatment plants can be designed to  handle most  problems.

     Advanced Treatment.  Advanced  treatment serves primarily  to remove
toxic substances and nutrients  that would stimulate biological  activity.
The technology  is  relatively new; experience in design  and operation of
advanced  treatment  processes   is  therefore  limited.   However,   when
designed properly, the reliability of these  processes  is high.

     Land Application.    Application of  treated  sewage  effluent to  the
land  is still  infrequent in the United States, but its use is growing
steadily.   Local  climatic  conditions  such  as heavy  rains  or   very  low
temperatures  may make  the  technique unsuitable  in a particular  area.

     Potential problems with land application include:   groundwater con-
tamination; dispersal  of microbial  mass by airborne transport;  odors;
surface water  contamination; accumulation of metals in  the  vegetation;
and possible  toxic effects  upon local animals.  These problems can be
minimized  with  proper   design,  but  there   is  not  yet  the  extensive
practical  experience required  to  develop  advanced design  technology.

c.   On-Site Treatment

     Septic Tanks.  The design and operation of modern septic tanks have
benefited  from  long  experience.   Properly designed  and  maintained,
septic  systems  will provide satisfactory  service with  minimum mainte-
nance.  Care must be taken not  to  put  materials  in the system that may
clog  it.   The principal maintenance requirement is periodic pumping of
the tank,  usually every two or three years.

     Problems  of  septic   systems  include   heavy  rain  saturating  the
ground, clogged  drainfields  caused by full septic  tanks, clogged or
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frozen  pipes,   and   broken  pipes.   Current  environmental  laws
restricting sites  according to soil  suitability,  depth to  groundwater
and bedrock,  and other factors --  are limiting the cases where  septic
systems can be used.

     Sand Mounds.  Elevated sand mounds four or five  feet above original
ground  level  are  an  alternative  drainage  mechanism  where   siting
restrictions do not allow  the use  of standard drainfields.  Because  they
do  not always provide  satisfactory service  and  are considerably  more
expensive than conventional  drainfields,  they have not  been  universally
accepted.

d.   Cluster Systems

     Cluster  systems  are   localized   wastewater  disposal   mechanisms
servicing several residences.   The  reliability is  similar  to that  of  a
septic system,  except that  a  malfunction affects not  just  one, but  a
number of residences.  Because  a  cluster system requires more piping  to
connect  individual  houses to the  treatment tank than does a series  of
individual  systems,  there  is  a greater  chance for pipes  to break  or
clog,  or  for  I/I to  occur  during  heavy rain.  If pumping is required,
the reliability  of the  system declines because of  the mechanical  nature
of the pumps and their dependence  upon electricity  for power.

6.   EFFLUENT DISPOSAL

     Three approaches exist  for disposal  of treated  wastewater.   Reuse,
perhaps  the  most  desirable  of  the  three,  implies recycling  of the
effluent  by  industry,   agriculture   or   groundwater   recharge.    Land
application takes advantage  of  the absorptive and  renovative capacities
of  soil  to  improve  effluent  quality  and  reduce the  quantity  of
wastewater  requiring  disposal.   Discharge to  surface  water generally
implies  the  use  of  streams  or impoundments  for  ultimate disposal  of
treated effluent.

a.   Reuse

     Industry Reuse.   There is limited  industrial  development   in the
Study  Area,   The only industry that consumes  significant quantities  of
water  is  Pet,  Inc.   Located in Frankfort, Pet  uses  only potable  water.
There  are no  industries  in the area  that use a significant amount  of
non-potable water, consequently industrial reuse  does  not seem to  be  a
feasible means of effluent disposal.

     Agricultural Irrigation.   The  use   of   treated   wastewaters  for
irrigation is addressed in Section III.6.b.

     Groundwater Recharge.   Groundwater  supplies  all  of  the  potable
water  in  the  Study  Area.   The availability of ample  quantities  of water
from  sand and gravel deposits  is  a  significant resource of the area.
There  is no  evidence that  these  resources  are being  depleted  to the
extent  that supplemental  recharge is  necessary.   Wastewater reuse  by
groundwater recharge has therefore not been evaluated.
                                   115

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b.    Land Application

     Two types of land application are  relevant  to  the  Study Area, rapid
infiltration/percolation    and    agricultural     irrigation.     Rapid
infiltration/percolation  is  presently used  for  final  treatment  and
disposal  of  wastewaters  for  Beulah.   Expansion  of  this  facility or
construction  of  similar  facilities   on   sites within  the  watershed
directly tributary to  the  Betsie  River may be  feasible for other parts
of  the  Study Area.   With  proper selection   of  sites  and  design of
facilities, wastewater could be renovated  to  a  degree which would meet
or  exceed  the  quality  of  effluent  generated  by  more conventional
treatment  processes.    It  would   be   necessary to   collect  renovated
wastewater and discharge it to the Betsie River.

     The  Facility Plan  evaluated  agricultural irrigation  at  a  site
within  Section 31  of Benzonia Township.   This  site, located  in the
Crystal Lake  watershed,  is  divided by  Cold Creek and its  stream  valley.
This EIS  considered two  additional sites:   one  within  the Crystal Lake
watershed,  north  of  the proposed  site in  Township Sections  25  and 30;
and  the  other outside  the Crystal Lake  watershed  and  south  of the
proposed site.  Figure III-3 shows the  locations of the sites.  Soils at
all three sites are moderately to  rapidly permeable.

     Surface runoff could be controlled by  a system of  berms and  storage
cells;  renovated  wastewater by recovery wells.  The  necessity  of  such
management  would  depend upon  a  careful evaluation of  the site.  Costs
associated  with  site management  and   silviculture  of  white  pine in
Township Sections 25  and 30 have  been  incorporated in the evaluation of
land  application alternatives.   Detailed  site  investigations   for the
land  application alternatives  should   consider all three  sites.  All
approaches  to recovery of renovated wastewater  would  include transport
to the Betsie River for discharge.

c.    Discharge to  Surface Waters

     Effluent  from  the  Frankfort  and Elberta  plants  is  now being
discharged  into  Betsie Lake.   In the  Proposed  Action, a new RBC plant
would  discharge  to  Betsie  Lake   from land purchased by the   City of
Frankfort.   It would be  expected to  meet DNR  effluent limitations for
discharge  to Betsie Lake  (see Appendix D-4).   The  DNR has  recommended
that  there  be no discharges to the Betsie  River or to Lake Michigan (by
letter, Mr. Kenneth J. Burta, DNR, 17 November 1976).

7.   SLUDGE  HANDLING AND DISPOSAL

     Two  types  of sludge would be generated by  the wastewater treatment
options considered above:  chemical/biological sludges from  the  proposed
RBC  plant;  and  solids  pumped from septic tanks.   The  residues  from
treatment by  lagoons and land application are grit  and screening.

     The  Facility  Plan  evaluated  several  options  for handling  and
disposing  of sludge  from  by the  proposed  RBC  plant.  These  included:
                                   116

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     o    Incineration and landfill of the resulting ash.
     o    Digestion followed by liquid disposal on land.
     o    Digestion and landfill of the dewatered sludge.
     o    Digestion and land application of the dewatered  sludge.

     For  maximum  flexibility  in  disposal  of  digested  sludges,   the
Facility Plan recommended  structural  measures  accommodating  disposal by
any  of  the  above  methods.    Sludge  drying   beds  would  allow  land
application of  dewatered  sludge under most conditions and would  result
in  reduced  transportation  costs.   Liquid  digested  sludge  could  be
applied to land to conserve drying bed capacity.   The Facility Plan  also
recommended including  sufficient capacity in  the sludge  digesters  for
six months of winter storage.   Sites for landfill or surface  application
of  digested  sludge  were  not  selected but  a  potential  site for  land
application on  Graves  Road in  Crystal  Lake  Township was  identified.

     Alternatives  using residential  septic  tanks  for on-lot  systems,
cluster systems, or STEP sewer systems must provide for periodic  removal
and  disposal  of   sludge.   For  the  purposes  of designing  centralized
wastewater  treatment by  a RBC  plant, processes  for conditioning  and
treatment   of   septage  were   provided.    In    alternatives   including
centralized treatment  by  lagoon and land application, septage would be
applied to the land.
C.   EIS  ALTERNATIVES

1.   INTRODUCTION

a.   Approach

     The  preceding   section  described  options  for   the   functional
components of wastewater  management systems for the communities  in  the
Study  Area.   This  section  examines  alternative wastewater  management
plans  --  alternative  courses of  action for the  Study Area,  including  a
No Action and a Limited Action Alternative.

     The  four  alternatives  developed in  the  Facility  Plan  (described
earlier)  provided   for   centralized  collection   and  treatment  of
wastewater.   In response  to  questions about the need for and expense of
the  Proposed Action,  the development  of  EIS  alternatives  emphasizes
decentralized and  alternative or  innovative technologies:   alternative
collection  systems,   decentralized   treatment   and   land  disposal  of
wastewaters.   The EIS  alternatives  would  manage wastewaters  in the same
Service Area as the  Facility Plan Proposed Action, but  five  of the  EIS
alternatives  use  decentralized treatment  to avoid the costs  of sewers.

     Because  of the  high  cost of collection in  the Proposed  Action,  the
cost effectiveness of pressure sewers, vacuum sewers,  and small-diameter
gravity  sewers  was  compared.  Pressure  sewers proved  to  be  the most
cost-effective,  alternative  method  for  collection  of wastewater.   These
                                   117

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sewers were,  therefore,  incorporated  into the design of two  completely
centralized systems,  one calling for  an  RBC  plant,  the other  for  land
application.

     Where  site  conditions  such  as  soils  and topography are  favorable,
land  disposal   of  wastewater  offers   advantages  over   conventional
biological treatment systems that discharge  to surface waters:   the  land
is used  as a natural  treatment  facility system; reduced  operation and
maintenance may result from relatively simple  operations; and  savings in
capital and operating costs are possible.

     Analysis   of   decentralized   treatment   technologies   and   site
conditions  showed  feasible alternatives to sewering the entire Crystal
Lake  shoreline.   It  would be possible to  combine multi-family  filter
fields  (cluster  systems) with rehabilitated  and new on-site  treatment
systems to meet the wastewater treatment needs in this part of the Study
Area.

     The various alternatives are compared after the  discussion below of
projections of design  populations and flow and waste load  which are the
same for all alternatives.

     Appendix J-l presents the assumptions used in design and  costing of
alternatives  are presented  in Appendix  (J-l).   Table  III-l   lists  the
major features  of the Proposed Action, the Limited  Action Alternative,
and the EIS Alternatives.

b.    Flow and  Waste Load Projections

     The  domestic  sewage  generation  rate  depends  upon the  mix  of
residential, commercial, and institutional sources in the area.  Studies
on residential  water usage  (Witt,  Siegrist,  and Boyle  1974;  Bailey et
al.  1969;  Cohen and  Wallman 1976)  reported  individual  household water
consumptions varying widely  between 20 and 100 gpcd.  However, averaged
values  reported  in those  studies  generally  ranged between 40-56 gpcd.
On a  community-wide basis,  non-residential domestic  (commercial, small
industrial,  and  institutional)  water use  increases  per  capita  flows.
The extents of such increases are influenced by:

     o    the importance of the community as a local  or  regional trading
          center;

     o    the  concentration  of   such water-intensive  institutions  as
          schools and hospitals;  and

     o    the level of small industrial development.

For  communities  with  populations  of  less  than 5,000,  EPA  regulations
allow design  flows in  the range of  60 to 70  gpcd  where  existing per
capita  flow  data  is  not  available.  In  larger communities,  and  in
communities within  Standard  Metropolitan  Statistical Areas,  the maximum
allowable flow ranges up to 85 gpcd.
                                   118

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     The  Facility  Plan  reported  wastewater flows  in  the Crystal  Lake
Facility  Planning  Area to be  65  gpcd for Elberta  (including  Ann  Arbor
Railroad and Gustafson Oil Company) and 74 gpcd for Frankfort (including
commercial flows,  other  than  Pet,  Inc.)-   These figures  relate well  to
the range of domestic flows determined by EPA to be applicable  for  small
communities.

     For  these  reasons,  this  EIS  assumes on  a 70 gpcd  design flow  of
domestic  sewage for  permanent residents  in  Frankfort,  Benzonia,  and
Elberta;  these  municipalities  have several commercial  and institutional
water users.   In primarily residential  areas, including  the  presently
unsewered areas around Crystal Lake, a flow of 60 gpcd  has been assumed.

     Water   consumption   by   seasonal  users  varies  much  more   than
consumption  by permanent  residents.   The  actual  rates  of  consumption
depend upon  such factors  as  type  of accommodations in  the area and type
of recreation  areas  available.  EPA regulations (EPA 1978) suggest that
seasonal  population  can  be converted  to equivalent permanent population
by using the following multipliers:

          Day-use visitor     0.1  to 0.2

          Seasonal visitor    0.5  to 0.8

     A  multiplier   of   1.0   was   applied  to  the  projected   seasonal
population   to   account    for   both  day-use  and   seasonal  visitors.
Considering   the  possible    error   in   projecting  future   seasonal
populations,  the  preponderance  of  present  seasonal  visitors   using
well-equipped  private  dwellings   and  the  lack  of  data  on  day-use
visitors,  this  multiplier  was  thought  generous,  i.e.,  it  probably
overestimates flows to some degree.

     The  two design  flow figures  of  70  and  60  gpcd  do  not  reflect
reductions  in  flow from  a program of  water  conservation.   Residential
water conservation devices,  discussed in  Section  III.B.I,  could  reduce
flows  by  16  gpcd.   Later  in this  chapter,  to  demonstrate  probable
impacts  of  such  reduction in  flow,  one  of  the alternatives  has  been
redesigned and  recosted.

c.    Population Projections

     The  design population of 12,490  is  that population projected  to
reside  in the  Proposed  Service  Area  (Figure 1-4) in  the year  2000.
(This  area  includes  the  immediate  service area  and  a  future  service
area.)   The  methodology  used  to  develop this estimate  is  presented  in
Appendix H, Table H-2.

     In the  interests  of comparability, the same population projections
have been incorporated into  design and costing of all  alternatives.  In
fact, however,  the type  of sewer   service  provided,  that  is, whether it
is centralized  or  decentralized,   may influence the actual  design year
population.  Chapter IV discusses  the importance of this factor.
                                    121

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d.    Development of Decentralized Options

     Although two of the  alternatives  offered in this EIS would  extend
central  sewers  throughout  the  Study Area,  four  would   dispose   of
wastewater by  decentralized  options.   The approach used to  develop  the
latter included the following:

     Identification of sites  where existing on-lot  systems are  known or
are  implied to  be  failing.   The  failure   of  on-lot  systems  may  be
evidenced in several ways:  effluent may rise  to the surface; sewage  may
not  drain  properly into  the system; or the  soil may not renovate*  the
wastewater.  Section  II.C reviews problems  with  the existing  on-site
systems around Crystal Lake.

     Identification of local  environmental characteristics  which  would
limit  the  feasibility  of soil-dependent  effluent disposal.   Sections
II.A.3 and II.C present information on  soil depth to groundwater and  lot
size as they affect the feasibility of  soil disposal systems.

     Screening of technologies  for  their   applicability  in  non-sewered
portions  of the  Proposed  Service  Area.  Section  III.B.3 lists  the
technologies capable of providing decentralized treatment of  wastewater.
Those  which  imply direct  discharge  to Crystal Lake  or  its  tributaries
have been  rejected  and the remainder evaluated as  part of  two different
schemes.   Implicit in both  is  the assumption that on-site  disposal of
wastewaters  would  rely  upon  septic  systems,  off-site disposal,  and
cluster  systems.   The two schemes described  below generate  a  range of
costs  associated with application  of the  various  technologies  on  a
site-by-site basis.

     o    Partial  Sewering  and  Reliance  on  Cluster Systems.    Sewers
          would extend:

               from Benzonia Village along Eldridge Hill Road (to serve
               the northeast shore of Crystal  Lake) to approximately the
               Benzonia Township-Lake Township line, and

               from Frankfort along Route 22 to Crystalia and Pilgrim at
               the southwest corner of  Crystal Lake.

          It  is  assumed   that  sixteen  cluster  systems serving  20-25
          dwellings  each   would   serve  scattered  groups of residences
          along the  lakeshore.   Other  residences would  continue  to  use
          on-lot  septic  systems.   Rehabilitation  of  undersized  and
          failing  on-lot  systems  would  be undertaken and  new on-site
          systems  which  compensate  for  poor soil conditions,   such as
          mound systems, would be  constructed where necessary to replace
          conventional  on-site  systems.  A management  agency,  with the
          authority to acquire  land for  cluster  systems  and easements
          for  access  to on-lot systems,  to monitor groundwater impacts
          of   the   systems,   and  to   perform  routine  and  emergency
          maintenance,  would  be  required.    Design  assumptions  of  a
          typical cluster system are presented in Appendix J-l.
                                   122

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     o    Continued   Reliance   on   On-lot   Systems.    Detailed   site
          investigations  (sanitary  survey,  groundwater  analyses,   and
          soil studies)  may indicate  that partial sewering and  off-lot
          technologies  are  not  necessary   to   remedy  water   quality
          problems.   If  so,   only   rehabilitation  of   failing   on-lot
          systems would be needed.

     Selection of the most reliable  technologies    on   the    basis    of
specificity to the site(s).

2.   ALTERNATIVES

     The action proposed by the Facility Plan has  been compared with the
"do-nothing"  (no action)  alternative,  a  "limited action"  alternative,
and  six  new  approaches  developed  in  this  EIS.   The alternatives,
discussed below,  are summarized in Table III-l,  and Table III-2 lists
the cost-effectiveness of each.

a.    No  Action

     The  EIS  process must  evaluate  the  consequences  of  not  taking
action.  This "no action" alternative  implies that EPA would not  provide
funds  to  support new construction,  upgrading, or expansion of existing
wastewater  collection   and  treatment   systems.    Presumably,   no   new
facilities would be built; wastewater  would still  be  treated in existing
plants and on-site systems.

     If  this  course of  action  were  taken,  additional flows  to   the
primary treatment  plants at Frankfort  and Elberta  would be  prohibited
because the  plants  are  already overloaded and have difficulty  meeting
effluent  discharge  standards.   Existing  on-site  systems in  the Study
Area would continue to be used  in  their present conditions.

     The No Action Alternative is unlikely to be selected.   It  implies
that the  treatment plants at Frankfort and Elberta  would violate NPDES
discharge  conditions when  interim  limitations expired.  Consequently,
new  facilities  to  adequately treat  wastewaters   from  Frankfort   and
Elberta would be needed in the  near  future.

b.    Limited Action

     The "limited  action"  alternative includes a  new treatment facility
for treating  wastewaters  from  Frankfort and Elberta.  This  consists of:

     o    Treatment  of  wastewaters  from Frankfort and Elberta at a new
          RBC  plant  in  Frankfort   discharging to  Betsie Lake.   Design
          flow for the plant would be  0.33 mgd.

     o    Treatment of wastewaters from Beulah at  the Village's existing
          treatment facility.

     o    Decentralized  collection  and  treatment  in all  other parts  of
          the  Study  Area.  Where  appropriate,  malfunctioning   on-lot
          systems  would  be  repaired or  replaced.   For the northeast and
                                   123

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          southeast  shore  of  Crystal  Lake,  detailed  engineering and
          environmental  studies,  performed  during  the  design  phase,
          would  indicate  the most  appropriate technology.   It  may be
          that  these  parts  of  the  Study Area  are  most  suited for
          continued  reliance  upon   septic systems,   or   that  cluster
          systems may  be  required.   Alternatively,  pressure sewers may
          be  required  to  connect  the northwest and southeast shoreline
          areas  to  the existing sewerage  system  in Beulah.  The  costs
          developed  for  this Limited Action Alternative are predicated
          on  the  assumption  that  cluster  systems  will be  required for
          the northeast and southeast shorelines.

     This alternative  would  require  formation  of  a managing agency to
acquire  rights-of-way  and  easements,  to provide routine inspection and
maintenance, to periodically monitor groundwater, and  to collect service
fees.

c.    Facility Plan  Proposed Action

     The Facility Plan recommended  treatment  of all  wastewaters in the
Proposed Service  Area  at  an RBC  treatment facility handling 0.89 mgd.
The plant,  located  in Frankfort,  would   discharge  effluent to Betsie
Lake.    The  plant  would use  chemical  addition  and microstraining for
removal  of  nutrients.    See  Chapter  I  for a  brief  description  of the
Proposed Action.  The  design of the proposed  facilities was outlined in
detail in Chapter 8 of  the Crystal Lake Area Facility  Plan  (Williams and
Works 1976).

     The Proposed  Service  Area and  location  of the proposed RBC  plant
are illustrated in Figure 1-4.   A  list of  the  facilities included in the
design of the plant may be found in  Appendix J-2.

d.    EIS  Alternative 1

     EIS Alternative 1  proposes centralized collection and treatment of
wastewaters as  with  the Facility  Plan, but with pressure  sewers, rather
than gravity, as the collection system around  Crystal  Lake.   The Service
Area would be identical to that proposed by the  Facility Plan.

     The  pressure sewer  system,  collecting  approximately  26%  of the
projected  design  flow,  would  discharge   into  a  force main  north of
Frankfort.   The area  to be  served  by  the system,  the treatment  plant
location, and  the  transmission  line routing are shown  in  Figure III-4.

e.   EIS Alternative 2

     EIS Alternative 2  also modifies an alternative  in the  Facility Plan
to  use  pressure  sewers  around  Crystal  Lake.   In  this  alternative
pressure  sewers  have  been  applied  to Facility  Plan  Alternative 3,
consisting  of  the  centralized  collection of 0.89  mgd of  wastewater,
treatment  in  an  aerated  lagoon   and disposal  by  land  application.
Although the  service  area  is  the  same as for EIS  Alternative  1, the
                                   125

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126

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configuration differs.   In EIS Alternative 2, wastewaters  are  conveyed
to the eastern part  of the Study Area; the previous  alternative routed
wastewater to the west.

     Wastewaters  in  the Study Area  would be  conveyed  to  Benzonia,  as
shown  in  Figure III-5,  and  treated  in an  aerated lagoon.   Treated
effluent would be applied  to  the land by spray irrigation.   A solid-set
irrigation system  for commercially farming white pine was  incorporated
into the design and cost of this  alternative.

     Three  possible  locations  for  the   land  application  system  are
identified in  Figure  III-3.   Design  and costing  assumptions  used  in
developing this  EIS alternative  are  presented in Appendix J-l.   Major
components of  the  alternative and  the  costs  of  these  components  are
listed in Appendix J-2.

f.   EIS  Alternative 3

     EIS Alternative 3 is based on decentralized treatment of wastewater
in part of the Study Area.   However, site conditions  along the northeast
and  southwest  shore of  Crystal  Lake are assumed to  be  unfavorable  for
septic systems,  so  wastewater from these areas would  be  collected  by
pressure sewers as shown in Figure III-6.

