905R80104
vvEPA
United States
Environmental Protection
Agency
Region V
230 South Dearborn
Chicago, Illinois 60604
November 1980
Water Division
Environmental
Impact Statement
Final
Alternative Waste
Treatment Systems
For Rural Lake Projects
Case Study Number 5
Ottertail County Board
Of Commissioners
Ottertail County,
Minnesota
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EPA-5-JIN-OTTER TAIL-OTTER TAIL-LA-80
FINAL ENVIRONMENTAL IMPACT STATEMENT
ALTERNATIVE WASTEWATER TREATMENT SYSTEMS FOR RURAL LAKE PROJECTS
CASE STUDY NO. 5: OTTER TAIL COUNTY BOARD OF COMMISSIONERS,
OTTER TAIL COUNTY, MINNESOTA
Prepared by the
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V, CHICAGO ILLINOIS
and
WAPORA, INCORPORATED
WASHINGTON, D.C.
Approved by:
John McGuire
Regional Administrator
November 1980
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LIST OF PREPARERS
This Final Environmental Impact Statement was prepared
by WAPORA, Inc., under the guidance of Alfred Krause, EPA
Region V Project Officer. Mr. Edward Wandelt was WAPORA's
Project Manager. Invaluable assistance was provided by
Gerald Peters, Ross Pilling, and Henri Bartholomot.
Significant input to the Draft EIS was provided by
numerous subcontractors; they are listed in that document.
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EXECUTIVE SUMMARY
Background
The 1979 Draft Environmental Impact Statement (DEIS) on Alternative
Wastewater Treatment for Rural Lake Projects, Otter Tail County, Minnesota,
addressed issues raised during the review of the 1976 Facility Plan. The
issues included the high cost of centralized collection and treatment (1980
Construction Costs of $10.1 million); uncertain water quality improvements to
Otter Tail Lake as a result of the project; economic effects on area resi-
dents; and the potential for induced growth and associated secondary impacts.
The Facility Plan, which was prepared by Ulteig Engineers, proposed the
construction of a regional wastewater collection system and a centralized
treatment facility. On-site wastewater treatment systems, which currently are
in use in the Study Area, would be abandoned. Gravity sewers, utilizing
grinder pumps and low pressure sewers in some low-lying areas, would convey
wastewater to a site about 0.3 mile west of Otter Tail Lake in Amor Township.
The wastewater would be treated in stabilization ponds, chlorinated, and
subsequently applied to the land via spray irrgation. The secondary effluent
most likely would be utilized for controlled farm operations with either row
crops and/or forage crops.
To assess the appropriateness and the environmental consequences of the
proposed plan, EPA conducted a variety of tests. These included an aerial
photographic survey of surface malfunctions; two septic leachate surveys of
the potentially affected lakes (Otter Tail Lake, Lake Blanche, Walker Lake,
Round Lake, and Long Lake); a groundwater survey; a partial sanitary survey;
and detailed soil, groundwater, and aquatic plant analyses of selected waste-
water treatment systems in shoreline areas. Data from the second leachate
survey, sanitary survey, and the site-specific analyses, however, were not
available in time to be used in the preparation of the DEIS.
These studies found that only a few on-site treatment systems were having
any impact on water quality even though many did not comply with the Otter
Tail County Shoreland Management Ordinance. Water quality modeling indicated
that none of the EIS or Facility Plan alternatives would have a significant
effect on lake water quality or trophic status.
A wide range of alternatives were developed and evaluated during the EIS
process. These ranged from highly centralized (the Facility Plan Alternative
and some variants) to largely decentralized (Limited Action and No Action).
Composite alternatives were developed with varying mixtures of on-site system
maintenance and upgrading, partial sewering, and cluster treatment systems for
the shoreline buildings adjacent to the Study Area's five lakes. Total pre-
sent worth costs varied greatly from $10.4 million for the Facility Plan
Alternative, to $7.2 million for the DEIS Limited Action Alternative. The
impacts of the alternatives differed greatly only for overall and local costs.
The DEIS recommended the Limited Action Alternative, which would result
in generally comparable water quality impacts at a much lower cost than any
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other alternative. The Limited Action Alternative would include decentralized
systems for all parts of the Proposed Service Area and would include a program
of replacement and rehabilitation of on-lot systems, where necessary, to
alleviate existing water quality and public health problems. Utilization of
on-site facilities throughout the Study Area would constrain future population
growth below the level anticipated with the provision of centralized waste-
water treatment. Under the Limited Action Alternative, the in-summer popula-
tion growth would be limited to 44% in excess of the 1976 level (from 1976
population of 5,250 to year 2000 population of 7,555). This level of popula-
tion growth would necessitate the conversion between 400 to 500 acres of
undeveloped land to residential land use. Residential densities throughout
the Service Area are anticipated to remain relatively low (1 to 2 dwellings
per acre) and uniform. The densities in the Service Area would be determined
largely by the lot size requirements specified in the Shoreland Management
Ordinance.
Comments
After the November 1979 publication of the DEIS, a Public Hearing was
held on 5 January 1980 in Battle Lake, Minnesota. Numerous people attended,
and a variety of comments were received, many of them in writing. In general,
the comments were concerned with the following topics:
The need for site-specific information relating to alternatives
Clarification of the administrative elements of the DEIS Alternative
Concern about non-point pollutant sources and water quality impact
especially in view of the limited role of on-site treatment systems
Documentation of the need to upgrade or replace on-site systems
Clarification of secondary impacts from the proposed actions.
Responses
After the close of the comment period EPA scrutinized the results of the
field studies conducted during the summer of 1979. These studies included a
groundwater hydrology survey, a second septic leachate survey, and detailed
soils, groundwater, aquatic plant analyses of six on-site sewage treatment
systems in lakeshore areas and a sanitary survey. The results of prior work
were confirmed and the body of knowledge on the effects of on-site systems was
increased.
EPA also clarified Federal, state, and local administrative questions
about the formation of a Small Waste Flows District. New features of a
District to manage on-site treatment systems include:
A regional standard for project needs documentation requirements
(see Appendix A)
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Methods to reduce the cost and complexity of detailed site work and to
expedite processing of innovative and alternative grant applications
A variety of approaches to simplify easement and access requirements.
(This process, which is still ongoing, could altogether eliminate the
expense and complexity of easement acquisition (see Appendix A).)
Finally, EPA described and costed the No-Action Alternative in greater
detail than provided in the DEIS and re-examined the Limited Action Alterna-
tive. Costs of the Limited Action Alternative were modified to reflect more
detailed work plans for the site-by-site engineering and environmental analy-
sis and for long-term operation and maintenance. These costs were estimated
on a conservative basis. This effort led to the creation of the FEIS
"Modified Limited Action Alternative."
The Final EIS
This FEIS is considerably shorter than the DEIS. Elements that were
discussed at length in the DEIS are summarized, with emphases on responses to
comments and explanations of management procedures and costs. This approach
is consistent with the Council on Environmental Quality's 1978 National
Environmental Policy Act (NEPA) regulations that became effective after the
DEIS was completed.
Recommendations
The various administrative changes, field surveys and responses to public
comments have not changed basic assumptions or information published in the
DEIS. Based on the 1979 summer field study results, however, the Modified
Limited Action Alternative is the recommended action. It differs from the
Limited Action Alternative in the DEIS in several respects, including:
Greywater/blackwater separation will be omitted except for replacing
holding tanks and for individual dwellings where separation will
provide some benefits
All cesspools will be replaced with new on-site systems. The type of
replacement will depend on soil depth above groundwater: dosed mounds
for depths from 0 to 2 feet, dosed shallow placement drainfields or
beds for depths from 2 to 4 feet; gravity fed shallow replacement
drainfields, or beds from depths of 4 to 6 feet, and conventional
drainfields for depths greater of more than 6 feet.