     Frankfort, Elberta, and the southwest Crystal  Lake  shore area would
discharge  their  wastes to  a  new RBC  plant  in Frankfort.   Wastewaters
from Benzonia Township and Benzonia Village  would  be treated in lagoons
and  applied  to the  land.   The RBC plant would have a hydraulic capacity
of 0.45  mgd; the laud application system would  be  able to  treat 0.18
mgd.

     The  remaining   portions   of  the  Crystal  Lake  shoreline would  be
served by  a  combination of cluster systems and on-site  systems suitable
to local  soil  conditions.   These areas are shown  in  Figure III-6.  The
preliminary  design,  comparison,  and assessment of  decentralized systems
were based upon the following assumptions:

     Cluster Systems.  Cluster systems  would  be used for those parts of
the  Proposed Service  Area where  small  lot  sizes or soil limitations
preclude  on-site systems.  Sixteen cluster  systems  are assumed  to  be
needed;  suitable soils exist  at  the sites for which these systems  are
proposed.  The costs  developed were based on a "typical" cluster system
that  would  serve  23  residences  located  along the  south  shore  of  the
Lake.

     On-lot  Systems.  Residences not served by sewers or cluster systems
would use  on-lot systems.   This  alternative  would include  a  program of
replacement  and  rehabilitation  of malfunctioning  systems  in  order  to
insure compliance with local health codes.

     The  specific  requirements  for upgrading  existing  on-lot systems
were  estimated  by analysis of the data  presented in the  Crystal Lake
sanitary  survey, the  "Septic  Snooper" investigation, and other environ-
mental data.  Based  upon these,  the following upgrading assumptions (by
                                   127

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shoreline  area)  were  used in  the design  and  costing of  alternatives
involving continued use of on-site systems:

                           Existing Systems

                                        Shoreline  Area
                                   NE    NW    W    SW     SE
Replace septic tanks               50%   50%  20%  60%   60%
Replace drainfields                60%   50%  30%  40%   50%
Hydrogen peroxide renovation       10%   10%  10%  10%   10%
 of drainfield

                            Future Systems

                                                  1980-2000

Conventional septic tank and drainfield              55%
Improved performance system                          20%
 (e.g, dosing system)
Mound systems                                        257o
Hydrogen peroxide renovation                         2% per year
     Design and costing assumptions used in developing EIS  Alternative  3
are presented  in Appendix J-l.   Major components of EIS  Alternative  3
and their costs are listed in Appendix J-2.

g.   EIS  Alternative 4

     The  fourth EIS   alternative  for  the  Crystal Lake  area  includes
decentralized  treatment  of  wastewater  for the  same portions  of  the
Crystal Lake  shoreline as in  EIS Alternative 3.   All other  centrally
collected  wastewaters  would be  treated by  a  land application  system.
EIS Alternative 4 is illustrated in Figure III-7.

     The  central  land  application  system  is similar to that  described
for EIS Alternative 2  but the hydraulic capacity has been decreased to
0.65 mgd.

     Design and cost assumptions used in developing this  alternative are
presented  in  Appendix  J-l.   Major  components  of  the alternative  and
their costs are listed in Appendix J-2.

h.   EIS  Alternative 5

     EIS  Alternative  5  proposes   the  same  partially  decentralized
treatment of wastewater as EIS Alternative 3. Flows from other parts of
the   Proposed   Sewer   Area,  the   northeast   shore,   and   from   the
Crystalia-Pilgrim  area would be  treated  at a  new RBC plant  located in
Frankfort.  As in Alternative 3, the plant design  would include advanced
treatment for nutrient removal and discharge of plant  effluent to Betsie
Lake.  This alternative is illustrated in Figure  III-8.
                                   130

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131

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132

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     The RBC  facility would be  designed along lines  similar to those
developed in  the Facilty Plan  but the  design  flow would be 0.65 mgd.
Design  and  costing  assumptions  used in developing this alternative are
presented in  Appendix  J-l.   Major  components  of  the alternative and
their costs  are listed in Appendix J-2.

i.   EIS Alternative 6

     EIS Alternative 6 proposes  treatment similar  to  that  of Alternative
3.  A  new  RBC plant,  located  in  Frankfort,  would serve Frankfort and
Elberta.  The plant would be designed to remove nutrients; 0.33 mgd of
effluent would be discharged to  Betsie Lake.  An  aerated lagoon land
application  system  would  serve  the  Benzonia  Village  area  and  the
northeast   shore   of   Crystal   Lake.   Wastewater  renovated  by  land
application would  be  recovered  and  0.18 mgd discharged  to  the Betsie
River.

     Cluster systems  would  serve  groups  of houses along the southeast
shore  of  Crystal  Lake.   In  the  remaining part  of  the  Study  Area
continuing  emphasis would be placed  upon restoring and  rehabilitating
septic systems.  This  alternative is illustrated  in Figure III-9.  Major
components  of  the alternative   and their costs are  listed in Appendix
J-2; Appendix  J-l  contains  the  design  and  cost assumptions  used  in
developing this alternative.

3.   FLEXIBILITY

a.   No Action

     The No Action Alternative maintains  the  existing  conditions and
places no additional planning and design restrictions upon the treatment
of wastewater.   Because  no  action is taken at present, the  flexibility
for future  planning is  high  compared to an alternative recommending an
extensive commitment of resources.

b.   Limited Action

     A  new  RBC plant  at Frankfort to  serve  the Frankfort and  Elberta
areas would replace existing primary treatment plants.   Existing  on-site
septic  systems would  be  repaired and upgraded,  and cluster systems or
other  collection techniques would be  employed  for  the  northeast and
southeast shores.  The main benefit of the Limited Action  Alternative is
that  it would meet  environmental  requirements,  while leaving  maximum
flexibility for  future  planning  and  design changes  in  the unsewered
sections of the Study Area.

c.   Facility Plan  Proposed Action

     A  centralized  treatment  facility  for  all  wastewater flows within
the  Proposed   Service Area  would  reduce  the  flexibility  for future
planning  and  design  changes   concerning  wastewater  treatment.   This
alternative would  relegate  the  entire  Proposed  Service Area  to one
treatment  scheme  and involve  an  extensive commitment  of  resources.
However, the  modular  characteristic  of the RBC plant  does  allow some
capacity for expansion if future demands warrant  it.

                                   133

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134

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d.   EIS Alternatives I and 2

     EIS Alternatives 1 and 2 both employ collection by  low pressure and
gravity sewers  and  centralized  treatment of all wastewaters within the
same proposed Service  Area  as  in the Facility Plan Proposed Action.  In
Alternative  1  wastewater  is  treated  by  an  RBC  plant  located  in
Frankfort.   In  Alternative 2  land application near Benzonia is used for
treatment  of  wastewater.  As  with the  Facility Plan  Proposed Action,
these alternatives would  relegate  the  entire Proposed Service Area to a
single  treatment scheme.   The  resulting  commitment  of  resources  and
reduction   in  future   planning  and   design  flexibility   would  be
significant.

e.   EIS Alternative 3

     EIS  Alternative  3  allows  for  future  expansion  and  change  in
treatment  technique  using  a  combination  of  conventional,  land,  and
on-site treatment.   Only  those  areas  not suitable for on-site treatment
would  be  sewered,   thus  reducing  capital  costs.   This  alternative
provides flexibility  for  future  expansion because of  the many modes of
treatment  used.  Also,   the  decentralized  nature  of  the alternative
allows  the flexibility  to  base  future  decisions  concerning  land use
development upon local conditions.

f.   EIS Alternatives 4  and 5

     Alternatives 4 and 5 would serve the same sewered area as suggested
in Alternative  3.    In  Alternative  4,  all  sewered  wastewater  would be
routed  to  a  land application  site in  Benzonia.   With Alternative 5,
sewered wastewater  would be  routed  to a RBC plant  in Frankfort.  Like
Alternative 3,  Alternatives  4  and 5 would rely  upon on-site systems to
treat   wastewater   in  areas  deemed  suitable.   The   flexibility  of
Alternatives  4  and  5 is slightly less than Alternative  3 because  of the
reduced  number  of  suggested  treatment  mechanisms  and  the  reduced
decentralization.  Future expansion would  be slightly more difficult to
plan and design.

g.   EIS Alternative 6

     Alternative  6   calls  for centralized  treatment  of wastewater for
Frankfort,  Elberta,  Benzonia,  and the northeast shore of Crystal Lake.
Remaining  areas  around  Crystal  Lake  would  use  cluster  systems  and
upgraded septic systems.  This  alternative provides a  fair  degree of
flexibility for future expansion because a  combination  of conventional
and  land   application  facilities  are  recommended, making  two  modes of
treatment  available  for  future  expansion.   Also,  because  the  entire
Proposed Service Area  is  not being sewered, the immediate  commitment of
resources  is  not  as  great as the Proposed Action in the Facility Plan.
This allows some  ability  for future expansion and changes in localized
planning.    On  the  other hand,  the absence  of centralized facilities
limits  the opportunities  for development of  additional  building  sites.
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4.   COSTS  OF ALTERNATIVES

a.   Total  Project Costs

     Project  costs  were  grouped  by  capital  expenses,  operating and
maintenance   expenses,  and  salvage  values  of  the  equipment  for each
alternative.   A   contingency  fund  amounting  to  approximately  25% of
capital and  salvage value was  included to provide for such expenses as
engineering    and   legal  fees,   acquisition   of   rights-of-way,  and
administration.  The methodology  and assumptions used  in the analyses
are described  in  Appendix J-l.  Detailed  costs  for each alternative are
presented in Appendix J-2.

     Table III-2  summarizes  present and future project costs for  each of
the  alternatives.   The  analyses  of  total  present  worth  and   annual
equivalent  costs  of  each alternative  are also  presented there.    (Debt
service on financing  the local  share is not included.)

b.    Federal/State  Cost  Sharing  and  Remaining  Local   Costs

     The Proposed Rules  and  Interim Regulations  for the Clean Water Act
of  1977  (EPA  1978)  address Federal  funding  of wastewater collection,
treatment,  and  related  facilities.   Appendix   J-3  summarizes  these
proposals and  regulations.  The 1977 Act  differs  significantly from the
Water  Pollution  Control  Act of  1972.   For example,  Federal funding of
facilities  using  innovative  and  alternative   technologies  has  been
increased from 75% to 85%.

     Michigan's  share  of  the   capital   costs   of  pollution   control
facilities is related to Federal eligibility requirements.   In the past,
the  State has  funded  5% of  those project costs  eligible  for  Federal
funds.  With respect to facilities eligible for  85% Federal  funding, the
State  has   decided  to   maintain  the  same   5%  funding  as   before.
Consequently,  the  remaining local  costs  would  be 20% for  conventional
facilities and 10% for alternative or innovative  ones.

     Some uncertainties  about  local costs will  remain until the extent
of  the collection system that  would be eligible  for Federal funding and
until  the  nature of the management system that would be instituted if
on-lot and  cluster systems  were part of the wastewater management plan
are known.

     The  RBC plant should  be  eligible for 75% Federal funding as the
plant  represents a conventional treatment  technology.  Land  application,
however, is  an alternative  technology eligible  for 85%  Federal funding.
Interceptor  sewers  connecting  Frankfort  and  Elberta  to the RBC plant,
and a  collector  sewer  for the northeast shore were assumed  eligible for
75% Federal  funding.

     Rehabilitation  and  replacement  of  existing on-site  systems and
construction  of   cluster systems  would  be   eligible  for  85%  Federal
funding.  Under  private  ownership the only systems eligible for  Federal
funds  would  be those serving permanent residents.  If the  systems were
publicly owned, both seasonal and permanent residents  could  benefit from
Federal and  State funding.

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5.   ENGINEERING AND ECONOMIC  ANALYSIS OF
     FLOW REDUCTION  DEVICES

     Economies could be effected through use of household flow reduction
devices.  A  listing of  devices  used for reducing residential  flows  is
presented  in Appendix  1-3.   This  Appendix  also contains  cost  data,
equipment lifetimes,  and indication of  the potential savings  of  water
associated with each device.

     The  incremental costs  of flow reduction are presented  in  Appendix
1-2.   Implicit  in  this Appendix  is the  assumption that  installation
costs  would  be   approximately  equal   for  conservation-oriented  and
conventional devices.

     Design  flows  for  the  Facility  Plan Proposed  Action  and for  EIS
Alternatives  1 and  2  could  be reduced from 0.89 mgd  to  0.71  mgd if dual
cycle  toilets and  flow control valves for  shower  heads and  lavatory
faucets were installed in all sewered residences.

     This reduction of  flow would  reduce capital expenses and operation
and maintenance  costs  for  facilities.   To estimate this cost  savings,
Alternative  2  was  re-examined on  the basis  of the  lower design  flow.
Savings in the pressure sewer system are attributable primarily to size
reductions for new  force mains.  The capital costs for  land  application
treatment processes are also reduced.  The total savings  associated with
flow  reduction  for  Alternative  2  amounted   to  $567,000  in  capital
expenditure   and   approximately $8,000  per  year  in   operation  and
maintenance  costs.   In  terms  of economics the  present  worth* of  flow
reduction ($596,000) would  amount  to 3.4% of the total  present  worth of
Alternative 2.

     To achieve these savings local plumbing codes would have to require
flow reduction devices in new housing and, as necessary,  for  replacement
of old fixtures.   The approximate savings over the 20-year design period
is $410,000, equivalent to  $112 per design-year dwelling unit.

     Although costs of flow reduction have not been analyzed in detail
for the  other alternatives,  total  annual homeowner savings  in the  range
of $100  to  $125  have  been estimated for dwellings in the sewered areas.
As  discussed  in  Section  IV.B.I,a, decreased water  consumption  and
heating costs are included in these savings for the homeowner.

     In  unsewered   areas the  savings  are  harder   to  calculate.    The
parameters that  determine whether  or not soil  disposal  systems operate
properly are not well understood.   Consequently, conservative,  empirical
criteria for design are used.  Although reduced design flows  may justify
smaller soil disposal systems, most state agencies are  conservative with
respect to such changes.

     Flow  reduction measures  probably  improve the  operation  of  soil
disposal  systems  and,  therefore,  may  serve as  insurance against  early
failures.   Where rehabilitation of septic  systems  is necessary,  flow
reduction  devices  such  as  composting  and recycling toilets, which may
not be  cost  effective,  may be required to  forestall repeated  failure.

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D.   IMPLEMENTATION

     How a wastewater management plan  is  to  be  implemented depends upon
whether  the  selected alternative relies  primarily  upon centralized or
decentralized  components.   Since most sanitary districts have in the
past  been  designed  around  centralized  collection  and  treatment  of
wastewater,   there   is   a   great   deal   of   information  about  the
implementation of such  systems.  Decentralized  collection  and treatment
is, however,  relatively new and there is  little  management  experience on
which to draw.

     Regardless  of  whether   the   selected   alternative   is  primarily
centralized or decentralized,  four  aspects of the  implementation program
must be addressed:

     o    There must be  legal  authority  for  a managing agency  to exist
          and financial authority for it  to operate.

     o    The  agency must manage construction,  ownership and operation
          of the sanitary district.

     o    A choice must  be  made between  the  several types of long-term
          financing  that  are  generally required  in paying for capital
          expenditures associated with the project.

     o    A system  of user charges  to retire  capital  debts,   to cover
          expenditures for  operation and maintenance,  and to provide  a
          reserve for contingencies  must  be established.

     In  the  following sections, these  requirements  are examined first
with  respect   to centralized  sanitary districts,  then  with  respect to
decentralized districts.

1.   CENTRALIZED DISTRICTS

a.   Authority

     The Crystal Lake Area Facility Plan identified the Benzie  County
Board  of  Commissioners   as  the legal  authority  for  implementing the
Plan's  Proposed  Action.   The  Benzie County  Department of Public Works
would  be  the  operating  division  which  would  construct,  operate and
maintain  the  wastewater  management  system.   Under  Act  185   of  the
Michigan Public Acts of 1957 as amended,  the  County  has  the authority to
implement this  system  and to  contract with the villages, townships and
Frankfort City for services.

b.    Managing Agency

     The  role  of  the  managing  agency  has  been well  defined  for
centralized  sanitary  districts.    In  general,  the  agency  constructs,
maintains  and  operates  the  sewerage facilities.   Although  in fact
different contractual relationships  exist between  the agencies and their
service areas, for the purposes of this document ownership  of the
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facilities  may be  assumed  to  reside with  the  agency.   For  gravity
sewers,  such  ownership  has  traditionally  extended  to   the  private
property.   For STEP  or  grinder pump  stations  connected  to  pressure
sewers several options exist:

     o    The station may be designed to agency specifications,  with the
          responsibility   for   purchase,    maintenance   and   ownership
          residing with the homeowner.

     o    The station may be specified and purchased by  the  agency,  with
          the homeowner repurchasing and maintaining it.

     o    The  station may  be  specified  and  owned  by  the  agency,  but
          purchased by the homeowner.

     o    The  station  may  be  specified,  purchased  and owned by  the
          agency.    Regardless,   however,  of  the  option selected,  all
          residences are treated equally.

c.   Financing

     Capital  expenses  associated  with  a  project  may  be  financed  by
several  techniques,  which  are  discussed  in  detail in Appendix  J-4.
Briefly, they are:
     o
     o
     o
     o
pay-as-you-go methods;
special benefit assessments;
reserve funds; and
debt financing.
     The Facility Plan recommended debt financing in the form of 40-year
revenue bonds  for the  Proposed  Action.   As indicated  in Appendix  J-4,
revenue  bonds  generally  have  not  been  used  in  Michigan;   General
Obligation bonds have been more widely offered.

d.   User  Charges

     User charges are  set  at a level that will  provide for  repayment of
Long-term  debt  and  cover  operating  and  maintenance  expenses.    In
addition,  prudent management  agencies  frequently add an extra charge to
provide a contingency fund for extraordinary expenses and replacement of
equipment.

     The implementation program  proposed by  the  Facility  Plan is  an
example  of  a   scheme  calling  for  a  County to recover the costs  of
wastewater management from the local municipalities.  The municipalities
would,  in  turn,   charge  the  users  of  the system.   Because  of  the
potential  economic   impacts,  the  charges  must  be   carefully  allocated
among  various  classes  of  users.   Recognized classes  of  users  include:

     o    Permanent residents/Seasonal residents
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     o    Residential/Commercial/Industrial  users
     o    Presently sewered users/Newly sewered  users
     o    Low- and fixed-income residents/Active income producers

     Each class of user imposes different requirements on the  design and
cost of each alternative,  receives different benefits, and has different
financial  capabilities.    To  illustrate  the allocation of  techniques
available,  three possible  user-charge  schemes  have been examined  in
Appendix J-5.

2.   SMALL WASTE FLOW DISTRICTS

     Regulation of on-lot  sewage  systems has evolved to  the point where
most  new  facilities   are  designed, permitted  and  inspected by  local
health  departments  or  other   agencies.    After  installation,   local
government  has  no further  responsibility  for these systems  until mal-
functions  become  evident.   In  such  cases  the   local  government  may
inspect and issue permits for repair of the  systems.   The sole basis for
government  regulation  in this  field has been its  obligation  to protect
public health.

     Rarely have  governmental  obligations been  interpreted more broadly
to include  monitoring  and  control of other  effects of on-lot  system use
or misuse.  The  general  absence of information  concerning septic  system
impacts on ground and surface water quality  has  been coupled with  a lack
of knowledge of the operation of on-site systems.

     Methods  of  identifying  and  dealing with  the  adverse  effects  of
on-lot  systems  without building  expensive  sewers are being  developed.
Technical  methods include  both  the  wastewater treatment  and  disposal
alternatives discussed in Section III.B and  improved monitoring of water
quality.   Managerial methods  have already been developed  and are being
applied in various communities as discussed  in Appendix K-l.

     As with  any centralized  district,  the issues of legal  and  fiscal
authority,  agency management,  project financing,   and user charges must
all be resolved by small waste flow districts.

a.   Authority

     Michigan  presently  has no  legislation which explicitly  authorizes
governmental  entities  to manage wastewater  facilities other  than those
connected   to  conventional  collection  systems.    However,  Michigan
Statutes  Sections  123.241  et  seq.  and  323.37  et  seq.  have  been
interpreted as  providing counties, townships, villages  and cities with
sufficient  powers to manage decentralized  facilities (Otis and  Stewart
1976).

     California  and Illinois,  to  resolve  interagency   conflicts  or to
authorize access  to private properties for inspection and maintenance of
wastewater  facilities, have passed legislation  specifically intended to
facilitate  management  of  decentralized facilities.    These laws  are
summarized  in Appendix K-2.
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b.   Management

     The purpose of  a  small waste flow district is to balance the costs
of management with the needs of public health and environmental quality.
Management of  such  a district implies formation of  a  management agency
and  formulation  of  policies for  the agency.   The  concept of  such  an
agency  is  relatively  new.   Appendix  K-3  discusses   this  concept  in
detail.

     The range of functions a management agency may provide for adequate
control  and  use  of decentralized  technologies is  presented  in Table
III-3.  Because the level of funding for these functions could become an
economic  burden,  their costs  and benefits should be  considered in the
development of the  management agency.  Major decisions which have to be
made  in  the  development  of  this  agency  relate  to  the  following
questions:

     o    Should engineering and operations functions be provided by the
          agency or by private organizations under  contract?

     o    Would off-site  facilities  require acquisition of property and
          right-of-way?

     o    Would  public  or  private  ownership  of  on-site  wastewater
          facilities be more likely to provide cost savings and improved
          control of facilities operation?

     o    Are there environmental, land use, or economic characteristics
          of  the   area   that  would  be  sensitive  to  operation  and
          construction  of  decentralized  technologies?    If  so,  would
          special   planning,   education   and  permitting   steps   be
          appropriate?

     Five  steps  are  recommended  to  implement an  efficient,  effective
program for the management of wastewater in unsewered areas:

     o    Develop  a  site-specific environmental  and   engineering  data
          base

     o    Design the management organization

     o    Agency start-up

     o    Construction and rehabilitation of facilities

     o    Operation of facilities

     Site Specific Environmental and Engineering Data Base.   The  data
base should include  groundwater  monitoring, a house-to-house investiga-
tion  (sanitary survey),  soils and engineering studies, and  a  survey of
available technologies likely to function adequately in the area.  This
baseline  information will  provide the  framework   for the  systems  and
technologies appropriate to the district.
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                                   Table III-3

          SMALL WASTE FLOW MANAGEMENT FUNCTIONS BY OPERATIONAL COMPONENT
                       AND BY BASIC AND SUPPLEMENTAL USAGE
   Component
       Basic Usage*
    Supplemental Usage*
Administrative  User charge system
                Staffing
                Enforcement
Engineering
Operations
Planning
Adopt design standards*
Review and approval of plans*
Evaluate Existing systems/
  design rehabilitation
  measures
Installation inspection*
On-site soils investigations*
Acceptance for public
  management of privately
  installed facilities

Routine inspection and
  maintenance
Septage collection and
  disposal
Groundwater monitoring
Grants administration
Service contracts supervision
Occupancy/operating permits
Interagency coordination
Property and right-of-way
  acquisition
Performance bonding
  requirements

Design and install facilities
  for public ownership
Contractor training
Special designs for alternative
  technologies
Pilot studies of alternative
  technologies
Implementing flow reduction
  techniques
Emergency inspection and
  maintenance
Surface water monitoring
                                Land use planning
                                Public education
                                Designate areas sensitive
                                  to soil-dependent systems
                                Establish environmental, land
                                  use and economic criteria
                                  for issuance or non-issuance
                                  of permits
 * Usage normally provided by  local governments at present.
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     A  program for  monitoring groundwater  should include  sampling  of
existing  wells and  possibly  additional testing  of the  aquifer.   Such
monitoring should be  instituted  early enough to provide  data  useful  in
selecting and designing wastewater disposal systems.