Holding tanks will be converted to receive only waste from very low
flow toilets; other wastewaters from houses with holding tanks will
be discharged to new septic tank/soil absorption systems. Design
of the soil absorption systems will be based on depth to groundwater
as described above for cesspool replacements. It is recognized that
some holding tanks will have to be retained for environmental or
economic reasons
Replacement of all defective or undersized septic tanks
Dosed mound systems will replace soil absorption systems that have
insufficient hydraulic capacity because of high groundwater
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Half of the resort units will be served by low pressure sewers and
off-site, multi-family filter fields (cluster systems).
The Applicant, the Otter Tail County Board of Commissioners, will
provide information on use, cost, and benefit of flow reduction de-
vices to residents, and owners of businesses:
- in Segments 1, 2, 11, 13, 21 through 25, 28 through 31, and 34; and
- in other locations with high groundwater, or
- whose systems will be upgraded with Federal funds
All existing on-site systems will be modified for easy access and
pumping if they currently do not have these features.
The present worth of the Modified Limited Action Alternative is estimated
to be $4,763,100. This compares to $7,152,2000 for the Limited Action Alter-
native described in the DEIS and $10,358,600 for the Facility Plan Proposed
Action.
In other respects, particularly the requirements for house-by-house site
analysis and community supervison of on-site systems, the Modified Limited
Action Alternative represents the same concept as the DEIS's Limited Action
Alternative. That is, maximum use of existing on-site systems with upgrading
and repairs as necessitated by system performance plus continuing community
supervision of all wastewater facilities.
The various elements of this approach have been developed and costed on a
segment by segment basis from site-specific information for 30% of all systems
(see Appendix B and D) . This is consistent with the new EPA needs documenta-
tion guidance (see Appendix A). Final details will not be known until 1)
house-by-house inspection (probably during Step 3) confirms or changes the
selection of treatment methods for each house and 2) the Applicant and com-
munity decide on the method and degree of management to be provided.
Should the Otter Tail County Board of Commissioners wish to proceed with
this action, EPA recommends that careful consideration be given to the sec-
tions of the FEIS on Management and Implementaion, (Section II.B.2 and II.B.3)
which discuss the nature and advantages of many of the available choices. In
addition, the Otter Tail County Board of Commissioners should inititate the
management structure that will operate in the future so that citizens and
local officials can take part in the site-by-site design treatment choices.
This will allow all concerned individuals to become familiar with the proce-
dures that will be needed to maintain and improve water quality in the Otter
Tail Lake area.
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TABLE OF CONTENTS
Page
List of Preparers i
Executive Summary ill
List of Tables ix
List of Figures ix
I - PURPOSE OF AND NEED FOR ACTION
A. The Applicant's Facility Plan and Environmental Impact
Statement Issues 1
1. Water Quality 1
2. Cost Effectiveness 1
3. Economic Impacts 1
4. Induced Growth and Secondary Impacts 3
B. The Need for Improved Wastewater Management - Otter
Tail Lake 3
II - ALTERNATIVES
A. The Facility Plan Proposed Action 15
B. The EIS Recommendation - Modified Limited Action 17
1. Technology Selection 18
2. Community Management 22
3. Implementation 25
C. The No-Action Alternative 27
D. Other Alternatives 28
III - AFFECTED ENVIRONMENT AND IMPACTS OF NO-ACTION
A. Soils 31
B. Surface Water Resources 31
C. Groundwater Resources 31
D. Population and Land Use 32
E. Environmentally Sensitive Area 35
F. Economics 35
VII
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IV - ENVIRONMENTAL CONSEQUENCES OF THE ACTION ALTERNATIVE
A. Surface Water Resources 37
B. Groundwater 38
C. Population and Land Use 38
D. Economic Impacts 39
V - PUBLIC AND AGENCY COMMENTS
APPENDIXES:
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
INDEX
EPA Region V Guidance Site Specific Needs
Determination and Alternative Planning for
Unsewered Areas