     The  sanitary  survey should  include  interviews with  residents and
inspections  of existing systems.   A  trained  surveyor should  record
information on lot size and location; age and use of dwelling;  location,
age, and  type  of  sewage disposal system;  adequacy of the maintenance of
the existing system;  water-using  fixtures;  and problems with the exist-
ing system.

     Detailed site analyses may be required to evaluate operation of the
effluent  disposal fields  and  to  determine the impacts  of effluent dis-
posal  upon local groundwater.   These  studies  may include  probing the
disposal  area; boring  soil  samples;  and  the  installation of  shallow
groundwater observation  shafts.   Sampling  of the  water  table downhill
from  leach fields  aids  in  evaluating the  potential  for  transport  of
nutrients  and  pathogens  through the  soil.   Soil  classifications  near
selected  leach fields may improve correlations between  soils  and leach
field  failures.   An  examination  of  the  reasons  for   the  inadequate
functioning of existing  wastewater  systems may avoid such problems with
the rehabilitation or construction of new systems.

     Design the Management Organization.  Both the Facility Plan and the
EIS have  recommended Benzie County as the agency best suited to managing
wastewater facilities  in  both unsewered and  sewered areas  of  the Study
Area.    An  analysis   of  the  County's  technical  and  administrative
capabilities as  outlined  in   Table  III-3,  should  proceed  concurrently
with  development  of  the  environmental  and engineering  data base.   The
role  of  organizations  such  as  the  Department  of  Health  should  be
examined  with  respect to avoiding interagency conflicts and duplication
of effort and staffing.

     Determination  of the basic and  supplementary management  functions
to be provided will be influenced by the technologies appropriate to the
Study  Area.    In  this respect, the  questions raised  earlier  regarding
formulation of management policies must be resolved.

     The product of these analyses should be an organizational  design in
which  staffing requirements,  functions,  interagency  agreements,  user
charge systems and procedural  guidelines are defined.

     Agency Start-Up.   Once  the structure  and responsibilities  of the
management agency have  been defined,  public review is  advisable.   Addi-
tional  personnel  required for construction and/or operation  should  be
provided.  If necessary, contractual arrangements with  private  organiza-
tions  should  be  developed.   Acquisition  of property  should also  be
initiated.

     Construction and Rehabilitation of Facilities.  Site data  collected
for the environmental and engineering data base should  support  selection
and design of  appropriate technologies  for individual  residences.  Once
construction and  rehabilitation  begin,  site  conditions  may be revealed
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that  suggest   technology   or  design  changes.    Since   decentralized
technologies  generally  must  be  designed  to  operate  within   site
limitations instead of overcoming  them,  flexibility should be  provided.
Personnel authorized to revise  designs  in the field would provide  this
flexibility.

     Operation of Facilities.   The administrative planning, engineering,
and operations  functions listed  in Table  III-3  are  primarily applicable
to  this  phase.   The  role  of  the management  agency would have  been
determined in the organizational phase.   Experience  gained during agency
start-up  and  facilities construction  may indicate  that  some  lower  or
higher level of effort will  be necessary to insure long term  reliability
of the decentralized facilities.

c.   Financing

     The financing of a small  waste flows  district is similar to  that of
a  centralized  district.    Such  financing  was  discussed  in  Section
II.D.I.e.

d.   User Charges

     Although renovation and replacement costs for on-site systems  owned
by  permanent  residents  are  eligible  for Federal  funding,  such  costs
incurred  by seasonal residents  are  not.   The  major difference in the
financing  of  the  two systems  arises  from  the question  of seasonals'
ownership of on-site  systems.   With respect to  the  Study  Area,  where a
significant proportion  of  the users  would be  seasonal, the absence of
Federal  funding would  transfer  a large fraction of the project costs to
the local users.   This  would  be reflected in either 1)  capital  outlays
by  the  users   for  construction,  2)  increased  user  charges  covering
increased local costs or 3)  both.

     User charges  and  classes have been discussed in Section III.D.l.d.
The significance  of  decentralized districts  lies in the  creation  of an
additional  class  of users.    Since residents of such districts may be
differentiated  in terms  of  centrally  sewered   areas  and  decentralized
areas,  user charges  may  differ.   As a result many  different management
functions are conjoined.   For example,  permanent users on septic systems
may be  charged less  than  those  on  central sewers.   Seasonal users on
pressure  sewers may  have  high annual costs associated with amortization
of  capital  expenses;  permanent  users of pressure sewers  may be  charged
less than seasonal users, because Federal funding reduced their share of
the  capital costs.   Alternatively, the management  agency  may  choose to
divide  all  costs equally among all users.   For the analyses in  this EIS,
public  ownership  of  permanent  and  seasonal on-site  systems has  been
assumed.

     Problems  such as these  have not been  adequately addressed by the
historical  sources  of  management  information.   Development  of  user
charges  by small waste flows districts will undoubtedly  be  complicated
by  the  absence  of such historical  records.  EPA  is preparing an analysis
of  equitable means for recovering costs  from users in small waste flow
districts and combined sewer/small waste flow districts.
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                                    CHAPTER IV

                                      IMPACTS
A.   SURFACE WATER

1.   PRIMARY IMPACTS

a.   Eutrophication Potential Analysis

     This section  discusses  the effect  of  nutrient loading associated
with  different  wastewater management  alternatives  upon  the  trophic
status of open waters in  Betsie Lake  and  Crystal Lake.  To  evaluate the
impact of each alternative, nutrient  loading  levels  for phosphorus were
calculated.    Phosphorus  is the  limiting  nutrient  for algal  growth in
most temperate zone lakes.  Phosphorus  is also more  easily  controllable
than nitrogen.

     The major  sources  of phosphorus  for Crystal  Lake and Betsie Lake
were identified earlier  as:

     o    precipitation

     o    septic tank  leachate

     o    tributary

     o    non-point source runoff including drainage  from the immediate
          area around  the  lake

     o    wastewater treatment plant discharge.

Other  sources  known  to   contribute  to  nutrient   loading  including
groundwater,  detritus, waterfowl,  and  release from  sediments  are less
significant  in  the Study  Area  in  terms of  the time scales considered.

     This analysis  first  used  simple  mathematical  models  to establish
the  existing trophic status  of Betsie  and Crystal Lakes  in  terms of
total  areal  phosphorus  loading levels.  Then future phosphorus loading
scenarios  based  on wastewater  management  alternatives  were  derived.
Next  a Vollenweider/Dillon model  projected the  trophic  status  of the
lakes  using  derived phosphorus  loading  levels.   The model used in this
analysis is detailed in  Appendix E-4.

     Summary of Existing Trophic Status.    Given    such    hydrological
features of  the lake as  hydraulic  retention  time  and depth,  the model
generates a "permissible"  phosphorus loading limit above which a lake is
considered mesotrophic and a  "dangerous"  phosphorus  loading limit above
which  the   lake   is  considered  eutrophic.   The   phosphorus  loading
tolerance  limits  for Betsie  Lake  and Crystal Lake  are  summarized in
Table  IV-1.   Existing  phosphorus loading levels  derived  in Chapter II
are included for purpose of comparison.
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                              Table IV-1

                  PHOSPHORUS LOADING LIMITS (g/m2/yr)

                                 Betsie Lake           Crystal Lake;

          Permissible              3.23                     0.064
          Dangerous                6.46                     0.132
          Existing                12.39                     0.044

Betsie  Lake  can  assimilate  greater  phosphorus  loads  per  unit  area
because of  its  relatively high flushing rate  (hydraulic  retention time
of 2 days) compared with that of Crystal Lake (63 years).

     The  current status of  eutrophication of these  lakes  can  best  be
summarized in Figure  IV-1.   It shows that  Crystal  Lake  is  currently in
the oligotrophic category while Betsie Lake is eutrophic.

     Future Load Scenario:  Betsie Lake.   Table  IV-2  shows  estimates of
phosphorus  inputs  for  Betsie  Lake  for  each wastewater  alternative.
Non-point source runoff was  assumed to remain constant until  the year
2000, because future land use was uncertain.  These estimated phosphorus
inputs  for  the  alternatives  indicate  that  loads  could  be  reduced  by
43-48%, below existing conditions.   The reduction in phosphorus loads is
similar for  all wastewater  management  alternatives  (except  No Action)
because (1) over 50% of the phosphorus load is from nonpoint sources and
will  not  be  controlled by  wastewater  management alternatives  and (2)
effluent  discharged  from  the treatment plant or land application is low
in phosphorus  (1  mg/1  and  0.3 mg/1  respectively).   Three  options are
available for reducing the phosphorus to Betsie Lake.

     o    Elimination  of  wastewater  discharge   from the  Elberta  and
          Frankfort  plants  into  Betsie  Lake.   The  land  application
          alternatives  (2 and  4)  which  eliminate discharge  to Betsie
          Lake  have  the  greatest  potential for  reducing  phosphorus
          loads.   Reduction  in  phosphorus  loads  of  about  48%  are
          anticipated with Alternatives 2 and 4.

     o    Chemical  precipitation.   Design  for  the RBC plant specifies
          phosphorus  removal   by   chemical  precipitation.   Phosphorus
          levels in the effluent discharge with this method will be less
          than  1.0  mg/1.    EIS Alternative  1  and  the  Facility Plan
          Proposed  Action would  treat  the wastewater from  the entire
          Study  Area  and  the phosphorus loading to Betsie Lake will be
          only  about  10% greater  than if  land application  is  used for
          the entire Study Area.

     o    A  combination  of  chemical  precipitation  of  phosphorus and
          reduction  of  wastewater  flow.   EIS Alternatives  3,  4,  and 6
          propose  the use of on-site systems for various  sections of the
          Crystal   Lake  shoreline  and   treatment   of   the  remaining
          wastewater  at the  RBC plant  or by land  application.  These
          alternatives are intermediate in hydraulic and nutrient loads.
                                    146

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    1.0 C
 CM
  £
  v.
  o>
IT

I
    O.I
   0.01
i    I  i   I  i m
i    r
             EUTROPHIC
                      ©.CRYSTAL LAKE
                      \EXISTING CONDITIONS
                         ALL ALTERNATIVES
               O BETSIE LAKE
                EXISTING
                 CONDITIONS
               o-ALTERNATIVES 1,3,5,6; LIMITED ACTION;
                        /      PROPOSED" ACTION
                 ALTERNATIVES 2,4
                                               OLIGOTROPHIC
                         I   I  I  l I  I I
                       JL
       1.0                            10.0                           100.0

                           MEAN DEPTH(METERS)


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

              R= PHOSPHORUS RETENTION  COEFFICIENT (DIMENSIONLESS)

              P- HYDRAULIC FLUSHING RATE (yr"1)



  FIGURE EM  TROPHIC  STATUS  OF BETSIE LAKE AND CRYSTAL LAKE
                                  147

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                                  Table IV-2

                 ESTIMATES OF PHOSPHORUS LOADS TO BETSIE LAKE
                   FOR THE WASTEWATER TREATMENT ALTERNATIVES
   ALTERNATIVES
Alternatives 2 & 4
Limited Action
Alternative 6
Alternative 3
Alternative 5
Alternative 1 and
Proposed Action

Existing Conditions
and No Action

HOSPHORUS LOAD
ffl/m2/Yr(Lb/Yr)
6.47 .
(14.4 X 10 )
6.91 -
(15.40 X 10 )
6.96 ,
(15.51 X 10 )
7.0
(15.71 X 10 )
7.1 -
(15.80 X 10 )
7.1
(16.55 X 10 )
12.39 3
(27.6 X 10 )
% ABOVE % REDUC1
DANGEROUS OVER EXIl
LIMIT CONDITK
0.2 48%

6.4 44

7.0 44

7.0 44

9.8 43

8.8 43

48

                                     148

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          Phosphorus  loads  would  be  reduced by  43-44% as  compared  to
          with present conditions.

     With any of  the  available options the phosphorus  reduction  is not
significant  enough to   change  the  trophic  status  of the  lake  from
eutrophic to  mestrophic according  to  Dillon's model;  in  all instances
the-loads are slightly  greater than Dillon's "tolerance limits" of 6.46
g/m /yr  for  Betsie Lake.   However, the  reduction in  phosphorus  input
(43% - 48%) provided by the wastewater treatment alternatives represents
a  significant  achievement in  correcting  the eutrophication  problem  in
Betsie Lake.  Phosphorus  concentration in the lake will be lowered as a
result of the proposed project.  Unfortunately,  data deficiency prevents
the prediction of  the subsequent decline in  algal  growth  at this time.
In  any  case,  the  proposed  action  is  the first  step towards restoring
Betsie Lake.

     Future Load Scenario:  Crystal Lake.  In marked  contrast to Betsie
Lake,   Crystal  Lake  has been  shown to  be  oligotrophic under  existing
conditions.  Inasmuch as total phosphorus loads shown in Figure IV-1 are
well within  the  "permissible" limits and because  phosphorus  loads from
on-site  systems  are but  a  small  portion  (6.7% or less)  of  the  total,
none of  the  alternatives is  anticipated to  have a significant effect on
the  quality  of   the  open  water.    Localized  shoreline  eutrophication
resulting  from septic tank leachate and non-point  sources  is discussed
in Section IV.A.l.b.

     Table  IV-3   shows  estimated  phosphorus  loads   for  the  existing
conditions, decentralized, and  centralized  alternatives.   The following
assumptions were  made in deriving the nutrient loads:

     o    Phosphorus  loads   from   ST/SAS  were   assumed   to  be  0.25
          Ib/cap/day  and  corrected  for  seasonal  residency.    A  14%
          increase in nutrient loads from ST/SAS was anticipated for the
          year 2000.  This figure  was  based on the calculated number of
          homes and ST/SAS which could be constructed on half acre lots
          where soils  are suitable  for  ST/SAS.   Based upon  results  of
          the "Septic Snooper"  survey  (Kerfoot  1978) the  septic tank
          load estimate is considered to be  conservatively high.

     o    Phosphorus loads from Cold Creek were based upon data provided
          by Tanis (1978).

     o    Phosphorus  loads  resulting  from   changes  in  land  use  were
          estimated by  using Omernik's  regression model.  This  model,
          detailed  in Appendix  E-2 approximates  the  total  phosphorus
          (and nitrogen) concentration  in  surface  water  runoff  based
          upon the influence  of  agricultural,  residential/urban,  and
          forested land in the watershed.

     The  estimated  loads  readily  show unchanged  trophic  status  of
Crystal Lake regardless  of the alternative.  Phosphorus loadings should
remain 30-35% below the permissible limit of 0.064 g/m /yr.  Because the
contribution of total nutrients  from septic  tanks  is  small,  the  ban on
phosphorus  will   not   significantly  reduce  the  total  Crystal  Lake
phosphorus load.

                                   149

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                           Table IV-3

                  CRYSTAL LAKE PHOSPHORUS INPUT
                        Loading Rate
EXISTING CONDITIONS


Precipitation
Septic Tanks
Cold Creek
Non-Point Source
Runoff-Imraed. Watershed

   TOTAL


1975 - WITHOUT SEPTIC
       TANKS

Precipitation
Septic Tanks
Cold Creek
Non-Point Source
Runoff

   TOTAL

CENTRALIZED ALTERNATIVES

Precipitation
Septic Tanks
Cold Creek
Non-Point Source
Runoff

   TOTAL

YEAR 2000 DECENTRALIZED
(No Phosphorus Ban)

Precipitation
Septic Tanks
Cold Creek
Non-Point Source
Runoff

   TOTAL

WITH PHOSPHORUS BAN

Precipitation
Septic Tanks
Cold Creek
Non-Point Source
Runoff

   TOTAL
*Dillon's permissible load = 0.064 g/m2/yr.
 Tanis 1978; Omernik 1977; EPA, NES 1975.
Areal Loading Rate Percentage
Ibs/yr)
1,690
263
1,533
465
3,951
1,690
1,533
465
3,688
1,690
0
1,533
614
3,837
1,690
176
1,533
614
4,013
1,690
88
1,533
614
3,925
(kg/yr)
767
120
695
210
1,792
767
695
210
1,672
767
0
695
279
1,741
767
80
695
279
1,821
767
40
695
279
1,781
(g/rf/yr)
.019
.003
.017
.005
.004*
.019
.018
.005
.041*
.019
0
.017
.007
.043*
.019
.002
.017
.007
.045
.019
.001
.017
.007
.044
%
42.8
6.7
38.8
11.7
100.0
45.8
41.6
12.6
100.0
44.0
40.0
16.0
100.0
42.0
4.4
38.2
15.4
100.0
43.0
2.3
39.0
15.7
100.0
                                 150

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b.   Lakeshore  Eutrophication

     The colonization of Cladophora in localized areas  along the  Crystal
Lake  shoreline  has  been  attributed  to  nutrient  influx  from  human
activity.   Cladophora  requires high  nutrient  concentrations which  are
not  naturally available  in  nutrient poor,  oligotrophic  lakes  such  as
Crystal Lake.  Several  studies  have been made  in an effort to  determine
the cause and extent of Cladophora growth along  the lake  shore.  Under
existing  conditions,  correlations  have  been  found   between  housing
density  and  shoreline  vegetation  (Tanis  1978  and   Gannon  1970)  and
between  several  variables  associated  with  septic   tank  performance
(University of Michigan 1978) including:

     o    length of home occupancy
     o    age of septic tanks
     o    proximity of septic tanks to the lake shore

     The data strongly suggest that  Cladophora growth is  at  least,  in
part,  the  result of nutrient  leachate from septic tanks.   Septic  tank
plumes may  channel nutrient rich  waters to the vegetation, in effect
acting as a hydroponic culture.

     The data  supplied  by these studies suggest  that  the  frequency  and
density of Cladophora growth may increase slightly if  additional  permits
for shoreline  septic  systems are  granted.   However,  the availability of
nutrients  for algal  growth could  be  reduced  along  the  southwestern,
southeastern,  and  northwestern shorelines if the ST/SAS were  upgraded.
Many of  the  existing systems are  undersized or are  located too close to
the lakeshore.  Nutrients from  ST/SAS along the northeastern shore and a
small  part  of the  southeast   shore  may not  be reduced  by  upgrading
because of expected high rates  of  groundwater inflow to the lake.

     The centralized alternatives  (Facility Plan Proposed Action  and EIS
Altternatives  1  and 2)  are  most  likely to  reduce the concentration of
nutrients contributing  to  shoreline eutrophication.   Alternatives 3, 4,
5  and 6  which propose  sewering   the northern  shore  where  Cladophora
growth is heaviest, may effectively reduce the  major nutrient source for
growth.

     There is  no  guarantee that sewering the Study Area will  eliminate
the  growth  of Cladophora.   With  51%  of  the  phosphorus coming  from
non-point  source  runoff  and tributaries,  it  is conceivable that  some
localized growth  may result from  these sources.  This  is particularly
true  along  the northeastern shore where groundwater  flow patterns  may
channel nutrients to localized  areas.

c.   Bacterial  Contamination

     Effluent discharges to Betsie from the proposed new treatment plant
in Frankfort should not result  in  significant bacterial contamination of
surface  waters.   Disinfection  facilities are included in  the  design of
the RBC plant.  However, the efficiency of disinfection is  a function of
mixing,  contact  time and plant operation.  Regular sampling  to  measure
                                   151

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fecal coliform and residual disinfectant should provide  an  indication  of
disinfection  effectiveness.    Plant  malfunctions   would   not   severely
affect  Betsie  Lake  unless   the  Lake  were  used   for water   contact
recreation.   Centralized  treatment  of wastewater  by   land  application
will not impact  surface waters;  the land application sites  are  located
at a distance from Crystal and Betsie Lakes.

     Pumping   stations   malfunctions   could   occur  with   centralized
Alternatives  1 and  2,  resulting  in  contamination  of  surface  waters.
Rigorous inspection  and  maintenance of pumping stations would  minimize
this possibility.

     Bacterial contamination of Crystal Lake  surface water  should not  be
a problem  with the decentralized alternatives.   Available data  suggest
that  bacteria are  removed even  by  the  medium sandy  soils along the
lakeshore.    The  results  of the bacterial sampling  surveys performed  by
Kerfoot  (1978)  and Gannon  (1970)  are discussed in section II.B.7 and
II.C.I.  Kerfoot  observed that  bacterial  concentration did not exceed
Michigan's primary  contact standards  (200  organisms/100  ml) even  when
the samples  were  collected at the site of a  leaching septic  tank plume.

d.   Non-Point  Source Nutrient Loads

     Primary   impacts   on   surface   water   quality  related   to  the
construction  of  ST/SAS  systems  and the replacement of old systems  is
likely  to  result  in increased soil erosion.   Similarly, installation  of
sewers,  especially  those   that pass under the many  small  drainage  ways
leading to Crystal Lake,  will accelerate erosion.

     Compliance with  state and local  soil erosion  control requirements
could substantially reduce the erosion problem and the  subsequent impact
on water quality.

2.   SECONDARY  IMPACTS

     The  potential  productivity  of Crystal Lake  and Betsie  Lake  is
determined to  a  large  extent by the  type  of  land  over  which the runoff
drains.   Current  estimates  of  nutrient loadings  indicate  that  the
non-point  source  runoff  contributes roughly  52% of the  total phosphorus
to Betsie Lake and 50% of  the total phosphorus to Crystal Lake.

     Increased shoreline housing, a secondary impact of  sewering Crystal
Lake,   might   increase  sediment  and  nutrient  loads.    Conversion  of
forested  land  to  residential  or  agricultural  use  tends  to  increase
non-point source loadings  significantly (Omernik 1977).

     Any  nutrient  loading estimates  for  non-point  sources  have a low
confidence  limit.   (See   Omernik's  Model,  Appendix  E-2.)  They  cannot
account for  particularly  sensitive features  of the  Study Area  or for
specific land  use purposes.

     For purposes of land  use planning, increases in nutrient loads  from
non-point  source  runoff  must   be   considered.    Increased  loads  could
result  from:
                                    152

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     o    increased runoff from construction of impervious surfaces such
          as rooftops and parking areas;

     o    lawn  and  garden   fertilization   creating  unnaturally  high
          nutrient levels in the runoff; and

     o    soil   disruption   by   human  activities,   (i.e.,   housing
          construction, leveling of forested area etc.).

Any  of  these   could  result  in  increased  nutrient  and  sediment  loss
especially  in  areas with  steep slopes or  in drainage ways  leading  to
Crystal Lake.

     The topography of  the Crystal Lake watershed suggests  that certain
large areas may be particularly vulnerable to increased non-point source
runoff.  The  Cold Creek  watershed lies  in  an upland area  that slopes
towards  the  lake.   Approximately 36%  of  the  area  is  forested  now.
Development of this land will increase runoff to the lake.  Tanis (1978)
has demonstrated that forested areas of the Cold Creek watershed produce
runoff with  fewer  nutrients  than runoff from land used for  agricultural
or residential purposes.

     The  remainder of  the  Crystal  Lake watershed consists mainly  of
bluffed areas  around  the Lake.   These areas  are  about 50%  forested and
their  runoff  water  is  characterized by  low phosphorus  concentration
(0.016  mg/1).   Residential   development  encouraged  by   sewering  could
increase  runoff phosphorus  concentrations  and sediment  loadings.   The
potential  for  increased development  is  much  greater along  the Crystal
Lake shoreline  than  that of Betsie Lake.  Since  Betsie Lake is already
sewered, the wastewater management alternatives are not likely to induce
growth in the Betsie Lake area.

3.   MITIGATIVE  MEASURES

     The  impact analysis  has  indicated  that  non-point  source  runoff
contributes a  large percentage  of the total Crystal Lake  nutrient load.
The Benzie  County  Development Plan has made  several recommendations  to
control  such  runoff.   These  recommendations  should be enforced by the
townships  through  zoning,  performance  standards   and  ordinances  for
control of non-point sources.

     Erosion and sedimentation resulting from construction of wastewater
collection  systems  should be minimized by adhering to the  requirements
of the Soil  Erosion and Sedimentation Control Act of 1972.   Enforcement
of this act is the responsibility of Benzie County Community Development
Department.  Construction  permits  can be revoked for violations  of the
standards set forth in this act.

     The two major  non-point sources  have been identified as the lower
Cold Creek  watershed and  the lake bluffs.   The use  and  development  of
land  in  the  lower  Cold  Creek  watershed  should  be   restricted  to
compatible  uses.    Alternatives  to  the  current   practice  of  routing
Beulah's stormwater  to Cold  Creek should be  investigated.   Sources  of
wastewater  entering  Cold Creek  should  be  identified and  dealt  with
                                   153

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appropriately.    Any development  on  the  bluffs  around  the  lakeshore
should require  individual plan approval,  the  developer being  required  to
ensure that  sedimentation  and erosion can be controlled and  structural
failures will not occur.   Although  septic tanks have  been  shown  to be a
minor source of nutrients, several  mitigative  measures could minimize
the nutrient load from  this source.   Cladophora growth along  the  Crystal
Lake  shoreline  has been  attributed to  localized  nutrient sources.
Several  measures  are  available  which may minimize Cladophora  growth.
These include  upgrading the  existing on-site systems, use of off-site
systems   or    composting   toilets    and   minimizing  the   use    of
phosphorus-containing fertilizers.

     These improvements in septic  tanks are intended to reduce nutrients
for  algal  growth   along  the  shoreline.   There  is  no  guarantee that
Cladophora  growth   would  be  eliminated  by  these  mitigative  measures,
however.   As  a  last resort Cladophora  growth which  does  occur  may  be
controlled  by   adding   copper  sulfate locally.   Used  in  properly low
concentrations, this chemical will interact with polypeptides secreted
by the algae.   This will kill the algae  but  make  the  copper  unavailable
for uptake (and toxicity) to other organisms.

     There  is   some possibility   that  the   approximately  25  dormant
effluent  plumes  along  the  western  third   of   Crystal   Lake  may   be
influenced by  the prevailing  direction of groundwater flow  (see  Figure
II-8), which is away  from the lake  and  toward  Lake  Michigan.   Should
this be  the case,   under  conditions  of peak  flows,  the plumes may have
hydraulic loadings  sufficient to  overcome the  normal  groundwater flow
and  force a plume  out into   the  lake.   As  system use declines  (when
seasonal  residents  leave)  leachate   would  again  tend  to  move  in the
direction of the groundwater.   These unusual  conditions may allow use  of
flow  reduction devices as mitigative  measures,  because  reduced flow
would result in lower hydraulic loadings  and  fewer plume extensions into
the lake.

B.   GROUNDWATER  IMPACTS

     Groundwater impacts  fall into two categories,  those  affecting the
available quantity  of  the resource, and  those  affecting  its quality.

1.   GROUNDWATER  QUANTITY  IMPACTS

     No  significant primary or secondary impacts  on groundwater  quality
should  come from   any  of  the various  alternatives.  This  is  mainly
because all of the  water quantities associated with  the alternatives are
relatively  miniscule   in  comparison  with  the   estimated  groundwater
storage,  recharge   from all  other  sources,   and  available  groundwater
yield.

     The  conversion from sewage disposal  practices based  on individual
soil  absorption systems  to  central  sewered treatment systems  without
effluent  land  disposal  can result in the  loss of groundwater recharge.
The  significance of  this  loss  hinges   upon its  relationship  to the
recharge from all other sources; these include downward infiltration and
                                   154

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percolation from  precipitation and  surface  water bodies,  and  adjacent
aquifer  inflow.   Precise  definition of this  depends  upon an  accurate
knowledge  of  the  aquifer(s),  and  its  hydrology  (e.g.,  precipitation,
runoff,  evapotranspiration,  discharge)  and  hydraulic  characteristics
(e.g., transmissivity, and storage coefficients).   There is insufficient
data with which to undertake such precise quantification.

     Study Area  groundwater extraction  is  currently very  small,  being
limited  mainly  to   small  wells  serving  individual homes,  except  in
municipalities.  It  is  on  an order of magnitude as the total  Study Area
wastewater flows, perhaps 0.89 mgd (equivalent to approximately 620 gpm)
by the year 2000.   The 500-foot thick sediments  in  the area, even with
allowance  for their expected  discontinuity  and  low   specific  yields,
should have  a safe  yield  several orders of magnitude  greater  than the
total wastewater effluents  available for groundwater recharge.   This is
particularly true of the outwash deposits southeast of the Study  Area.
Failure to return the relatively small quantities of wastewater flows as
recharge is not  expected to have a  significant  impact  upon groundwater
quantity.  Because of the small water quantities involved, land effluent
disposal or  soil absorption  systems will show  only minute  impact re-
ductions over the other alternatives.

     The short-term  construction impacts on groundwater quantity will be
even  less  discernible since  still  smaller quantities  of  water  will be
involved.  Also,  in no  case will construction activities  be likely to
result in  the sealing  of  enough recharge area to  create a significant
adverse effect upon  groundwater quantity.

     Increased  groundwater  demands, arising  from  Study Area  induced
growth,   may   cause  groundwater   quantity  impacts.    Decentralized
alternatives   should  do  this  less  than   centralized   sewer  system
alternatives.   Study Area population growth from centralized systems use
may  be about  19%  by the  year 2000.  A  corresponding 19% increase in
water use  would  amount to  about 0.17 mgd.   This  increased demand is so
small  compared  to   the  aquifer  capacity  that  it  will  not create  a
significant impact.   The County  Development  Plan shows  that available
groundwater supplies are more than adequate for demands through the year
2000  (Wilbur  Smith  and  Associates  1974).  However,  existing municipal
storage  and  distribution  facilities are  inadequate for  future needs.

2.   GROUNDWATER QUALITY IMPACTS

     No  significant short-term  impacts  on  grcundwater  quality should
result  from  the  construction  of  any  of the  alternatives.   Long-term
impacts would be as  follows:

     o    Impacts on bacterial quality  are  expected to  be significant
          for all alternatives;

     o    Continued  use  of  ST/SAS  particularly on  the  northeastern
          lakeshore  may  result  in  minor   impacts   associated   with
          shoreline  algal growths;
                                   155

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     o    No   significant   impacts   on   nitrate   concentrations   are
          anticipated providing  the  density of  ST/SASs complies  with
          generally accepted standards.  Only  the  No  Action alternative
          is likely to result in significant adverse impacts.

These  conclusions  are  discussed in  more  detail  in  the sections  that
follow.

     Soil   erosion  is    the   chief  short-term   construction   impact.
Compliance with the regulations of the Erosion and Sedimentation Control
Act  can  minimize  such  erosion.   The clayey soils  found throughout the
area are an effective barrier against sediments reaching the aquifers by
filtration  and adsorption.   No  significant  impacts  are thus  expected
from any of the alternatives.

     Long-term impacts on groundwater quality are mainly associated with
the  following  three types  of  pollutants:    (1)  bacteria, organics, and
suspended  solids,   (2)  phosphorus,  and  (3)  nitrogen  in  the  form  of
nitrates.

     Bacteria and  suspended  organics  are readily removed by filtraztion
and  adsorption onto soil  particles.   Five  feet  of soils  are  ample to
remove  bacteria   except   in  very  coarse  grained,   highly  permeable
material.   Available  data show that bacterial  well water contamination
is not a problem for Crystal Lake shoreline residents.  The  upland soils
in  Benzonia  and  Beulah  Townships  have  varying   degrees  of  clay for
adsorbing bacteria;  and  aquifer water  levels  are  low,  providing ample
distance  for  bacterial removal.   The  sandy  and  loamy-sand  lakeshore
soils  are effectively removing bacteria from ST/SAS despite the general
absence of soil clay (Gannon 1970;  Kerfoot 1978).

     Land  wastewater  application  on  upland  soils  should  not  cause
groundwater  bacterial  contamination.   Land  application site  soils are
chosen  for  their  effectiveness  in  removing bacteria  and  suspended
solids.   Pretreatment   and  subsequent  die-off  due to  dehydration will
greatly reduce viable bacteria.

     Groundwater phosphorus  is important because  of  the potential role
in  lake  eutrophication.   Jones (1977) reviewed relevant studies on this
subject for the Environmental Protection Agency concluding that:

     ...  it is very unlikely  that  under most circumstances,  sufficient
     available   phosphate  would   be   transported  from   septic  tank
     wastewater  disposal  systems   to   significantly  contribute  to the
     excessive aquatic  plant growth problems in water courses  recharged
     by these waters.

Field  studies,  they point out, have shown  that most  soils, even medium
sandy  soils  typically   remove  over  95%  of  phosphates  within   short
distances  from  effluent  sources.   The  review shows  the  two primary
factors  in  the removal  of phosphates applied to the land.  The first is
phosphorus  absorption on small amounts of clay minerals, iron  oxide and
aluminum  oxide  in  soil  and  aquifer materials.  The second is hard water
calcium  carbonates  and precipitation  of  phosphate  as hydroxyapatite.


                                    156

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     Jones  et  al.   (1977)  have  also indicated  several  studies  in areas
similar to  the  Study Area (loamy, clayey soils over glacial moraine and
outwash  deposits)  where  the soil  has essentially  removed all  of the
phosphorus present  in  septic tank effluents.  They also  stated  that in
hard water  areas such  as those  of  the southern half  of Michigan, the
"likelihood  of  significant  phosphate  transport   from  septic  tank
wastewater  disposal system  effluent to the  surface  waters  is  greatly
reduced because of the calcium carbonate present in the soil and subsoil
systems."

     Because the soils and subsoil systems throughout the Study Area are
clayey to varying degrees and the groundwaters are also very hard (up to
360 mg/1  as  CaCO,..)  very  little phosphate transport from groundwaters to
surface waters  should take place in the Study Area.

     This was  confirmed  by  the  "Septic Snooper" survey of groundwater
leachate  plumes entering Crystal  Lake (Kerfoot 1978).   Only  90 of the
1090 existing shoreline dwellings showed detectable septic tank leachate
plumes.   Of  the  plumes  sampled,  an  estimated  0.7%  of  the  total
phosphorus  in  septic  tank  effluents  reached  the  lake  by  way  of
groundwater.   This   phosphorus  was  too  small to  affect  Crystal  Lake
surface water eutrophication (see II.B.7.a) but sufficient to stimulate
algal growth within localized plume emergence areas.  Only the No Action
Alternative, relying on on-site systems along the northeast shore, could
potentially  worsen  the  localized  lakeshore  eutrophication  problem.
Mitigating  measures  such as localized  chemical  treatment or mechancial
algae removal might even  solve this problem.

     Groundwater nitrates are of concern, at high concentrations causing
methemoglobinemia in  infants consuming foods prepared with such waters.
The National Interim Primary Drinking Water Regulations  (40 CFR 141) of
the Safe Drinking Water Act PI 93-523 set a limit of 10 mg/1 of nitrates
as  nitrogen (N0~ -  N).   Chapter  II  contains a discussion on the well
water levels of nitrates  around Crystal Lake.

     Septic  tank/soil   absorption  unit   density  is  often  the  most
important parameter influencing groundwater levels of nitrates (Scalf et
al. 1977).   However,  the same source indicates that currently available
"information has  not been  sufficiently definitive nor  quantitative to
provide a basis for density  critera" (Scalf et al. 1977).

     The  Sanitary Code  of  the Grand  Traverse-Leelanau-Benzie District
Health  Department   (GT-L-BHD)  requires  that  septic  tank systems  be
located  at  least 50  feet from any potable  water supply, well,  spring,
etc.  This  distance usually provides ample water travel time within an
aquifer  to  reduce  initially excessive nitrate concentrations (more than
10  mg/1  as N0« - N)  to less  than 2 mg/1.   Minnesota  field studies by
Schroepfer  and  Polta (1969)  show a reduction from 12.6 mg/1 to 1.7 mg/1
within 30  feet  at depths of less than 15 feet in a water table aquifer.
Most  sanitary  codes  reflect  the  general  acceptance  of  a  50-foot
separation  of  wells  and septic  tank  systems as  the  best  available
yardstick  for  assessing  likely  adverse impacts of  ST/SASs.   A minimum
lot  size of  1/3 acre  usually  ensures the  observance  of  the  50-foot
separation  of   wells  and  ST/SASs.   The  Grand Traverse-Leelanau-Benzie


                                   157

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District  Health Department considers  that the  alternatives  satisfying
this density  criterion,  among  others  in the code,  create no significant
groundwater nitrate impact.

     Multi-tier or grid  type  residential development can create greater
potential  groundwater  nitrate  impacts  from ST/SAS use  than  can single
tier development.  Depending  on the direction of  groundwater,  flow and
pumping  rates  of wells,  nitrate  contributions  from  individual ST/SASs
may  become  cumulative  in multi-tier  developments.   It  is  thus  more
important  to  enforce  existing  density codes and  set-back distances to
wells in such developments than in single tier ones.

     The  existing  situation within the Service Area  as  established by
the sanitary  survey  is that 23 percent of all ST/SASs is located closer
than the  required  50-feet from wells.  Five (5) percent of all ST/SASs,
or  nearly  one-fourth  of these  violating  the 50-foot   criterion,  is
located  within  25  feet  of wells.   Gannon  (1970)  found  focal  points of
high nitrate concentrations (>4 mg/1)  in wells along the northshore, and
particularly  along the  northeastern   shore of  the lake.  These  focal
points are  located in  the areas of high ST/SAS  density.   In two cases,
on the northeastern  shore, nitrate concentrations  exceeded the standard
criterion  of  10  mg/1 NCL-N.   In many  other  areas  Gannon  found  no
nitrates,   or   concentrations   that   were  less   than   1  mg/1.    The
implications are that  while  the source was not identified, high nitrate
concentrations well  in excess  of  background levels were associated with
high density development in the Service Area.

     The  No Action Alternative will perpetuate  and may  possibly worsen
this  situation  with  a  resulting  increased  violation of  the  drinking
water standard.   It is not a recommendable action.

     The  Limited Action alternative   tentatively  proposes  the use  of
cluster  systems to overcome  the problem but  it  would  be subject to the
findings of detailed studies to be undertaken during the design phase of
the  project.    No  significant  adverse  impacts on water quality  are
therefore expected to result from the  Limited Action Alternative.

     Cluster  system  soil absorption fields are  designed  like  to septic
tank fields to ensure an adequate areal distribution of the effluent and
depth  to   groundwater  for   satisfactory  treatment.    Nitrate  levels
entering  groundwater  should  be equivalent to  those  of  leachate  from
ST/SASs.    Locating the  soil absorption fields of cluster  systems at
greater  distances  from  residential developments  (500 feet  adopted for
EIS Alternative  design)  provides  more than ample  room  for  dilution of
nitrate concentrations below drinking  water limits  prior to interception
by  wells.   Cluster  system  alternatives  should  therefore produce  no
significant groundwater nitrate impacts.

     EPA  recognizes  almost all types   of  land  treatment  alternatives as
being  capable  of producing  final  effluent  nitrate nitrogen (NCL  - N)
concentrations  of  10  mg/1  and  less  prior to entry  into groundwaters.
Table  IV-4 shows irrigation  (spray)  and  overland flow  methods produce
effluents  of  2.5 mg/1  of NC-   -  N) while  for  infiltration percolation
(rapid  infiltration)  10  mg/1  may be  expected  (EPA 1975).   Dilution
                                    158

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                           Table IV-4

  EFFLUENT QUALITY COMPARISON FOR LAND TREATMENT AND AWT SYSTEMS
Effluent quality parameter, mg/1
System
Aerated lagoon
Activated sludge
Irrigation
Overland flow
Infiltration-percolation
AWT-1
AWT- 2
AWT- 3
AWT- 4

BOD
35
20
1
5
5
12
15
5
5

SS
40
25
1
5
1
15
16
5
5

Nil -N NO N Total N
10 20 30
20 10 30
0.5 2.5 3
0.5 2.5 3
10 10
1 29 30
3
20 10 30
	 	 3

P
8
8
0.
5
2
8
8
0.
0.




1




5
5
Cost-Effective Comparison of Land Application and Advanced Wastewater
Treatment (EPA-430/9-75-016).
                            159

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within   aquifers   by   groundwater    flow    further    reduces    these
concentrations.    No  signficant  impacts   on  groundwater   quality  are
therefore expected from alternatives using  land  application techniques.
While  spray  irrigation  and  overland  flow  techniques will  produce
effluents  of   better  quality,  rapid  infiltration  will  produce  a
satisfactory  one.   Selection   of  land application  alternatives   would
require a detailed site analysis including  a  geohydrologic survey,  soils
classification and soil chemistry survey.

3.   MITIGATIVE MEASURES

     Groundwater   quality   should  be   carefully   monitored   for   all
alternatives  involving  the  use of  ST/SASs,  cluster  systems  and  land
application system.   This  will  verify that water quality  is not  being
significantly   degraded,   and   to  warn  of  malfunctions,  inadequate
treatment and the need for corrective action.

     The  proposed  detailed  groundwater  studies  scheduled for  imple-
mentation  during  the  project  design phase  will  ensure  that  the
implemented   alternative   poses  no   significant   adverse   threat   to
groundwater quality.
C.   POPULATION AND  LAND  USE  IMPACTS
     Population  and  land  use  impacts  associated  with  various  system
alternatives   are   evaluated  in  this  section.   These   impacts   are
summarized below:

     o    Different alternatives will  result  in significantly different
          rates  of   population  increase.    Provision  of  centralized
          facilities  would  result  in  a  19%  increase  above  standard
          projections  for  the  drainage  basin,  while   reliance  upon
          existing on-lot systems in unsewered areas (the Limited and No
          Action  Alternatives)  will  hold  population growth 7%  below
          standard   projections.    Decentralized   alternatives   will
          generate  population  growth  4%  above  current  projections.

     o    Residential  land  acreage  will   increase regardless  of  the
          alternative  selected.   Increases  will  range   from  77%  (No
          Action Alternative)  to 88%  (fully  centralized alternatives).

     o    Availability  of sewers  would allow  present demand for  land
          development along  the  shore  of Crystal Lake to  be  met.   This
          would  result  in residential  densities averaging 25% above the
          No  Action  Alternative  and possible  multifamily development.
          No Action, Limited Action, and decentralized alternatives will
          increase values  of existing  residential properties around the
          Lake  because  they will  limit the  amount of  additional  land
          which may be developed.
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     o    Provision  of  centralized sewerage  facilities  will result  in
          increased development pressure.   Adoption of the  Limited or  No
          Action Alternatives  will tend to maintain  existing  community
          character.    Decentralized  alternatives  will  be  nearly  as
          effective as the No Action Alternative in maintaining existing
          community character.

1.   INTRODUCTION

     The  capacity  of  an area  to  support  development varies with  the
degree  to   which   wastewater  facilities  are   site-related.    On-lot
wastewater treatment  facilities are extremely site-related because they
are limited  to  sites with suitable soils.  Sewers  allow development  to
be  much  more   independent  of  site  characteristics   because  the  soil
permeability,  slope,  and drainage  are  not   such strong  constraining
factors.   Thus, sewers   increase  the  inventory  of   developable  land.
Sewers also increase the possible density of development.   The amount  of
additional growth  actually occurring  in the area if sewers are provided
is dependent not only upon increases in development  potential  but also
upon  demand  for additional  residential development  in the  area.   This
demand  reflects  the   residential  amenity  of  the  area in  comparison  to
other areas  and  the  reduction in the cost  of residential  land when the
supply of developable land is increased.

     Population and  land use impacts are estimated here for completely
centralized  and  completely  decentralized  (No  Action)   alternatives.
Impacts  are  also  estimated   for  EIS Alternatives 3, 4,  and  5,  which
incorporate  partial  sewering and  cluster  systems.  These  alternatives,
while described  as  decentralized,  are  actually  hybrid  or intermediate
systems in terms of population and land use impacts.

2.   POPULATION

     If centralized  facilities  were provided, population in the Service
Area would be anticipated to increase 19% above baseline  projections for
the  year  2000.    This   increase  in  population  growth  above  regional
baseline   trends   is  referred   to  as  induced  growth.    Completely
decentralized  facilities (No  Action Alternative)  might  limit  Service
Area population growth  7% below baseline projections  for the year 2000.
Centralized  facilities  would  concentrate  growth within  the  nearshore
segments   of   the   Crystal   Lake  Proposed   Service   Area.    With
site-dependent,  decentralized  facilities,  nearshore  areas  would  be
developed at a lower density or might not be developed at all,  resulting
in more development in areas  further from the  lakeshore areas.

3.   LAND USE

     Significant increases in residential acreage would be  likely within
the  proposed  Crystal Lake  Service  Area  regardless  of  the  treatment
alternative  adopted.   Residential acreage  is projected  to  increase  by
77% by the year 2000 even under the completely decentralized (No Action)
alternative.    Residential  acreage  might  increase  by   88%  with  the
provision  of centralized systems.  The increase  in residential acreage
with  centralized facilities  would not match  the  increase  in population
because new development would be of higher density.