Modified Limited Action Site Analysis and
Costs
No-Action Alternative Present Worth Analysis -
Otter Tail Lakes Project
Modified Limited Action Present Worth and User
Charger - Otter Tail Lakes Project Area
Septic Leachate and Groundwater Flow Survey -
Otter Tail Lakes, Minnesota, September 1979
Letters and Written Comments
EPA Memo on Access and Control for On-Site
System Upgrading
Otter Tail Lake Sanitary Survey - Otter
Tail County, Minnesota, July 3, 1980
viii
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LIST OF TABLES
Page
Table 1 Wells Around Otter Tail Lake with Evidence
of Contamination 9
Table 2 Upgrading and Repairs of Existing On-Site
Systems - Modified Limited Action 19
Table 3 Population and Dwelling Unit Equivalents for
the Total, Permanent, and Seasonal Population
of the Proposed Otter Tail Lake Service Area,
1976 and 2000 34
Table 4 Financial Burden and Displacement Pressure 39
LIST OF FIGURES
Figure 1 Proposed Sewer Service Area, Otter Tail Study
Area 2
Figure 2 Location of Erupting and Stream Source Plumes 5
Figure 3 Locations of Surface Water Samples Obtained
for Bacterial Analysis 6
Figure 4 Groundwater Flow Patterns Surrounding Otter
Tail Lake 7
Figure 5 Locations of Plume Discharges Observed During
September 1979 Survey of Otter Tail Lake 10
Figure 6 Rate and Direction of Groundwater Flow Measured
Along the Shoreline During September 1979 12
Figure 7 Facility Plan Proposed Action 16
Figure 8 Distribution of Lot Sizes and Percentage of
Lots with High Groundwater Levels (Less Than
Six Feet to Groundwater) 33
IX
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CHAPTER I
PURPOSE OF AND NEED FOR ACTION
A. THE APPLICANT'S FACILITY PLAN AND ENVIRONMENTAL IMPACT STATE-
MENT ISSUES
In July, 1976, Ulteig Engineers completed the Facility Plan for the Otter
Tail Lake Area, Otter Tail County, Minnesota. The Plan evaluated alternative
wastewater collection and treatment strategies for the area, and proposed
construction of new wastewater collection and land treatment facilities. The
proposal was submitted to the US Environmental Protection Agency (EPA) Region
V by the Otter Tail County Board of Commissioners (hereafter referred to as
the Applicant), for funding under the EPA Construction Grants Program.
The major issues examined in this EIS are closely related to the proposal
to build sewers around Otter Tail Lake and segments of nearby lakes. Figure 1
shows the service area addressed in this EIS. The issues examined are:
1. WATER QUALITY
The probable water quality impacts of the Facility Plan Proposed Action
and alternatives were not satisfactorily addressed in the Plan. Of principal
concern to the Applicant were further eutrophication and bacterial contamina-
tion of Otter Tail Lake and impacts on groundwater quality. Although the
Facility Plan presented indirect evidence that there may be water quality
problems, claims of a connection between deteriorating water quality and
inadequately functioning septic systems have not been documented. In addi-
tion, claims of possible hazards to public health were not fully sub-
stantiated. Therefore, it is not yet clear that the proposed level of
resource commitment proposed in the Plan would be necessary.
2. COST-EFFECTIVENESS
The collection system proposed in the Facility Plan Proposed Action is
estimated to cost $8.6 million or 83% of the total capital cost. Since the
Minnesota Pollution Control Administration (MPCA) does not normally assign
high grant funding priorities to collector sewers, the cost of the collection
system can affect the local community more than other project components. The
high cost of sewers provided the incentive to consider alternatives to cen-
tralized collection and treatment.
3. ECONOMIC IMPACT
The estimated user charge for the Facility Plan Proposed Action was $350
per year for each residence or residential equivalent in the new sewer service
area around Otter Tail Lake. This charge would amount to 1.4% of the per-
manent residents' average annual income. Otter Tail Lake Proposed Sewer
Service Area homeowners would pay an initial $970 for stub fee and connection
charge to a gravity sewer. In addition, the homeowner would pay for installa-
tion of a house sewer connecting his household plumbing with the public sewer.
The effect of these sewage costs could be to encourage seasonal and fixed
income residents to sell their properties or, in some instances, to convert
from seasonal use to permanent residency.