                                   161

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     The  major  differences  in  future  development   patterns   between
centralized  and  decentralized  alternatives  relate  to  the  amount  of
nearshore development.  With centralized facilities,  the nearshore areas,
undevelopable   with   decentralized    facilities   because   of   site
restrictions, would become high-development-potential  areas.

4.   TRANSPORTATION  IMPACTS

     No  population  growth   resulting   from   the   proposed   wastewater
treatment facilities is expected to have significant impact on the local
transportation  system  by  requiring  new road  construction or  other
infrastructural investment.   Increased visitation  to  the Sleeping  Bear
Dunes  National  Lakeshore,  which  is immediately north of  the  Proposed
Service Area, will  increase  through traffic,  as that  area lies  between
the National Lakeshore and  major  population  centers to the south.   The
through  traffic  is  not  likely to  have a  significant  impact  on  the
adequacy  of  local  transportation  facilities  (by  telephone,  Mr.  Max
Holden, Sleeping Bear Dunes National Lakeshore).

     Traffic  counts obtained  from  the  Benzie Count Road  Commission
indicate that  present  traffic volumes  in the area  are quite low.   The
counts indicate no consistent pattern of increase in traffic volumes for
the years 1970 to 1978.  Average daily traffic (ADT) volumes on  Michigan
Routes 22 and  115  were under 1,000 cars for  all recording stations  from
1970 to  1978.   The  ADT on US Route  31  was  higher --  2,900 vehicles for
1978.  Benzie County has  no current plans to  widen  or reconstruct roads
in the area for at least the next 5 years (by  letter,  James R. Thompson,
Manager, Benzie County Road Commission, 11 May 1979).

5.   CHANGES IN COMMUNITY COMPOSITION AND CHARACTER

     Centralized facilities  would  moderately  influence the composition
and  character  of  the  Crystal  Lake  community.    Additional  costs  of
wastewater  treatment would  displace  some  lower  income  permanent  and
seasonal  residents.   Provisions  of centralized facilities  would  also
make  feasible  the  development  of  higher-density  forms  of residences,
including townhouses  and  apartments.  These  developments would  appeal:
to older  persons  who  have  had single-family  summer  residences  in the
area in the past and want fewer maintenance responsibilities;  to younger
couples without children;  and  to  persons who  want to  share the  use of a
summer  residence.   Condominium  apartment developments have occurred in
some nearby  areas,  notably  Traverse City, and some  local residents have
expressed   an   interest   in  condominium  development  if  centralized
wastewater  treatment  facilities  are  constructed.    In  the  long  run,
however, the impacts of  proposed  wastewater  facilities on the  area may
be overshadowed  by national  trends  in gasoline availability and cost.
Rising  gasoline prices  or  shortages  in gasoline  supply  may  probably
curtail seasonal population  growth in the Crystal  Lake area  because of
the  long  auto  trip  from  metropolitan areas.  Reduction  in  seasonal
population  growth  would  also depress  the local economy and  thus limit
permanent  population  growth.   Growth  of seasonal  population   is  also
highly  responsive  to  changes  in  disposal  personal   income,  with  any
curtailment  in  the  growth of personel income  producing a marked drop in
the number of second (seasonal)  home owners.
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     The  rural  character  of  the  area  would  be  diminished  with the
additional  land  devoted  to   residential   and uses  associated  with
centralized facilities  and with higher density development.   Change in
the character of the  area  could also occur with EIS Alternatives  3, 4,
and 5  because  substantial  population growth and land development  would
take place in areas  serviced  by sewers  and  the  numerous cluster systems.

     Adoption of the  Limited or No Action Alternatives would encourage
preservation  of   the   area's   prevailing  community   character  and
composition.  There would be  very little economic  displacement pressure
in  the  Crystal  Lake  area, and land-use patterns  would  be unlikely to
change except in the amount of residential  use.

D.   ENCROACHMENT ON ENVIRONMENTALLY  SENSITIVE  AREAS

     Construction activities  related to the various wastewater treatment
alternatives and  secondary  impacts  from induced  growth  may  be felt in
certain environmentally  sensitive  areas.   The  Benzie County Development
Plan has  designated extensive areas of critical environmental concern.
The  areas  extend  through  large  tracts   of   land  which are  already
undergoing  development.   The  "critical  concern"  designation  does not
dictate land use but  recommends  restrictions which should be considered
prior to further development.

1.   WETLANDS

a.   Primary Impacts

     The wetlands located south  of Round Lake  and  near the Crystal Lake
outlet  to  the  Betsie  River  may  be  subject   to  sedimentation  during
construction of a sewer collection system  (Alternatives  1, 2, 4, 5, and
the Facility Plan Proposed Action).  Water circulation patterns  may be
modified by these activities.  These construction-related  impacts may be
minimized  by  adhering  to  the  regulations in the  Soil Erosion and
Sedimentation Control  Act.   This Act  regulates construction activities
within 500  feet of  a  shore through a  permit system  administered by the
County.

b.   Secondary  Impacts

     The  wetland  areas  surrounding  Round Lake  are   state-owned and
development will not  occur  in these wetlands.   The wetlands associated
with the  Betsie River are  protected to some extent by the Betsie  River
Natural River Zoning Act of 1973 (see Appendix  D-3).  The  Act requires a
minimum setback distance of 200 feet from the River.  It  also designates
a Natural River District, which is a strip  of land  400  feet wide on each
side  of   and parallel  to  the designated  river and  tributaries.   This
District is not under State ownership,  however,  and it merely defines an
areas  within  which  certain  types  of development will  be controlled.
Some  development  may   occur   in  these   wetlands  regardless  of the
waste-water management alternative selected.
                                   163

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c.   Mitigative  Measures

     The County should strictly enforce the regulations provided by the
Sediment and  Erosion  Control  Act to  prevent  sedimentation  which would
destroy the  filtering  capacity of wetlands.   Local  zoning  regulations
for  Benzonia  and  Crystal Lake Townships  should  be revised  to  protect
wetland areas.  Ideally,  these areas should  be  zoned for  open space.
Development near wetland  areas should provide  an adequate buffer zone.

2.   SAND  DUNES

a.   Primary Impacts

     The County  Development Plan has  characterized  the sand dunes  as
having  "unique  natural  features  worthy of protection."  The  Sleeping
Bear  Dunes Park,   north  of Crystal  Lake  is  currently protected  from
development.   However,  the dunes west and  southwest of Crystal Lake are
not  afforded  such protection.  A  sewage collection  system  that would
convey  wastewater  from   the   western   shore  to  the  Frankfort  Plant
(Alternatives 1,  2, 3,  4,  5, and  the  Facility Plan Proposed  Action)
should be  carefully located so that the dunes southwest of Crystal Lake
are not disturbed.

b.   Secondary  Impacts

     Implementation of  a  decentralized wastewater management alternative
is more likely to  encourage  development  in  sand dunes  since a scattered,
low-density  development   pattern  would  result  from  decentralization.
However, these  soils  are generally  sandy  with  slopes more  than 12%;
these characteristics present  structural problems to development.

c.   Mitigative  Measures

     The County should undertake a  study  of the  ecosystems  of the sand
dunes and  the impact which  development  might have on  these areas.  Lake
Township  should   implement  appropriate  zoning  regulations   to  protect
these areas.

3.   STEEP SLOPES

a.   Primary Impacts

     The  difficulties  of installing  on-lot   systems  on steep slopes
appears to be one of the  factors historically  limiting home construction
to  lakeshore and  other   level  to  rolling  sites.  However,  sewers and
suitably designed  on-site systems  may  be  constructed on steep  slopes.
Where  construction does  occur, adherence  to the  Sediment  and   erosion
Control Act of 1972 should minimize  the  impacts of erosion.

b.   Secondary  Impacts

     The   availability  of  off-lot  treatment  systems  as  provided  by
cluster  systems   or   sewers,   along   with  the   apparent  demand  for
residential  development  may  result  in  construction  activity  on  steep
                                   164

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sloped areas.   Accelerated  soil erosion particularly on the steep bluffs
surrounding the Lake  and  in the lower Cold Creek watershed can result in
additional non-point  source runoff into Crystal Lake.

c.   Mitigative  Measures

     The municipalities should adopt performance standards with specific
slope-density  provisions.   Developers  would  then  have  to  meet  the
performance standards which require proof that the sloped areas are not
a hazard to development.  Zoning ordinances should limit growth in steep
sloped areas.

     If cluster systems or  septic tanks are  placed  in areas  with steep
slopes, a  series  of  drop  boxes  should  be used.  With  this  method,  no
hillside seepage should occur unless the sewage flow exceeds  the design
capacity.

4.   PRIMARY AGRICULTURAL LANDS

a.   Primary Impacts

     "Prime and unique" farmlands are not likely  to  be  impacted by the
construction of cluster  systems  or sewers,  since UK se areas  are  not
located near the proposed location for collection  ;ysj, MS.

b.   Secondary Impacts

     Some  farmland  acreage  development  is  likely  regardless of  the
wastewater management alternative.  A centralized treatment system would
encourage  less  development by  concentrating growth  in sewered  areas
close to the lakeshore.

c.   Mitigative  Measures

     Agricultural   lands   should   be  protected   by   following    the
Development  Plan's  recommendation for  favorable  farm  tax  credits  to
encourage  the  retention  of prime farmland  for agricultural  purposes.
Zoning ordinances  should  discourage scattered development which converts
large tracts of farmland  into residential lands.

5.   FLOOD HAZARD AREAS

     No primary impacts on  flood hazard areas are anticipated  with any
of  the  alternatives.   The  sanitary  code  and  local  zoning  ordinances
preclude any construction within 50 feet of the Crystal Lake  shoreline,
which is ample to protect  the narrow flood prone areas around the lake.
The minimum setback distance of 200 feet stipulated by the Betsie River
Zoning Act of 1973 should preclude floodplain development.

6.   CRITICAL AND UNIQUE HABITATS

     The Michigan Department of  Natural  Resources  is  currently  in the
process  of identifying  critical  and  unique  habitat areas.   Impacts
cannot be identified  until  these areas are located.
                                   165

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E.   ECONOMIC  IMPACTS

1.   INTRODUCTION

     This  section evaluates  the economic  impacts of  the  alternative
wastewater  systems proposed for Crystal  Lake.   These impacts  include:
financial  burden  on  system users;  financial pressure  on residents  to
move  from  the  service  area;   financial  pressure to  convert  seasonal
residences  to  full-year  residences;  and  the  net  benefits  of water
quality on the economy of the Crystal Lake area.

2.   USER CHARGES

     Users  charges are  the  costs billed periodically to  the  wastewater
system customers.   Total annual user charges have  been estimated for  the
eight  alternatives.   The   user  charge consists  of  three  parts: debt
service (repayment of principal and  interest), operation  and  maintenance
costs, and  a reserve fund  allocation  assumed ^o  equal  20% of  the debt
service amount.  Annual user  charges  are  presented in Table  IV-5.   The
first column  shows the  user charges if all usei s  in the  Study Area paid
equal amounts.  The  second  and third ccJumns show the charges  if costs
were  prorated  between  sewered  (Frankfort  and  Elberta)  and unsewered
portions of the Proposed Service Area.

a.   Eligibility

     Eligibility refers  to  that portion of wastewater facilities costs
determined  by EPA to be  eligible   for  a  Federal  wastewater  facilities
construction  grant.   Capital costs  of wastewater facilities  are  funded
under  Section  201   of  the  1972 Federal  Water  Pollution  Control   Act
Amendments.   Section  201 enables the  EPA  to fund 75% of  total  eligible
capital  costs of  conventional  systems  and 85%  of the eligible capital
costs of innovative and alternative  systems.  Innovative  and  alternative
systems  considered  in  the  EIS Alternative includes  land  treatment,
pressure  sewers,  cluster  systems,  and septic  tank  rehabilitation  and
replacement.  The  State of  Michigan  funds 5%  of the capital  costs  of
both conventional  and innovative/alternative wastewater  facilities.   The
funding formula in Michigan thus requires localities  to  pay  20%  of  the
capital  costs of  conventional  systems  and 10%  of the capital  costs  of
innovative/alternative systems.  Operation and maintenance costs are  not
funded by the Federal government and  must  be paid by the users  of  the
facilities.

     The  percentage  of  capital  costs  that is elegible for  Federal  and
State funding greatly affects  the  cost that, local users  must. bear.   The
capital  costs  of  treatment as  Crystal  Lake were assumed  to  be fully
eligible  for  grant funding; the costs of  construction of the collection
system  were  subject  to the  terms   of Program  Requirements  Memorandum
(PRM)  78-9.   This PRM  establishes  three  main  conditions that must  be
satisfied before collector sewer costs may be declared eligible:

     o    Systems   in use   for disposal  of  wastes  from the  existing
          population are creating a  public health  problem, contaminating
          groundwater or violating  point  source discharge requirements.

                                    166

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     o    Two thirds  of the design  population  (year 2000) served by  a
          sewer must have been  in residence  on October  18,  1972.

     o    Sewers must  be shown  to be  cost-effective  when compared to
          decentralized or on-site alternatives.

     The Construction Grants Management branch of  EPA Region V evaluated
the eligibility of  the  sewers  proposed by the Facility Plan  and of  the
EIS Alternatives.   This  evaluation,  based upon  the two-thirds criterion
of PRM  79-3,  concluded  that approximately 40% of  the sewers proposed by
the Facility  Plan would be  eligible; of the collection systems proposed
in EIS Alternatives  1 and 2, approximately 33% would be eligible.   Local
costs for EIS Alternative  3 through 6 assume public ownership and 100%
eligibility of upgrading on-site treatment systems.  Table  IV-5 presents
local costs based upon the EPA  determination of  eligibility.

     The Michigan Department of Natural Resources  will  prepare the final
determination of the  eligibility of project costs.  This determination,
which  will  be  based  upon Step  II plans  and  specifications for  the
alternative  to  be  funded,  will  differ  in  two  respects  from  the  EPA
determination:

     o    EPA did not have plans  and specification upon which  to base
          its  computation.   Consequently   a   detailed  sewer-by-sewer
          determination was impossible.

     o    In  estimating  collector  sewer  eligibilities,  EPA  did  not
          compare   the   alternatives  to  one  another  in  regard  to
          cost-effectiveness or  to  their  probable success  in  satisfying
          documented   public   health,   groundwater  or  point   source
          problems.    Each  alternative was considered on its  own merits
          only, and  on  the  ability of its collector sewers to meet  the
          "two-thirds" rule.

     After selection  of a  recommended alternative (discussed  in  Chapter
V),   that   alternative  will  serve   as  a   baseline   for  determining
cost-effectiveness  and,  thus,   eligibility.  Collection  and  treatment
costs  of other alternatives would not be  eligible to the extent that
they   exceed  costs  for   comparable   facilities   in   the  recommended
alternative.    User  charges  for   actions  more   expensive   than  the
recommended  alternative would,  therefore, be even  higher  than shown in
Table IV-5.

b.   Calculation  of User Charges

     The user charges presented in Table IV-5 have been calculated  for
two  different  conditions:   1)  the costs  of the  system   were  divided
equally throughout   the currently  sewered  (Frankfort  and  Elberta)  and
unsewered  areas 2)  the  costs  were  prorated between  the sewered  and
unsewered  portions  of the Service Area.  It  should be pointed out that
the  Facility Plan  does  not  propose  to spread  costs over  the entire
system;  such  a comparison is made only for the purposes of  illustration.
To be equitable, the  costs  for areas served by existing sewers have been
segregated from those associated with  the unsewered areas.   This
                                    168

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prevents  the  situation  wherein  sewered  areas,  such as  Frankfort  and
Elberta, subsidize the construction and operation of sewerage facilities
in the unsewered areas.

     The  calculation  of  the user  charges was  based on  local  capital
costs being paid  through the use of a  30  year bond at 6 7/8% interest.
Some  communities  may  be  eligible  for a  40  year  loan  at 5%  from  the
Farmers  Home  Administration  to reduce the  annual financial burden of
local capital costs.

     The  centralized alternatives  (Proposed Action,  EIS  Alternative 1,
and EIS  Alternative  2) are the most costly to users  in unsewered areas
(and all users if spread out over the entire system).   Total annual user
charges  for  each household  range  from  $350  to  $440  for the  entire
system,  $590  to  $720 for the  unsewered  areas,  and $60  to  $110  for
Frankfort  and Elberta.   The large  variations  between the  sewered  and
unsewered areas'  costs are related to the ineligibility  of much of the
collector sewers  in  the  unsewered areas.   Neither the Facility Plan nor
the data collected for preparation of this EIS, document sufficient need
for collector sewers around Crystal Lake or in the Village of Benzonia.
Costs for most  collector sewers would therefore  be met  entirely at the
local   level,   should  Limited   Action  be   the  alternative   finally
recommended and application be made for any other.

     EIS Alternatives  3,  4, and 5 combine centralized and decentralized
components  and  are   less  costly  than the   centralized  alternatives.
Annual user charges  range from $150 to $170 for the entire system, from
$90  to  $110  for Frankfort  and  Elberta, and  $180  to  $240  for  the
unsewered areas.

     The  least  expensive  alternatives  for the entire  system as  well as
the   unsewered   areas  are  the  two  most   decentralized  ones:    EIS
Alternative 6 and the Limited Action Alternative.  Annual user charges
for the  entire  system are $150  for  EIS  Alternative 6 and  $60  for  the
Limited  Action  Alternative.  Frankfort and Elberta's  annual  cost would
be approximately $100  for both alternatives.   User charges would be $190
for  the  unsewered   areas  under  EIS  Alternative  6 and  $50 under  the
Limited  Action   Alternative.   Clearly,  the  decentralized  alternatives
involve  the least  amount  of  sewering and  have  the lowest amount of
ineligible costs.

     In  addition to  user  charges,  households  in newly  sewered  areas
would  have  to  pay  the  capital  costs  (approximately  $1,000  for  each
connection) of  a house  sewer on  their property to  connect  to gravity
collector sewers.   Seasonal homeowners may  also have  to pay  the  full
price  for the  replacement or  rehabilitation  of their on-site  systems
(septic  tanks  and soil  absorption systems)  if  they  do  not  cede these
sytems to the local  wastewater management agency.  Assuming, however,  a
reasonably  high proportion  of public  on-site system ownership  Alter-
natives  3,  4 and 5  would  offer substantial,  and Alternatives  6  and
Limited  Action,  an  almost total, reduction in private  costs.   Overall,
additional  costs  would   vary   from  household  to  household  due   to
differences in the distance to the collection sewer and the condition of
on-site systems.
                                   169

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3.   LOCAL COST BURDEN

a.   Significant Financial  Burden

     High-cost wastewater  facilities  may place  an excessive financial
burden on users of the system.   Such burdens  may  cause  families to alter
their  spending patterns  substantially by  diverting money  from their
normal  expenditure  categories.  The  Federal  government  has developed
criteria  to identify  high-cost wastewater  projects  (The  White House
Rural  Development  Initiatives  1978).    A   project  is   identified  as
high-cost when the annual user  charges  are:

     o    1.5% of median household  incomes less than  $6,000
     o    2.0% of median household incomes  between  $6,000 and  $10,000
     o    2.5% of median household  incomes greater  than $10,000.

     The  1978  median  household income  for  the  service  area has been
estimated to be $13,000 for permanent  residents.   (No data are available
for seasonal resident income characteristics.)  According  to the  Federal
criteria,  annual  user  charges should  not   exceed  2.5%   ($326)  of the
$13,000 median  household income figure.  Any  alternative having annual
user charges exceeding $326 is  identified as  a  high-cost alternative and
is  likely  to place  a  financial burden  on  users of the  system.  Table
IV-6  identifies  the  alternatives that  are  classified  as  high-cost
according to the Federal criteria.

     Significant financial burden is determined by  comparing annual user
charges with the distribution of household incomes.   Families  not facing
a significant  financial  burden are the only  families able to  afford the
annual  wastewater  user  charges.   Table  IV-7  shows the  percentage of
households  estimated  to  face a significant   financial burden  under each
of  the  alternatives.   The  centralized  alternatives  (the Facility Plan
Proposed Action, EIS Alternative 1, and EIS  Alternative 2) imply annual
user charges that would  place  a significant financial  burden on 60-85%
of  the  households  in  the  entire system   if  costs  were distributed
equally, 5-25% of the households in Frankfort and Elberta, and 85-98% of
the  households in  the unsewered  area.   EIS Alternatives 3,  4, and  5
would  place a  significant burden  on  15-30% of  the households  in the
entire  system  (costs  distributed  equally),  10-25%  of  Frankfort and
Elberta households, and  30-40% of  the  households in  the unsewered area.
EIS  Alternative  6 would place a  significant burden on 15-25% of total
system  households,   15-25%  of  Frankfort and Elberta  households,  and
25-30%  of  the  households   in  the  unsewered  area.   The   Limited Action
Alternative would place  the least  financial  burden on  households in the
total system  (costs  distributed equally)  and the unsewered areas.  Only
5-10%  of  the  households  in  these   areas  would  face   a significant
financial  burden under  the Limited  Action  Alternative.   The  Limited
Action Alternative would place a  significant financial burden on 15-25%
of the households in Frankfort and  Elberta.

b.   Displacement Pressure

     Displacement pressure  is  the  stress placed upon families  to move
away  from  the service  area as a  result of costly  user  charges.  Dis-
placement  is  measured by  determining  the percent of  households having

                                   170

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annual user charges  exceeding  5% of their income.   The pressure  induced
by each of the alternatives is  listed in Table IV-7.

     Displacement   pressure   is    highest    under    the   centralized
alternatives.   In the unsewered area, 40-60% of the households  will  face
displacement   pressure   under  the   centralized   alternatives.    EIS
Alternatives  3,  4,  and  5 have  displacement  pressures of 5-15%  in  the
unsewered areas.  The  decentralized alternatives may  cause up 1-10% of
the unsewered  households  to  be displaced.  Displacement pressure is  not
as  severe  in  Frankfort  and  Elberta:   approximately  1-5%  of   the
households may potentially be  displaced under each of the alternatives.
When  the costs  are distributed equally  throughout  the service area,
displacement pressure  ranges from  15-30% under centralized  alternatives
to 1-5% under the decentralized alternatives.

c.   Conversion Pressure
     Wastewater  facilities costs  are  likely  to  encourage  the  trend,
already  underway,  of   converting   seasonal   residences  to  permanent
residences.   The  requirements  would impose a  relatively heavier  cost
burden  on  seasonal  residences of  capital expenses  than on  permanent
ones.   These  residences  would typically  be  used  only  three or  four
months during the year but would be charged for  capital costs throughout
the year.  This may  place a financial burden on  seasonal residents who
are  maintaining  a  full-time   residence  in addition  to  their seasonal
residence.    The  higher  cost  burden of  centralized  alternatives  will
exert more conversion pressure than the cost burden of the decentralized
alternatives.   Because of the apparent high income of  seasonal residents
(based  on visual  inspection  of  seasonal residences)   the   number  of
seasonal-to-permanent  residential   conversions   as   a  result  of  the
wastewater user charges is likely to be small  in any case.

4.   MITIGATIVE MEASURES
     The significant financial burden and displacement pressure on users
in  the  unsewered areas  may be mitigated  by selection of a  lower cost
decentralized  alternative.   The  local wastewater management  authority
may seek to  obtain  a loan or grant from the Farmers  Home  Administration
Such  a  loan  would  decrease  annual  user  charges  by spreading out  the
payment of  the local  share over  a  longer period of time with a lower
interest rate.  The  impacts of the high costs  to  seasonal  users  may be
mitigated  by  not charging for  operation and  maintenance  during  the
months that seasonal residences are vacant.
                                   173

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F,    IMPACT  MATRIX
IMPACT CATEGORY

Surface Water
Quality
IMPACT

Nutrient loading
(Phosphorus)
                   Shoreline
                   Eutrophication;
                   Cladophora
                   growth
                   Non-Point Source
                   Runoff
IMPACT TYPE
& DEGREE

Primary:
Long Term
                    Primary:
                    Long Term
                    Primary:
                    Short  term
                                                       IMPACT DESCRIPTION
                All Alternatives:

                None of the alternatives  will have  a significant  im-
                pact on phosphorus loading since only  77.  of  existing
                nutrient load comes from septic  tanks  in  contrast  to
                93X from non-point sources and precipitation.  Lake
                trophic status will not  be changed.

                Betsie:

                All Alternatives:

                All alternatives will reduce phosphorus load by
                43-48% by eliminating plant discharge  or  by  chemi-
                cally removing phosphorus in the RBC plant.  No  change
                in trophic status as predicted by  model.

                Crystal:

                Alternatives 1, 2 and Proposed Action:

                These alternatives would have the  greatest potential
                for eliminating lakeshore eutrophication  by  eliminat-
                int septic tanks as a source of  nutrients for
                Cladophora growth.

                Alternatives 3, 4, 5, 6:

                Would eliminate the major sources  of nutrients from
                septic tanks by sewering the northeast shore.  How-
                ever, some on-site systems will  continue  to  leach
                nutrients for localized  algal growth along the
                northwest.  (Alt.  3, 4,  5 +• 6) and southeast shore
                (3, 4+5)

                Limited Action:

                On-site systems will continue to provide  nutrients
                for shoreline Cladophora growth.

                Crystal:

                Alternatives 1, 2, Proposed Action:

                A temporary increase in  soil erosion and  sedimentation
                will occur as the result of sewering

                Alternative 3, 4,  5, 6:

                Increased soil erosion and sedimentation  will  be less
                than with the centralized alternatives.
Groundwater
                   Groundwater
                   Quantity
                                       Secondary:
                                       Long Term
                    Primary.
                    Long Term
                                       Secondary:
                                       Long Term
                Betsie;

                All Alternatives:

                Construction-related impacts will be minimal.

                Alternatives 1,  2,  Proposed Action:

                Induced  growth is  likely to be greatest as a result
                of these alternatives and growth will be concentrated
                along the shoreline.   This may result in increased
                non-point source runoff

                Alternatives 3,  4,  5. 6, Limited Action:

                Growth is consistent with baseline projections and
                development is scattered.  Therefore in comparison to
                centralized alternatives, increased non-point  source
                runoff is less.

                All Alternatives (except Limited Action);

                Failure  to return  wastewater flows to groundwater
                results  in neglibible loss of groundwater recharge
                to local aquifer(s)

                All Alternatives:

                Loss of  aquifer recharge area as the result of develop-
                ment of  impervious  surface cover is  minimal.
                                                  174

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IMPACT CATEGORY
                   IMPACT

                   Groundwater
                   Quality
Environmentally
Sensitive Areas
Floodplain
                   Wetland
                   Steep SLopes
                    IMPACT TYPE
                    & DEGREE

                    Primary:
                    Long Term
Secondary:
Long Term
                                       Primary:
                                       Short or
                                       Long Term
                                       Secondary:
                                       Long Term
                    Primary:
                    Short  Term
                                       Primary:
                                       Long Term
IMPACT DESCRIPTION

Limited Action:

With the continued reliance on septic tanks, there is
the possibility of localized high groundwater nitrate
concentrations.

Phosphorus from septic tanks will continue to leach in
concentrations sufficient to support localized algal
growth.

Alternatives 3, 4, 5 and 6: '

The potential  for nitrate contamination of groudwater
is minimized by sewering the northeast shore, since
this is the only lakeshore area with known localized
groundwater problems.  Similarly, phosphorus availability
for localized  algal growth is minimized.

Alternatives 1, 2, Proposed Action:

Sewering entire lakeshore area eliminates septic tanks
as a source of (1) nitrates for localized groundwater
contamination  and (2) phosphorus as a nutrient source
for localized  algal growth.

All Alternatives:

Impacts on flood hazard areas are expected to be minimal.

Alternatives 1, 2, 4, 5, and Proposed Action:

Construction-related impacts will be unavoidable.
Whether they are short- or Ions-term, depends upon the
extent to which the original configuration is restored.

All Alternatives:

Some growth may occur in wetlands adjacent to Betsie
River, regardless of the wastewater management alternative.

All Alternatives:

Some temporary increases in erosion and sedimentation
may occur as a result of construction.  These impacts
would be most significant for Alternatives 1, 2, and
Proposed Action.

Alternatives 3. 4. 5,  6;  Limited Action:

Impacts associated with the use of decentralized systems
on steep slopes will be minimal; only systems designed
specifically for steep slopes will be used.
                                       Secondary:
                                       Long Term
                   Prime
                   Agricultural
                   Lands
                    Primary:
                    Short Term
                                       Secondary:
                                       Long Te rm
                Limited  Action:

                Development  on steep  slopes will  be mimirxal and scattered.

                Alternatives 1,  2,  Proposed Action:

                Possible impacts to steep  slopes  along shoreline may
                occur  with  increased  residential  development.   This may
                result in increased erosion and sedimentation  which
                contributes  to non-point source runoff.

                Alternatives 3,  4,  5,  6:

                Less growth  and  development of steeply slopes  areas will
                result from  these alternatives as compared  to  1,  2 and
                Proposed Action.

                All Alternatives:

                Direct impacts from construction  of wastewater management
                alternatives will be  minimal.

                Limited  Action:

                Development  of some prime  agricultural land may result
                since  large  lot  scattered  develop is encouraged.

                Alternatives I,  2,  Proposed Action:

                Development  of prime  agricultural land is less likely
                since  growth is  concentrated  along the shore.

                Alternatives 3,  4,  5,  6:

                Some development of prime  agricultural land may result.
                                               175

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IMPACT CATEGORY

Environmentally
Sensitive Areas
                   IMPACT
Sand Dunes
IMPACT TYPE
5. DEGREE

Primary:
Short Term
IMPACT DESCRIPTION

All Alternatives;

Primary impacts on sand dunes will be minimal.
                                       Secondary:
                                       Long Term
                                       Impacts
Population
Rate of
Growth
Secondary:
Long Term
Land Use
                   Developable
                   Acreage:
                   Growth
                   Patterns
                    Secondary:
                    Long Term
Local Economy
Local Cost
Burden
Primary:
Long Term
Alternatives 3, 4. 5, 6. Limited Action:

Some development may occur on unprotected sand dunes.

Alternatives 1, 2, Proposed Action:

Development is likely to occur close cc the shoreline as
a result of sewering.  Consequently development on unpro-
tected sand dunes is less likely.

Limited Action:

Projected study area population would be 7% below design
population for the year 2000.

Alternatives 3, 4, 5, 6:

Growth anticipated to increase 4% above baseline projections.

Alternatives 1, 2, Proposed Action:

Growth anticipated to increase 19% above baseline projections.

Limited Action;

Residential acreage is anticipated to increase by 77% even
if no centralized treatment is provided.  This alterna-
tive encourages scattered, low-density development.

Alternative 3, 4, 5 6:

Residential acreage would increase by about 85%.  Develop-
ment would be  less scattered and some high density develop-
ment would be  found in sewered areas.

Alternative 1, 2, Proposed Action:

Residential acreage would increase by 88% or 630 acres.
Higher density development close to the shoreline would
result.

Limited Action:

Average annual cost per resident would be $100 for resi-
dents of Frankfort and Elberta and $50  for the residents
in unsewered areas.

Proposed Action:

Annual cost per resident would be  $110  for residents of
Frankfort and  Elberta; and $720  for residents of unsewered
areas.  One-time household charge  for hook up  to the
sewer vould be approximately $l,000/household.

Alternative 1, 2:

Annual cost per resident would te  $90 or  $60  for resi-
dents of Frankfort and Elberta for Alternative 1 and 2
respectively;  residents of currently unsewered areas
would pay $650 or $590 annually,  respectively.

Alternative 3, 4, 5:

Annual cost per resident would be  $110,  $100,  or $90 for
residents of Frankfort  and Elberta fcr  Alternatives  3,  4,
and  5  respectively.   Residents from currently unsewered
areas would pay $220, $180,  or $240  annually  for Alterna-
tives  3, 4, or 5  respectively.   One  time  household  charge
for  gravity sewer connection approximately would be  $1,000
per  household.

Alternative 6:

Annual change  for residents  of Frankfort  and  Elberta would
be  $100, while the  charge  for  residents of  the currently
unsewered areas would be  $190.   One-time  household  charge
would  be approximately  $1,000.
                                                  176

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IMPACT CATEGORY
Local Economy
IMPACT

Financial
Burden;
Displacement
Pressure
IMPACT TYPE
& DEGREE

Primary:
Long Term
                   Community
                   Composition
                   and
                   Character
 IMPACT DESCRIPTION

 Limited Action:

 Displacement pressure is lowest with the limited action
 Alternative; 1-5% of the residents of Frankfort and
 Elberta would be threatened with displacement while
 less than 1% of residents of unsewered areas would feel
 displacement pressure.  A financial burder would be
 experienced by about 25% of Frankfort/Elberta residents
 and 10% of residents of unsewered areas.

 Alternatives 1, 2, Proposed Action:

 Displacement pressure (50-60%) and financial burden
 (85-98%) are high for residents of currently unsewered
 areas.  About 1-5% of the residents of Frankfort and
 Elberta would feel displacement pressure while up to
 15% of the population would experience a financial bur-
 den with Alternative 1 and 2 and 25% with proposed
 action.

 Alternatives 3, 4, 5:

 Displacement pressure of 1-5% for residents of Frankfort
 and Elberta and 5-15% for residents of unsewered areas.
 The financial burden would be 15-25% for residents of
 Frankfort and Elberta and 25-40% for residents of unsewered
 areas with Alternatives 3 and 4.  With Alternative 5 the
 financial burden would be 10-15% for Frankfort and Elberta
and 30-40% for residents of unsewered areas.
 Alternative 6:

Displacement pressure of 1-5% for residents of Frankfort
 and Elberta and 5-10% for residents of unsewered areas.
 Financial burden would be 15-25% for residents of Frank-
 fort and Elberta and 25-30% for residents of unsewered
 areas.

Limited Action:

Minimal impact on existing composition and character.

Alternative 3,  4,  5,  6:

 Some loss of lower income population base due to dis-
placement pressure.

Alternative 1,  2,  Proposed Action:

Significant loss of lower income population base;
potential disruption of community composition and charac-
 ter.
                                               177

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                               CHAPTER V

                         RECOMMENDED ACTION
     As  discussed  in  Section  I.D.I,  EPA has  several  possible choices
about the Facility Plan Proposed Action.   The Agency may:

     •    Approve the  original  grant application, possibly with recom-
          mendations  for  design  changes  and/or measures  to mitigate
          impacts of the Facility Plan Proposed Action;

     e    Return  the  application  with  recommendations  for  additional
          Step I analysis;

     •    Reject the grant  application;

     •    With the applicant's  and  State's  concurrence,  approve Step II
          funding  for  an  alternative  to  the  Facility  Plan Proposed
          Action.

     The  choice  of one of these  options  depends on  how the EIS alter-
natives compare to the Facility Plan Proposed Action.

     The  new  recommended alternative,  described in  this chapter,  is an
approach  to  meeting  the  problem of  water  quality  in  the  Study Area.
Selection of  this  alternative  is  tentative:  the applicant, the public,
and  State,  local  and Federal  agencies  are expected  to provide input
regarding its impacts, funding and implementation.
A.   SELECTION  OF THE RECOMMENDED ALTERNATIVE

1.   EVALUATION RESULTS

     Four primary criteria were used in selecting  the  recommended alter-
native:  costs, impact;  reliability; and flexibility.  Within each cate-
gory  several  factors  were  compared.   Costs,  for  example,  included
present worth, centralized  user  charges,  small waste  flow district user
charges, and total  1980  private  costs.   Impacts   which EPA  considers to
be  decisive in  alternative  selection  are identified  and  considered.
Alternative reliability  is  measured against centralized collection and
treatment as the  standard.

     A  matrix  provides  a  simple  method of  visualizing the relations
between alternatives  and the  criteria  applied in evaluating them.   By
tabulating each alternative and  the factors that  influence  the range of
choices, one  can quickly compare  the  effect  of  each alternative upon
that  factor.   Section IV.F contains a matrix relating alternatives to
environmental  impacts.   Table  V-l presents  a matrix  summarizing  the
relationship between  the  alternatives  and their costs, environmental
impacts, reliability and flexibility.
                                  179

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                                                       181

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     Table V-l  ranks  the  alternatives according to their  total  present
worth.  This is done for several reasons:

     o    Costs  are  easily quantifiable,  perhaps  the least  subjective
          measure of value.

     o    Non-capital   costs   impact   other  factors  influencing   the
          decision-making   process:    user  charges,  displacement  pres-
          sures, and conversion pressures.

     o    EPA  Construction  Grants  regulations require selection  of  the
          most cost-effective alternative.   That is,  the  one meeting  the
          project goals with  the  least total present worth  and  accept-
          able environmental and socioeconomic impacts.

     Selection of the cost-effective alternative requires identification
of trade-offs between costs and other relevant criteria.   The evaluation
factors  included  with total  present  worth in  Table  V-l  are  those  EPA
determined to be most important in identifying trade-offs.

2.   CONCLUSIONS

     Most of  the  on-site  systems  around Crystal Lake and in the  Village
of Benzonia are working well.   Approximately 90  effluent  plumes entering
Crystal  Lake  and a  few  surface  malfunctions  have  been  identified.
Periodic sewage backup  in some systems also occurs.   On-site systems do
not appear as  a significant contributor of nutrients to  Crystal  Lake --
of  the  total  input  of  phosphorus,  6.7%  or less comes  from effluent
plumes.  Where  plumes  do  emerge,  however,  they appear to  be supporting
localized growths of Cladophora.

     The only surface water quality improvement in Crystal  Lake  likely
to  result  from  the  Facility Plan Proposed  Action or  any of the  EIS
alternatives  would  be the  possible reduction in  number and  density of
localized growths of  Cladophora along the shoreline.  This  could occur
if on-site systems  along  the shoreline were  abandoned and cluster  sys-
tems  or  centralized  sewers used.   It also could occur for certain kinds
of  on-site  upgrading,  such  as  mound  systems.   No  alternative  should
affect  either adversely or  beneficially  the water quality  of the  main
body of  Crystal Lake through the year 2000.

     Future  development in  the Crystal Lake watershed  depends  on  how
many  new lots  can  be developed and the density of  future development.
Alternatives  relying  on continued  use of on-site systems would restrict
both  the number of  new lots  and their  density  as  compared to extensive
sewering around  the  lake.   One effect of  these  limitations  would be to
preserve the present character of the community.

     There  are large  differences  in the present worth  and  user  cost
among  the alternatives.   Both costs increase with sewer  centralization.
In the more expensive alternatives, high local user charges would result
in  substantial displacement  pressure  for  the permanent  population  and
pressure for conversion of seasonal  residences to permanent use.  Pro-
portionate increases in water quality would not occur.


                                    182

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     Because of  the high  costs  and limited benefits  to water  quality
with the centralized alternatives (Facility Plan Proposed Action  and EIS
Alternatives 1  and 2),  they  are not cost-effective and are not  recom-
mended.

     The  No Action Alternative  was  unacceptable  for  three reasons:

     o    Existing  treatment  plants  at Frankfort  and  Elberta  do not
          comply with effluent requirements and contribute  substantially
          to high productivity in Betsie Lake.

     o    There are some on-site system problems in the remainder of the
          Proposed  Service  Area.   These   problems  can  be   addressed
          through  monitoring,  improved maintenance of the existing and
          future systems, residential water conservation, and  renovation
          or replacement of existing systems.

     o    Improved surveillance and regulation  of on-site systems in the
          Crystal  Lake watershed  is justified  to  maintain  its  unique
          scenic and recreational values.

     Those  sections of the Proposed Service Area that would be  sewered
in EIS Alternative 3,  4 and 5,  showed insufficient  need for sewering
except for  areas  of high groundwater along the  northeast  and  southeast
shorelines.  For  the  two  shoreline areas, off-site treatment by land
application  (EIS  Alternative  6)  or by  cluster  systems  (Limited  Action
Alternative) could remedy local problems.

     In  addition  to providing off-site treatment for  the  northeast and
southeast shorelines,  EIS  Alternative  6 would  also sewer the  Village  of
Benzonia.  The costs for sewering Benzonia  are  high and do  not  appear  to
be justified by the presence of only 5 surface  malfunctions.   Joint land
application  by  Benzonia and  Beulah has been discussed  by officials  of
the two  municipalities.  In the event that such an approach is proposed
by them  for Federal  funding,  a redesigned Alternative 6 may be  appro-
priate.

     The  Recommended  Action  in  this  draft EIS  is the Limited  Action
Alternative described below (see Figure V-l).
B.   DRAFT EIS  RECOMMENDED ALTERNATIVE

1.   DESCRIPTION

     The Recommended Alternative includes:

     o    a  new  treatment  plant  to  serve  Frankfort  and  Elberta  and
          necessary interceptor sewers;

     o    sewer  system evaluation surveys  and  rehabilitation of  sewer
          systems in Frankfort and Elberta;
                                   183

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     o    design  and  implementation  of  a  small  waste  flow district;

     o    site-specific  environmental  and engineering analysis of exist-
          ing on-site  systems in  the unsewered parts  of  the Proposed
          Service Area;

     o    repair and renovation of  on-site  systems as needed;

     o    cluster systems or other  off-site  treatment for the northeast
          and southeast  shorelines.  Additional  small  scale, off-site
          treatment units may  be eligible  for  funding  if warranted by
          the site-specific  analysis  of  existing on-site  systems and
          relevant  cost-effective   analysis  performed  during  Step II;

     o    survey of effluent discharges to  Cold Creek to detect leakage
          from  Beulah  sewers  (Kerfoot  1978; Tanis  1976),  followed by
          replacement or repair of  leaking  pipes;  and

     o    survey of Crystal  Lake groundwater flow  and direction to  allow
          final  assessment of  flow  reduction  as an aid  to treatment for
          the western third  of Crystal Lake.

     Section  III.C.2.b  presents a fuller  description  of  the  Limited
Action  Alternative.   Discussions  of  its  components  are  presented in
Section III.B.

2.   IMPLEMENTATION

     Design and  construction of the interceptors and treatment plant for
Frankfort and Elberta  would proceed  according  to established 201  Con-
struction Grants  regulations.   Step II  and III  funding  for  these facil-
ities  should  be applied  for  and granted independently  from grants for
unsewered portions of the Proposed  Service  Area.   Management of central-
ized  facilities  in  the  Crystal Lake Study  Area  was discussed in Section
III.D.l.b.

     Management   of  decentralized  facilities  was  discussed in Section
III.D.2.b and Appendix  K.   Several specific aspects of  implementing the
Recommended Alternative are  discussed  below.

a.    Compliance  with State  and  Local  Standards  in  the Small
     Waste Flows District

     As discussed in Section  II.C.  many existing  on-site  systems do not
conform to  current design  standards  for eite,  design or distance  from
wells  or  surface waters.   For some systems,  such as those  with under-
sized  septic  tanks, non-conformance  can be remedied relatively easily
and  inexpensively.   In  other  cases  the remedy may  be disruptive and
expensive.  Obviously,  extraordinary renovation  or replacement should be
undertaken  only where  the  need  is  clearly  identified.    Data  on the
effects of existing systems  indicate that many nonconforming systems, as
well  as future  repairs  that still  may not  conform to design standards,
may  operate  satisfactorily.  Where compliance with design  standards is
either  1)  in-feasible,  or too expensive or 2) site monitoring of ground
                                   185

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and surface waters shows that  acceptable impacts are attainable, then a
variance procedure to allow  renovation and continued use is recommended.
Decisions to grant variances should be based on site-specific data or on
a substantial history of similar  sites in the area.

     Local and  state decisions on variance  procedures  would likely be
influenced by  the degree of authority vested  in  the  small waste flows
district.  If  the district  has sufficient  financial  backing to correct
errors, and trained  personnel  to minimize errors in granting variances,
variance procedures may be  more  liberal than if fiscal and professional
resources are  limited.   Higher local costs,  caused  by unnecessary re-
pairs  or  abandonment of systems is  expected to  result  from very con-
servative  variance  guidelines,  or  none  at  all.   Conversely,  ill-
conceived  or  improperly  implemented variance  procedures  would  cause
frequent water quality  problems and  demands  for more expensive off-site
technologies.

b.   Ownership  of On-Site  Systems  Serving Seasonal Residences

     Construction Grants regulations allow  Federal funding for renova-
tion and replacement  of publicly  owned on-site systems serving principal
or seasonally occupied residences and of privately  owned on-site systems
serving   principal    residences.    Privately  owned   systems   serving
seasonally  occupied  residences are  not eligible  for  Federally funded
renovation and replacement.

     Depending  on the  extent  and  costs of  renovation  and replacement
necessary for  seasonal  residences,  the  municipalities  or  a small waste
flow  district  may elect  to  accept  ownership of  the  on-site systems.
Rehabilitation  of these  systems would  then  be  eligible  for Federal
assistance,  resulting  in  a  drastic (90%)  drop  in  local costs  for
seasonal   residents.    Any   decision   to   accept   ownership   on  a
community-wide basis  should await  the  conclusions of the  site-specific
environmental and engineering  analyses and preliminary determination of
the  functions  of the management agency.   Ownership  of seasonally used
systems  may  create   responsibilities that  the agency  does  not  want.

c.   Completion of Step  I  (Facilities  Planning)  Requirements
     for  the  Small  Waste  Flow District

     If the  applicant,  local municipalities  and the State  concur in the
Recommended Alternative, Construction Grants regulations for individual
systems  ("Privately  owned  alternative  wastewater  treatment  works...
serving  one  or more  principal  residences...")  require  the applicant to
take  the following  actions before  award  of  a  Step II grant (40 CFR
35.918):

     o    Certify that  the  project  be constructed and  an operation and
          maintenance  program  established  to  meet  local, State  and
          Federal requirements.

     o    Obtain assurance  of unlimited  access  to  each individual system
          at  all reasonable  times   for  such purposes  as   inspections,
          monitoring, construction,  maintenance, operations,  rehabilita-
          tion and replacement.

                                  186

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     o    Plan for  comprehensive  program of regulation  and  inspection for
          individual systems.

     These actions  would have  to be  taken by the applicant prior to request-
ing Step II funds.

d.   Scope of Step II for  the Small Waste Flow District

     A  five  step  program  for wastewater  management in  small waste  flow
districts was suggested in  Section III.D.b.  The first three would appropri-
ately be completed  in Step  I.   These are:

     o    Develop a  site-specific environmental  and engineering data base,

     o    Design  the management organization, and

     o    Agency  start-up

     EPA will assist the applicant in defining specific objectives and tasks
for Step II work, both before  and  after  the Step II  grant.

3.   IMPACTS  OF  THE  RECOMMENDED  ALTERNATIVE  AND  MITIGATING
     MEASURES
Soil erosion and resulting
sedimentation and nutrient
transport during construction
of on-site and cluster systems,
Frankfort-Elberta interceptors
and STP, new housing and roads.

44% reduction in phosphorus
input to Betsie.  Trophic
status may improve.

Colonization of Cladophora in
localized areas along Crystal
Lake shoreline will  continue.
Increase in number and density
is possible but not  predictable.
Potential for localized nitrate
standard violations in private
wells around Crystal Lake.
Potential will increase as
densities of wells and ST/SAS
increase.
Mitigating Measures

Compliance with provisions  of the  Soil
Erosion and Sedimentation Control  Act.
Require individual plan approval for
construction on steep slopes  and adopt
performance standards with  specific
slope-density provisions.

Maintaining or improving on this reduc-
tion will require careful control  and mon-
itoring of wastewater treatment processes.

Residential flow reductions,  use of non-
phosphate detergents, control of lawn
fertilization, rehabilitation or replace-
ment of ST/SAS, off-site treatment, use
of composting toilets, local  application
of copper sulfate. EPA will conduct field
studies on effluent/soil/groundwater/
Cladaphora relationships at Crystal Lake
in summer, 1979.

Detailed groundwater hydrology investiga-
tion during STEP II.  Design  and operate
well and aquifer monitoring system during
Step II.  Develop reserve fund for future
off-site treatment facilities or community
wells.
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Potential for bacterial, organic and
nutrient contamination of Betsie Lake
from pump station or treatment plant
malfunction.

Potential for bacterial, organic and
nutrient contamination of Crystal Lake
from cluster system or pressure sewer
pump malfunctions.

Control of apparent wastewater discharges
to Cold Creek from Beulah is not included
in the Recommended Action.

Water supply demands of increasing popu-
lation in Frankfort and Elberta will
exceed capacity of existing storage
and distribution facilities.

Design year population of Proposed Ser-
vice Area will be 7% less than EIS trend
projection.

Residential land acreage will increase
perhaps 77% during the planning period.
Existing properties in Crystal Lake
watershed will appreciate due to limi-
tations on amount of developable land.

Existing community composition and
character will change less rapidly with
other alternatives.

Limitation on developable acreage result-
ing from Recommended Alternative may
shift development pressure to sand dunes
west and southwest of Crystal Lake.


Average annual user charges for residents
of Frankfort and Elberta may be $100.  20
to 25% of the residents will face finan-
cial burdens.  1 to 5% may relocate to
avoid paying increased costs.
Average annual user charges in the small
waste flow district may be $50.  5 to
10% of the residents will face financial
burdens.  1 to 5% may relocate or convert
to permanent occupancy to avoid paying
charge.
Private costs for renovations or repair
of seasonally used systems may be high
due to ineligibility for grant.
Mitigating Measures

Can be minimized by adequate oper-
ation and maintenance procedures
and funding.
Periodic inspection and maintenance
of pump systems.   Emergency repair
service.


The Village should, independently
or with grant, identify and con-
trol these discharges.
Institue waste conservation plan
and/or expand facilities.
Benzie County should study the eco-
systems of the dunes and the impact
that development may have on them.
Lake Township should provide zoning
that protects the dunes.
Cede seasonally used systems to
small waste flow dis;trict.
                                    188

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                             CHAPTER VI

             THE RELATIONSHIP BETWEEN SHORT-TERM USE
                    AND LONG-TERM  PRODUCTIVITY
A.   SHORT-TERM USE OF THE STUDY AREA

     Crystal  Lake has been,  and  will continue  to be used  as  a resi-
dential/recreational  area.   The  site was  initially disturbed when con-
struction of  houses first began.

     Disturbance   of   the  site  by  routine  residential/recreational
activities will  continue.   Implementation of either the  action proposed
by the Facility Plan or recommended  in this EIS is not expected to alter
these disturbances.
B.   IMPACTS UPON  LONG-TERM PRODUCTIVITY

1.   COMMITMENT OF NON-RENEWABLE RESOURCES

     If  the  Facility  Plan  Proposed  Action  were  implemented,  the
increased  potential   for  development  might  result  in  some  loss  of
terrestrial habitat.  Such  would  be expected  to  a  lesser  extent  by
implementation of the  Recommended Alternative of this EIS.

     Non-renewable resources associated with either action would  include
concrete for  construction.   Consumption of electric power by pumps may
also increase.  Manpower would  also be  committed  to  the  construction,
operation and management of new or  rehabilitated facilities.

2.   LIMITATIONS ON BENEFICIAL USE OF THE ENVIRONMENT

     Neither the Proposed Action  nor the  Recommended Action will have
any significant effect on beneficial use of the environment.  Existence
of the community has predetermined  the uses to which the  environment can
be put.
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                             Chapter  VII

    IRREVERSIBLE   AND  IRRETRIEVABLE  COMMITMENT  OF  RESOURCES
     Those resources  associated  with  construction  and maintenance of
wastewater systems would be committed.   These were discussed  in  Section
VI.B.I.

     In addition the growth expected in the  Study Area would  require a
commitment of  resources  to the construction of new dwellings and  com-
mercial  establishments,   construction  or  improvement of  roads,  and
facilities   associated   with  water   sports.    Besides    construction
materials, such as  lumber, steel,  concrete  and glass, electricity and
manpower would also  be  committed to new development.

     Human resources would  include  construction personnel  and,  perhaps
infrastructural personnel  to service the added community needs.
                                   191

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                            Chapter VIII

       PROBABLE ADVERSE  IMPACTS WHICH  CANNOT BE  AVOIDED
     If the action proposed by the Facility  Plan were implemented,  some
destruction of  terrestrial habitat would result  from construction of new
dwellings.   Such would be  true,  but  to a  lesser  extent,  if the Recom-
mended Alternative  in this EIS  were  implemented.  If  the Recommended
Alternative were selected, some  reduced localized growth of Cladophora
might be  expected along the shoreline of Crystal Lake.
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                               GLOSSARY
ACTIVATED SLUDGE PROCESS.  A method of secondary wastewater treatment in
     which a  suspended microbiological culture is maintained  inside an
     aerated treatment basin.  The  microbial  organisms oxidize the com-
     plex organic matter in the wastewater to  carbon dioxide,  water,  and
     energy.

ADVANCED WASTE TREATMENT.   Wastewater treatment beyond the secondary or
     biological  stage  that  includes removal of nutrients  such  as  phos-
     phorus  and  nitrogen  and a  high percentage  of  suspended  solids.
     Advanced waste treatment, also known as  tertiary treatment, is  the
     "polishing  stage"  of  wastewater  treatment  and  produces  a  high
     quality of effluent.

AEROBIC.  Refers to life or processes that occur only in the presence of
     oxygen.

ALGAL BLOOM.  A  proliferation of algae on the surface of lakes,  streams
     or  ponds.   Algal  blooms are  stimulated by phosphate  enrichment.

ALKALINE.  Having  the qualities  of a base,  with  a pH of more  than 7.

ALLUVIAL.  Pertaining  to material  that  has been  carried by a  stream.

ALTERNATIVE  TECHNOLOGY.   A  technology whose  use  has been widely sup-
     ported by  experience,  but  is  not a  variant  of  conventional bio-
     logical or physical/chemical treatment.

AMBIENT AIR.   The unconfined portion of the atmosphere; the outside air.

ANAEROBIC.  Refers  to life  or processes  that  occur in  the  absence of
     oxygen.

AQUATIC  PLANTS.   Plants  that grow in water,  either  floating  on  the
     surface, or rooted emergent or submergent.

AQUIFER.  A geologic  stratum or  unit that contains water and will allow
     it  to  pass  through.   The water may  reside  in  and  travel  through
     innumerable spaces between rock grains in a sand or gravel aquifer,
     small  or  cavernous openings  formed  by  solution  in a  limestone
     aquifer, or  fissures,  cracks,  and  rubble in such harder  rocks as
     shale.

ARTESIAN AQUIFER.  A  water-filled layer  that  is sufficiently compressed
     between less permeable  layers  to cause the water to rise above  the
     top  of  the  aquifer.   If the  water  pressure  is  great,  water will
     flow freely from artesian wells.

ARTESIAN  WELL.   A well  in  which flow  is sustained  by the  hydrostatic
     pressure of the aquifer.  See Artesian Aquifer.
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BACTERIA.  Any  of a  large  group  of microscopic plants  living  in soil,
     water or organic matter,  important to man because of their chemical
     effects as in nitrogen fixation,  putrefaction,  or fermentation,  or
     as pathogens.

BAR SCREEN.  In wastewater treatment, a screen that removes large float-
     ing and suspended solids.

BASE  FLOW.   The  rate  of movement  of  water in  a  stream  channel which
     occurs typically during rainless  periods  when stream flow is main-
     tained largely or entirely by discharges of groundwater.

BASIC  USAGE.   In  regard to  functions of  small waste  flow  districts,
     those  which would  be  required  to  comply with EPA  Construction
     Grants regulations governing individual on-site wastewater systems.

BEDROCK.  The solid rock beneath the soil and subsoil.

BIOCHEMICAL  OXYGEN  DEMAND  (BOD).    A  measure of  the amount  of oxygen
     consumed in  the  biological  processes that decompose organic matter
     in water.  Large  amounts  of organic waste  use  up large  amounts of
     dissolved oxygen;  thus,  the  greater the degree  of pollution,  the
     greater the BOD.

BIOMASS.   The  weight of  living  matter in a specified unit of environ-
     ment.   Or,  an expression of  the  total  mass  or  weight  of a given
     population of plants or animals.

BIOTA.  The plants and animals of an area.

BOD,-.   See "Biochemical Oxygen  Demand."   Standard  measurement is made
     for 5 days at 20°C.

BOG.   Wet,  spongy  land;   usually  poorly  drained,  and  rich  in plant
     residue, ultimately producing highly acid peat.

CAPITAL  COSTS.   All  costs  associated with  installation (as  opposed to
     operation) of a project.

CAPITAL EXPENDITURES.  See  Capital Costs.

CHLORINATION.  The  application  of chlorine to drinking water,  sewage or
     industrial  waste  for  disinfection  or  oxidation  of undesirable
     compounds.

COARSE FISH.  See Rough Fish.

COLIFORM  BACTERIA.   Members of a large group  of bacteria that  flourish
     in  the feces and/or intestines of warm-blooded animals,  including
     man.   Fecal coliform  bacterial,  particularly Escherichia coli  (E.
     coli),  enter water mostly in  fecal matter, such  as  sewage  or feed-
      lot  runoff.   Coliform bacteria  apparently  do not  cause  serious
     human diseases, but these organisms  are abundant  in  polluted waters
     and  they  are  fairly  easy  to  detect.   The  abundance of  coliform
     bacteria

                                    196

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     in water, therefore,  is  used as an index to the probability of the
     occurrence   of   such  diease-producing   bodies  (pathogens)   as
     Salmonella,   Shigella,  and  enteric viruses.   These  pathogens  are
     relatively difficult to detect.

COLIFORM ORGANISM.   Any of a  number of organisms common to  the intes-
     tinal tract  of  man and animals  whose presence  in  wastewater is an
     indicator  of  pollution  and of  potentially  dangerous  bacterial
     contamination.

COMMINUTOR.  A machine that breaks up wastewater solids.

CONNECTION FEE.  Fee charged by municipality to hook up house connection
     to lateral sewer.

CUBIC FEET PER SECOND (cfs).  A measure of the amount of water passing a
     given point.

CULTURAL  EUTROPHICATION.    Acceleration by  man  of  the  natural  aging
     process of bodies of water.

DECIDUOUS.  The  term describing a plant that periodically  loses all of
     its leaves,  usually  in the autumn.  Most broadleaf trees  in North
     America, and  a  few conifers, such as larch and cypress, are decid-
     uous .

DECOMPOSITION.  Reduction of the net  energy level and change in chemical
     composition  of organic matter  by action  of aerobic  or anaerobic
     microorganisms.   The  breakdown  of complex  material   into  simpler
     substances by chemical or biological means.

DETENTION  TIME.   Average time  required to flow  through a  basin.   Also
     called retention time.

DETRITUS.  (l) The heavier debris moved by natural watercourses,  usually
     in  bed  loam  form.   (2)  The sand, grit, and other coarse material
     removed by  differential  sedimentation in a relatively short period
     of detention.

DISINFECTION.  Effective  killing by  chemical or physical  processes of
     all organisms  capable  of  causing infectious disease.   Chlorination
     is  the  disinfection method  commonly  employed  in  sewage treatment
     processes.

DISSOLVED  OXYGEN  (DO).    The   oxygen  gas  (02)   dissolved  in water  or
     sewage.  Adequate  oxygen  is necessary for maintenance  of  fish and
     other  aquatic  organisms.   Low  dissolved  oxygen  concentrations
     generally are due to  presence  of excessive organic  solids having
     high BOD in inadequately treated wastewater.

DRAINAGE BASIN.   (1)  An area  from which surface  runoff is  carried away
     by  a  single  drainage  system.   Also  called  catchment  area, water-
     shed,  drainage  area.   (2)  The  largest  natural  drainage area sub-
     division of a continent.   The United States has been  divided at one
                                   197

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     time or another,  for  various  administrative purposes,  into some 12
     to 18 drainage basins.

DRAINAGEWAYS.   Man-made  passageways,  usually lined with grass  or  rock,
     that carry runoff of surface water.

EFFLUENT.  Wastewater  or other  liquid,  partially or completely treated,
     or in its natural state,  flowing out of a reservoir, basin,  treat-
     ment plant,  or industrial treatment plant, or part thereof.

EFFLUENT LIMITED.  Any stream  segment for which it  is  known that water
     quality  will meet  applicable water  quality  standards after  the
     application of effluent limitations.

ELEVATED  MOUND.    A  mound,  generally  constructed  of sand,   to  which
     settled wastewater  is applied.  Usually  used in  areas where con-
     ventional on-site treatment is inadequate.

ENDANGERED SPECIES  (FEDERAL CLASSIFICATION).  Any species  of  animal or
     plant declared to be in known danger of extinction throughout al or
     a significant part of its range.   Protected under Public Law 93-205
     as amended.

ENDANGERED  SPECIES  (STATE CLASSIFICATION).   Michigan's  list  includes
     those species on the Federal list that are resident for any part of
     their life cycle in Michigan,   also includes indigenous species the
     State believes are uncommon and in need of study.

ENDECO.  Type 2100 Septic Leachate Dector.   See "Septic Snooper".

ENVIRONMENT.    The  conditions  external  to a particular   object,  but
     generally  limited  to those  conditions  which  have a direct  and
     measurable  effect on  the  object.   Usually  considered to be  the
     conditions  which   surround  and  influence  a  particular  living
     organism,  population,  or  community.   The  physical   environment
     includes  light,  heat,  moisture,   and other  principally  abiotic
     components.    The  components  of  the  biotic environment  are  other
     living organisms and their products.

ENVIRONMENTAL  IMPACT  STATEMENT.   A  document  required by  the  National
     Environmental Policy  Act  (PL 91-190,  1969) that  is   used  in  the
     decision-making  process  to evaluate  the effects  (impacts)  of  a
     proposed action on the human,  biological,  and physical  environment.

EPILIMINION.    The  upper layer  of  more  or  less uniformly  warm,  circu-
     lating,  and  fairly  turbulent  water  in  lakes  during the  spring
     heating season.

EROSION.  The process by which an object is eroded, or worn  away,  by the
     action  of  wind,  water,  glacial  ice,  or  combinations   of  these
     agents.    Sometimes  used  to refer to results of chemical actions or
     temperature  changes.   Erosion may  be accelerated by  human  activ-
     ities .
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EUTROPHIC.  Waters  with a  relatively  large concentration  of  nutrients
     and hence a large production of organic matter,  often shallow,  with
     periods of oxygen deficiency.

EUTROPHIC LAKES.  Shallow  lakes, weed-choked at the  edges and  very  rich
     in  nutrients.    The  water  is  characterized  by  large amounts  of
     algae,  low  water transparency,  low dissolved oxygen and  high  BOD.

EUTROPHICATION.  The normally slow aging process by which a  lake evolves
     into a  bog or  marsh,  ultimately assumes  a  completely terrestrial
     state and  disappears.   During  eutrophication the lake becomes  so
     rich in  nutritive compounds,  especially  nitrogen and phosphorus,
     that algae  and plant life become  superabundant,  thereby  "choking"
     the  lake  and  causing  it eventually to  dry up.   Eutrophication may
     be accelerated by human activities.

EVAPOTRANSPIRATION.   A process  by  which  water  is  evaporated  and/or
     transpired from water, soil, and plant surfaces.

FECAL  COLIFORM BACTERIA.   The group of organisms common to the intes-
     tinal tracts of man and of animals.  The presence of fecal coliform
     bacteria  in water  is  an indicator of  pollution  and  of potentially
     dangerous bacterial contamination.

FLOE.  A  sheet of floating ice.

FORCE MAIN.   Pipe designed to carry wastewater under  pressure.

GLACIAL DEPOSIT.  A mass  of rock,  soil, and earth material deposited by
     a  melting glacier.   Such material  was  originally  picked  up and
     carried  along  its path  by  the  glacier,  and  usually varies  in
     texture  from  very  fine  rock  flour  to large  boulders.   Named
     according to their location and shape.

GLACIAL DRIFT.   Material  which  has  been  deposited  by a glacier or in
     connection  with  glacial  processes.   It  consists  of  rock  flour,
     sand, pebbles,  cobbles, and  boulders.  It may  occur  in  a  heter-
     ogeneous  mass   or  be more  or  less  well-sorted, according  to its
     manner of deposition.

GRAVITY  SYSTEM.   A  system  of  conduits  (open or closed)  in  which  no
     liquid pumping is required.

GROUNDWATER.  Water that is below the water table.

GROUNDWATER  RUNOFF.   Groundwater  that  is discharged   into  a  stream
     channel as spring or seepage water.

HABITAT.  The specific place  or the  general  kind of site in  which a
     plant  or animal  normally lives  during  all  or  part  of  its  life
     cycle.

HOLDING TANK.  Enclosed tank, usually of fiberglass or concrete, for the
     storage  of wastewater prior  to  removal or disposal at  another
     location.

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HYDROPONIC.  Refers to  growth  of plants in a nutrient solution,  perhaps
     with the mechanical support of an inert medium such as sand.

HYPOLIMNION.  Deep, cold and relatively undisturbed water separated from
     the surface layer in lakes.

IGNEOUS.   Rock  formed  by  the  solidification  of  magma  (hot  molten
     material).

INDIAN MOUND SYSTEM.  See Elevated Mound.

INFILTRATION.   The  flow of  a  fluid  into  a substance  through pores or
     small  openings.  Commonly  used in hydrology to denote the  flow of
     water  into soil material.

INFILTRATION/INFLOW.  Total  quantity of water  entering a  sewer  system.
     Infiltration means  entry  through such  sources  as  defective pipes,
     pipe joints,  connections,  or manhole walls.  Inflow signifies dis-
     charge  into  the  sewer system through service connections from such
     sources  as area  or foundation drainage, springs and  swamps, storm
     waters, street wash waters, or sewers.

INTERCEPTOR  SEWERS.  Sewers used  to collect  the  flows from main  and
     trunk  sewers  and carry them to a  central  point for  treatment  and
     discharge.   In a combined  sewer system,  where  street runoff from
     rains  is  allowed to enter the system along the sewage, interceptor
     sewers allow some of the sewage to  flow untreated directly  into the
     receiving  stream,  to  prevent the treatment  plant  from being over-
     loaded.

INNOVATIVE  TECHNOLOGY.   A  technology  whose use has  not been widely
     documented  by  experience  and is  not a  variant   of  conventional
     biological or physical/chemical treatment.

LAGOON.   In wastewater treatment, a  shallow pond,  usually man-made, in
     which  sunlight,  algal and bacterial  action  and  oxygen interact to
     restore the wastewater to a reasonable state of purity.

LAND TREATMENT.   A method  of treatment  in which the soil, air, vegeta-
     tion,  bacteria,  and  fungi  are employed to remove pollutants from
     wastewater.   In its  most simple  form,  the method  includes three
     steps:   (1)  pretreatment  to screen out large solids;  (2) secondary
     treatment  and chlorination;  and (3) spraying  over cropland, pas-
     ture,  or natural vegetation to allow  plants and soil microorganisms
     to  remove  additional  pollutants.  Much of the sprayed water evapo-
     rates,  and the remainder  may be allowed to percolate to the water
     table,  discharged  through  drain   tiles,  or  reclaimed by wells.

LEACHATE.   Solution formed when  water  percolates through solid wastes,
     soil  or other materials  and  extracts  soluble  or  suspendable sub-
     stances from the material.
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LIMITING FACTOR.   A factor  whose  absence, or  excessive concentration,
     exerts some restraining influence upon a  population.

LOAM.   The textural  class name for  soil having  a moderate  amount  of
     sand,  silt, and  clay.   Loam soils contain 7  to  27% of clay, 28 to
     50% of silt, and less than 52% of sand.

LOESS.   Soil  of wind-blown origin, predominantly  silt and  fine sand.

MACROPHYTE.   A  large  (not microscopic)  plant, usually in  an  aquatic
     habitat.

MELT  WATER.   Water which  is  formed from the  melting of  snow,  rime,  or
     ice.

MESOTROPHIC.  Waters with a moderate supply of nutrients and no signifi-
     cant production of organic matter.

MESOTROPHIC LAKE.   Lakes  of intermediate characteristics between oligo-
     trophic and eutrophic.  They contain a moderate supply of nutrients
     and plant life.

METHEMOGLOBINEMIA.   The presence of methemoglobin  in the blood.   Methe-
     moglobin is  the oxidized  form of hemoglobin  and  it  is unable  to
     combine reversibly with oxygen.

MICROSTRAINER.   A   device  for screening  suspended  solids that  are  not
     removed by sedimentation.

MILLIGRAM  PER LITER  (mg/1).   A concentration of 1/1000  gram of a sub-
     stance in  1 liter  of water.  Because 1  liter of pure water weighs
     1,000  grams,  the concentration  also can be stated  as  1 ppm (part
     per million,  by weight).   Used  to measure and  report  the  concen-
     trations of most  substances  which  commonly  occur in  natural  and
     polluted waters.

MORPHOLOGICAL.  Pertaining to Morphology.

MORPHOLOGY.  The form or structure  of a plant  or animal, or of a  feature
     of  the  earth, such  as a  stream,  a lake, or  the  land  in general.
     Also,   the  science  that  is concerned with the  study of form  and
     structure  of  living organisms.  Geomorphology deals  with the form
     and structure of the earth.

NON-POINT  SOURCE.   A  general  source of pollution not originating from a
     single controllable  source.   Surface water runoff is an example of
     a non-point source that is not easily controlled.

NUTRIENT BUDGET.  The amount of nutrients entering  and leaving a  body of
     water on an annual basis.

NUTRIENTS.    Elements  or  compounds  essential  as  raw  materials  for
     organisms  growth and  development,  e.g.  carbon, oxygen, nitrogen,
     and phosphorus.
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OLIGOTROPHIC.  Waters  with  a  small  supply of  nutrients  and hence  an
     insignificant production of organic matter.

OLIGOTROPHIC LAKES.  Deep  lakes  that  have a low  supply of  nutrients and
     thus contain  little organic matter.  Such  lakes  are  characterized
     by high water transparency and high dissolved oxygen.

ORDINANCE.  A municipal or county regulation.

OUTWASH.  Drift  carried  by melt  water  from  a   glacier  and  deposited
     beyond the marginal moraine.

OUTWASH PLAIN.  A  plain formed by material deposited by melt water from
     a  glacier flowing  over a  more or  less flat surface  of large area.
     Deposits of  this  origin are usually  distinguishable  from ordinary
     river deposits by  the fact  that they often  grade into moraines and
     their constituents  bear evidence  of glacial origin.   Also  called
     frontal apron.

PARAMETER.  Any of  a  set of physical properties  whose  values  determine
     characteristics or behavior.

PERCOLATION.   The  downward  movement  of  water  through pore  spaces  or
     larger voids in soil or rock.

PERMEABILITY. The property or capactiy of porous  rock, sediment,  or soil
     to transmit a  fluid,  usually water or air;   it  is  a measure of the
     relative  ease of   flow  under unequal  pressures.  Terms used  to
     describe the  permeability of  soil are:   slow,  less  than 0.2 inch
     per hour; moderately  slow,  0.2 to 0.63 inch; moderate, 0.63 to 2.0
     inches;  moderately  rapid. 2.0  to 6.3 inches; and  rapid,  more than
     6.3 inches per hour.  A very slow class and  a very rapid class also
     may be recognized.

PETROGLYPH.   An ancient or prehistoric carving or inscription on a rock.

PHOSPHORUS LIMITED.  Of all the primary  nutrients necessary to  support
     algal growth,  phosphorus  is  in  the  shortest supply  and therefore
     can limit additional algal growth.

PHYTOPLANKTON.  Floating plants, microsopic  in  size,  that  both supply
     small animals with food and give polluted water its green color and
     bad taste.

POINT SOURCE.  A stationary source of a large individual emission.  This
     is  a general  definition;  point  source  is legally  and  precisely
     defined in Federal regulations.

POVERTY LEVEL.   An index  providing a  range  of  poverty income  cutoffs
     adjusted by such factors as family size,  sex of family head, number
     of children under  18 years  of age, and farm or non-farm residence.

PREHISTORIC.   A  term  which describes  the period of  human development
     that occurred before the advent of written  records.  More generally,
     any period in geologic time before written history.

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PRESENT WORTH.   The sum of money that must be set aside at the beginning
     of the planning  period  in order to amortize the costs of a project
     over the planning period.

PRESSURE SEWER  SYSTEM.   A wastewater collection system  in which house-
     hold  wastes  are collected  in  the  building  drain  and  conveyed
     therein to the  pretreatment  and/or pressurization  facility.   The
     system  consists  of  two  major elements,  the  on-site  or  pressuri-
     zation facility, and  the primary conductor pressurized sewer main.

PRIMARY PRODUCTION.   Growth of green plants resulting from solar energy
     being fixed as sugar during photosynthesis.

PRIMARY  TREATMENT.    The  first stage in  wastewater treatment  in which
     substantially  all  floating or  settleable solids  are mechanically
     removed by screening and sedimentation.

RAPID INFILTRATION.  A form of land treatment where wastewater is placed
     into spreading basins and applied  to the  land  to undergo percola-
     tion into the soil.

RARE SPECIES.   A species  not Endangered or Threatened but uncommon and
     deserving of further study and monitoring.  Peripheral species, not
     listed as  threatened, may be  included in  this  category  along with
     those  species  that  were  once "threatened" or "endangered" but now
     have increasing  or protected,  stable populations.

RECHARGE.  The process by which water is added to an aquifer.   Used also
     to indicate  the  water that is added.  Natural recharge occurs when
     water from rainfall or a stream enters the ground and percolates to
     the water table.  Artificial recharge by spreading water on absorp-
     tive ground  over an aquifer or by injecting water through wells is
     used to store  water  and  to protect  groundwater  against  the intru-
     sion of sea water.

ROTATING BIOLOGICAL  CONTACTOR  (RBC).   A device,  consisting  of plastic
     disks that  rotate alternately through wastewater and air, used for
     secondary treatment of wastewater.

ROUGH FISH.  Those fish species considered to be of low sport value when
     taken  on   tackle,  or of poor eating  quality,  e.g.  gar,  suckers.
     Rough  fish  are  more  tolerant  of  widely changing environmental
     conditions than  are game fish.  Also called coarse fish.

RUNOFF.  The portion  of  rainfall,  melted snow  or  irrigation  water that
     flows  across  the  ground surface  and eventually  is returned  to
     streams.   Runoff can pick  up pollutants from the  air or the land
     and carry them to the receiving waters.

SANITARY SEWERS.  Sewers that transport only sanitary wastewater.  Storm
     water runoff is  carried in a separate system.   See sewer.

SANITARY SURVEY.  A method used to determine possible sources  of water
     quality  and  public   health  problems  and  to  locate inadequately


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     functioning  wastewater  systems  by making  site-specific  investi-
     gations of existing lots and systems.

SCENIC EASEMENT.   A  partial transfer  of  land  rights  to preserve  the
     aesthetic attractiveness of the land by restricting activities such
     as the  removal  of  trees,  placement of billboards,  or  development
     incompatible with the scenic qualities  of  the land.  Just compensa-
     tion is given to  owners for rights lost.   The right of  legal tres-
     pass is generally not included as part  of  this easement.

SECCHI DISK.  A round plate,  30 cm (1 foot)  in  diameter, that is used to
     measure the  transparency  of  water.  The  disk is  lowered  into  the
     water until  it  no  longer  can be seen  from  the surface.   The depth
     at which  the disk  becomes  invisible is a measure  of transparency.

SECONDARY TREATMENT.   Wastewater treatment in which bacteria  consume the
     organic parts  of  the  wastes.  This biochemical  action is  accom-
     plished by  use  of  trickling  filters  or the  activated  sludge pro-
     cess.  Effective  secondary treatment may remove approximately  90%
     of both BOD,, and suspended solids.

SEEPAGE CELLS.  Unlined  wastewater lagoons  designed so  that  all or part
     of wastewater percolates into the underlying soil.

SEPTIC SNOOPER.  Trademark for the ENDECO (Environmental Devices Corpor-
     ation) Type  2100 Septic Leachate  Detector.   This  instrument con-
     sists  of  an underwater probe,  a water intake system,  an  analyzer
     control  unit and   a  graphic  recorder.   Water  drawn through  the
     instrument is  continuously analyzed for  specific  fluorescence  and
     conductivity.   When  calibrated  against   typical   effluents,  the
     instrument  can   detect  and  profile effluent-like  substances  and
     thereby locate  septic  tank  leachate  or other sources  of  domestic
     sewage entering lakes and streams.

SEPTIC TANK.   An underground  tank used for the  collection  of  domestic
     wastes.   Bacteria  in the  wastes decompose  the organic  matter,  and
     the  sludge  settles to  the  bottom.   The  effluent  flows  through
     drains into the ground.   Sludge is pumped  out at regular intervals.

SEPTIC  TANK EFFLUENT  PUMP  (STEP).   Pump designed to  transfer settled
     wastewater from a septic tank to a sewer.

SEPTIC TANK SOIL  ABSORPTION  SYSTEM.  A system of wastewater disposal in
     which  large  solids  are  retained in a tank; fine solids  and liquids
     are  dispersed   into  the surrounding  soil  by a  system of  pipes.

SEWER, COMBINED.  A  sewer,  or system of sewers, that is used to collect
     and  conduct  both sanitary  sewage  and  storm-water runoff.  During
     rainless  periods,  most or  all of  the  flow  in a combined  sewer is
     composed  of  sanitary sewage.   During a storm, runoff increases the
     rate of  flow and may overload  the  sewage  treatment plant to which
     the  sewer connects.  At such times, it is common to divert some of
     the  flow, without treatment,  into the receiving water.
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SEWER, INTERCEPTOR.  See Interceptor Sewer.

SEWER, LATERAL.  A sewer designed and installed to collect sewage from a
     limited number of  individual  properties  and conduct it to  a  trunk
     sewer.  Also known as a street sewer or collecting sewer.

SEWER, SANITARY.  See Sanitary Sewer.

SEWER, STORM.   A conduit that collects and transports  storm-water run-
     off.   In  many  sewerage systems,  storm  sewers  are separate from
     those carrying sanitary or industrial wastewater.

SEWER, TRUNK.  A sewer  designed and installed to  collect sewage from a
     number of lateral sewers and conduct it to an interceptor sewer or,
     in some cases, to a sewage treatment plant.

SHOALING.  The bottom effect that influences  the height of  waves moving
     from deep to shallow water.

SINKING  FUND.   A  fund  established by periodic  installments  to  provide
     for the retirement of the principal of term bonds.

SLOPE.  The incline of the surface of the land.  It is  usually expressed
     as  a  percent (%) of slope  that equals the number of  feet  of fall
     per 100 feet in horizontal distance.

SOIL  ASSOCIATION.   General  term  used  to  describe  taxonomic units  of
     soils, relative proportions, and pattern of occurrence.

SOIL  TEXTURAL  CLASS.   The classification of  soil  material  according  to
     the proportions  of sand,  silt,  and clay.   The principal textural
     classes  in soil,  in increasing  order of  the  amount  of silt and
     clay,  are  as follows:   sand, loamy sand,  sandy  loam,  loam,  silt
     loam,  sandy  clay  loam, clay loam,  silty  clay loam,  sandy  clay,
     silty  clay, and  clay.   These class names are modified to indicate
     the  size  of  the sand  fraction or the  presence  of gravel,  sandy
     loam, gravelly loam,  stony clay,  and cobbly  loam, and are  used on
     detailed  soil maps.   These  terms  apply  only  to individual soil
     horizons or to the surface layer of a soil type.

STATE EQUALIZED  VALUATION  (SEV).   A measure employed within  a State  to
     adjust actual assessed  valuation  upward  to approximate true market
     value.  Thus it is possible to relate debt burden to  the  full value
     of taxable property in each community within that State.

STRATIFICATION.  The  condition  of  a lake, ocean, or other body of water
     when  the  water  column  is  divided into  a relatively cold bottom
     layer  and  a  relatively  warm surface  layer,  with a thin boundary
     layer  (thermocline) between  them.   Stratification generally occurs
     during the  summer and  during periods  of ice cover  in the  winter.
     Overturns,  of periods of  mixing,  occur  in  the spring and  autumn.
     This condition is most common in middle latitudes  and is  related to
     weather conditions, basin morphology, and altitude.
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STUB FEE.  See Connection Fee.

SUCCESSION.   The  ecological process  by  which terrestrial and  aquatic
     environments age.

SUPPLEMENTAL  USAGE.    In  regard  to   functions  of  small waste  flow
     districts, those  which are not  required to  comply with EPA  Con-
     struction Grants  regulations  governing  individual,  on-site waste-
     water  systems.    May  be  necessary  to  achieve  administrative  or
     environmental objectives.

SUSPENDED  SOLIDS  (SS).  Small  solid  particles that  contribute  to  tur-
     bidity.   The examination  of  suspended  solids  and  the  BOD  test
     constitute the two  main determinations for water quality  performed
     at wastewater treatment facilities.

TERTIARTY TREATMENT.   See Advanced Waste  Treatment.

THREATENED  SPECIES  (FEDERAL CLASSIFICATION).  Any species of  animal  or
     plant  that  is  likely  to  become  an  endangered species within  the
     foreseeable  future  throughout all   or  a  significant  part  of  its
     range.  Protected under Public Law 93-205, as amended.

TILL.   Deposits  of  glacial drift  laid   down in  place  as the  glacier
     melts.   These deposits  are neither  sorted nor stratified  and  con-
     sist  of  a heterogeneous mass  of  rock flow, sand, pebbles,  cobbles,
     and boulders.

TOPOGRAPHY.   The  configuration  of  a surface  area  including its  relief,
     or  relative  evaluations, and  the  position of its natural  and  man-
     made features.

TRICKLING FILTER PROCESS.  A method of secondary wastewater treatment in
     which  the biological  growth  is  attached to  a fixed medium,  over
     which  wastewater  is sprayed.  The  filter organisms  biochemically
     oxidize  the  complex  organic  matter  in  the  wastewater to carbon
     dioxide, water,  and energy.

TROPHIC  LEVEL.  Any  of the  feeding levels  through which the  passage of
     energy  through  an ecosystem  proceeds.   In simplest  form,  trophic
     levels   are:   primary   producers   (green   plants)   herbivores,
     omnivores, predators,  scavengers,  and decomposers.

WATER QUALITY.  The relative condition of a body of water as judged by a
     comparison between  contemporary  values  and  certain more  or  less
     objective standard values  for biological, chemical,  and/or physical
     parameters.   The  standard  values usually are based  on a  specific
     series  of  intended  uses,   and may vary  as the intended uses vary.

WATER TABLE.  The upper  level  of groundwater that is  not confined by an
     upper  impermeable layer  and is  under  atmospheric  pressure.   The
     upper  surface   of  the  substrate  that  is  wholly   saturated  with
     groundwater.

WATERSHED.  The area drained by a stream.

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WELL LOG.   A chronological  record  of the soil and  rock  formations  en-
     countered  in  the operation  of sinking a  well, with either  their
     thickness or the  elevation  of  the top and bottom of  each formation
     given.   It  also usually  includes  statements about  the  lithologic
     composition and water-bearing  characteristics  of each  formation,
     static and pumping water levels, and well yield.

ZONING.  The regulation by governmental action (invested by the State to
     cities, townships, or  counties)  of the use of the land,  the height
     of buildings,  and/or the proportion of the land surface that can be
     covered by structures.
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                        DOCUMENTS CITED IN THIS REPORT

Arthur Beard Engineers, Inc.  1978.   Correspondence regarding:  1) unit prices
     and collector sewer construction costs;  2) wastewater flow projections
     for Crystal Lake; and 3) "typical" cluster system, Crystal Lake.  Chevy
     Chase, MD.


Bailey, J.R., R.J. Benoit, J.L. Dodson, J.M.  Robb, and H. Wallman.  1969.  A
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Calver, J.L.  1947.  The glacial and post-glacial history of the Platte and
     Crystal Lake depressions, Benzie County, Michigan.  Michigan Geological
     Survey Publication 45.  Ph.D. thesis, 1942, Department of Geology,
     University of Michigan, Ann Arbor, MI.

Clean Water Act of 1977.  Public Law 95-217.    (33 U.S.C. 466 et seq.)

Cohen, S., and H. Wallman.  1974.  Demonstration of waste flow reduction from
     households.  Environmental Protection Agency, National Environmental
     Research Center, Cincinnati, OH.

Cooper, I.A., and J.W. Rezek.  1977.  Septage  treatment and disposal.  For
     EPA, Technology Transfer.

Crawford, W.A.  1977.  Findings in the proposed Crystal Lake sewer project
     area.  Contract No. C-262844-01.  Grand Traverse-Leelanau-Benzie District
     Health Department, Traverse City, MI.


Dearth, K.H.  1977.  Current costs of conventional approaches.  Presented at
     EPA National Conference on Less Costly Wastewater Treatment Systems for
     Small Communities, 12-14 April 1977, Reston, VA.


Environmental Photographic Interpretation Center (EPIC).  1978.  Crystal Lake
     septic tank system analysis.  EPA, Environmental Monitoring and Support
     Laboratory, Cincinnati, OH.

EPA (United States Environmental Protection Agency).  1975.  Cost-effective
     comparison of land application and advanced wastewater treatment.
     EPA-430/9-75-016.

EPA.  1975.  Report on Betsie Lake,  Benzie County, Michigan.  National
     Eutrophication Survey, Working Paper No.  185.

EPA.  1977.  National interim primary drinking water regulations of the Safe
     Drinking Water Act.  40 CRF 141.

EPA.  1977.  Process design manual for land treatment of municipal wastewater.
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                                     209

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EPA.  1978.  Construction grants program requirements memorandum 78-9.
     3 March 1978.

EPA.  1978.  Grants for construction of treatment works - Clean Water Act
     (40 CFR 35 Part E):   Rules and regulations.   43 FR 44022,  27  September
     1978.

EPA.  1978.  Construction grants program requirements memorandum 79-3.  15
     November 1978.
Federal Water Pollution Control Act Amendments of 1972, Public Law 92-500.


Gannon, J.J., et al.  1970.  Crystal Lake water quality investigation.
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     Michigan, Ann Arbor, MI.


Huffman, G.C.  1977.  Groundwater data for Michigan, 1976.  USGS, in
     cooperation with Michigan DNR.


Illinois Environmental Protection Agency.  1977.   Issuance of final Illinois
     guidelines for the preparation of facilities plans for unsewered
     communities.  Memorandum, 16 September 1977.


Jones, R.A., and G.F. Lee.  1977.  Septic tank disposal systems as phosphorus
     sources for surface waters.  EPA-600/3-77-129.   Robert S. Kerr Environmental
     Research Laboratory.


Kerfoot, W.  1978.  Investigation of septic leachate discharges into Crystal
     Lake, Michigan.  K-V Associates, Inc., Falmouth, MA.

Knutilla, R.L.  1974.  Compilation of miscellaneous streamflow measurements
     in Michigan through September 1970.  Water Information Series Report No. 5.
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League of Women Voters.  1978.  A background summary of the planning process
     and major issues identified by the League of Women Voters of the Grand
     Traverse Area for the Sleeping Bear Dunes National Lakeshore.  Traverse
     City, MI., 4 p.

Leverett, F., et al.  1907.  Flowing wells and municipal water supplies in the
     middle and northern portions of the southern peninsula of Michigan.  Water
     Supply and Irrigation Paper No. 183; Series 0, Underground Waters, 63.
     USGS, Washington, DC.

Livasy, L.L.  No date.  Documentation for the Crystal Lake area authority for
     treatment works—construction grant application.  Grand Traverse-Leelanau-
     Benzie District Health Department, Traverse City, MI.


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Martin, H.M.  1957.  Outline of the geologic history of the Grand Traverse
     region.  Michigan Geological Survey (brochure), 9 p.

McLaughlin, E.R.  1968.  A recycle system for conservation of water in
     residences.  Water and Sewage Works 115(4):175-176.

Michigan DNR (Department of National Resources).   1973.  National river
     report:  Betsie River, Benzie and Manistee Counties.  Office of
     Planning Services, 10 August 1973 revision.

Michigan DNR.  1977.  Betsie River natural river zoning.  Division of Land
     Resource Programs.

Michigan DNR.  1978.  Michigan's endangered and threatened species program:
     1976-1978.

Michigan DNR.  Variously dated.  Lake and stream management records and
     biological data:  Crystal Lake (unpublished reports).

Michigan DNR.  Variously dated.  Lake and stream management records and
     biological data:  Betsie Lake (unpublished reports).

Michigan DNR.  Variously dated.  Lake and stream management records and
     biological data:  Long Lake (unpublished reports).


National Park Service, Sleeping Bear Dunes National Lakeshore.  1978.  Citizens
     voice concerns and hopes about future of National Lakeshore.  Department
     of the Interior, Frankfort, MI., 14 p.


Omernik, J.M.  1977.  Non-point source stream nutrient level relationships:
     A nationwide survey.  EPA-600/3-77-105.  National Environmental Research
     Laboratory, Corvalis, OR.

Otis, R.J., and D.E. Steward.  1976.   Alternative wastewater facilities for
     small unsewered communities in rural America.  Annual report to the
     Upper Great Lakes Region Commission.


Scalf, M.R., and W.J. Dunlap.  1977.   Environmental effects of septic tanks.
     EPA-600/3-77-096.  Robert S. Kerr Environmental Research Laboratory,
     Ada, OK.

Schroepfer, G.J., and R.C. Polta.  1967.  Travel of nitrogen compounds in
     soils.  Sanitary Engineering Report 166-5.  Sanitary Engineering
     Division, Department of Civil Engineering, University of Minnesota,
     in cooperation with US Public Health Service.

SCS (Soil Conservation Service).  1972.  Land resource inventory map,
     Benzie County, Michigan.  US Department of Agriculture, National
     Cooperative Soil Survey, in cooperation with Michigan Agricultural
     Experiment Station.
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SCS.  1977.  Proposed rule, Prime and unique farmlands:   Important farmland
     inventory.  42 FR 42359, 23 August 1977.

SCS.  1978.  Benzie County soil conservation district map.

Siegrist, R., M. Witt, and W.C. Boyle.  1976.   Characteristics of rural
     household wastewater.  Journal of the Environmental Engineering Division,
     American Society of Civil Engineers,  No.  EES,  Proceedings Paper 12200:
     533-548.
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     (revised).  For the Crystal Lake Property Owners Association.   Ann
     Arbor, MI.

The White House Rural Development Initiatives.  August 1978.   Making water
     and sewer programs work.

Troyan, J.J., and D.P. Norris.   March 1977.  Cost-effectiveness analysis of
     alternatives for small wastewater treatment systems.  For the
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     Design Seminar on Small Wastewater Treatment Systems, Seattle, WA.
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     County, Michigan:  An on-site survey.   Pelston, MI.

Upper Great Lakes Commission.  1972.  Environmental implications of
     recreation associated development of private land surrounding federal
     recreation areas in the Upper Great Lakes Area - Michigan.  59 p. and
     6 maps.

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     Commerce, Census of Population and Housing, Washington, DC.

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     Department of Commerce, Washington, DC.

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     Interior.
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West Michigan Tourist Association.  1978.  West Michigan carefree days.
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                                                         6USGPO: 1980 — 654-261 — Vol. I
                                     213

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