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FIGURE 1
PROPOSED SEWER SERVICE AREA, OTTER TAIL STUDY AREA
LEGEND
1 PROPOSED SEWER SERVICE AREA
MILES
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4. INDUCED GROWTH AND SECONDARY IMPACTS
Shoreline sewer availability could allow construction of dwelling units
at slightly higher densities than is currently feasible. However, most of the
shoreline is already developable without provisions for centralized treatment.
Undeveloped lots along the shoreline indicate that there is some potential for
increased development.
B. THE NEED FOR IMPROVED WASTEWATER MANAGEMENT - OTTER TAIL LAKE
The Facility Plan identified the following problems associated with the
existing on-site systems in the Otter Tail area:
Highly permeable sandy soil, small lot sizes, and a seasonally high
water table may allow inadequately treated wastewater to reach surface
water and groundwater
At least three times in the past, total coliform concentrations at the
outlet from Otter Tail Lake have been too numerous to count. Monthly
coliform counts at this location indicated a jump from zero colonies
per 100 ml in the winter to a summer high of 400 to 500 colonies per
100 ml.
High nitrate concentrations have been found locally in the ground-
water
Many septic tanks and their drainfields are totally submerged in
groundwater
Many older on-site systems violate the Otter Tail County Shoreland
Management Ordinance for elevation above groundwater, or setback from
lakes or absorption areas.
Several studies were conducted during the preparation of the Draft EIS to
evaluate in greater detail the water quality and public health problems
related to use of on-site systems around Otter Tail Lake. These studies and
their major conclusions are:
Studies Reported in the Draft EIS
Eutrophication Modeling - On-site sewage disposal systems contribute
an estimated 3.5% of the phosphorous load to Otter Tail Lake, 32% of
the load to Round Lake, 0.2% of the load to Deer Lake, 1.2% of the
load to Long Lake, 0.4% of the load to Walker Lake, and 0.4% of the
load to Lake Blanche. Removal of this source would result in neg-
ligible change in the lake's trophic status.
Aerial Photographic Survey - EPA's Environmental Photographic Inter-
pretation Center (EPIC) conducted an aerial photographic survey to
determine the location of surface malfunctions within the Study Area.
Only three surface malfunctions were detected within the Proposed
Service Areas during the survey that were later confirmed by on-site
investigation.
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Septic Leachate Study - An investigation of septic leachate discharges
around Otter Tail Lake and its satellite lakes took place from March
through April 1979 to determine whether groundwater plumes from nearby
septic tanks were emerging along the lakeshore.
An instrument referred to as the "Septic Snooper" detected septic
leachate plumes. This instrument is equipped with analyzers to detect
both organics and inorganics from domestic wastewater. This device
was towed along the lakes, and holes were drilled in ice-covered areas
to obtain a profile of septic leachate plumes discharging to surface
waters.
The winter survey found in areas along the southwest and northeast
shore that there was nearly a one to one relationship between the
location of groundwater plumes and the number of permanent residences.
Areas with high numbers of plumes in Otter Tail Lake were found adja-
cent to Lake Blanche, Walker Lake and Long Lake and at the inflow of
Otter Tail River. The location of plumes and bacterial sampling
points are shown in Figures 2 and 3, respectively.
Near-Shore Hydrology Study - At intervals of about one-half mile along
the shorelines of Otter Tail Lake and its satellite lakes, groundwater
flows were measured with a meter that generates a heat pulse, then
measures the pattern of heat dispersion. Soil was excavated to the
water table at three points for each location; the probe was inserted
just below the water level and oriented with a compass fixed on the
body of the probe. Recordings from the three points were averaged to
describe the rate and direction of flow at each location. The results
are illustrated in Figure 4.
The study indicated that Otter Tail Lake acts like a large withdrawal
well, and that groundwaters flow toward Otter Tail Lake along all but the
western shoreline. Flow is particularly rapid along those lakeshore areas
adjacent to Long Lake, Walker Lake, and Lake Blanche. These lakes seek their
own level by gravity and discharge the underflow into Otter Tail Lake.
It is clear from the groundwater hydrology study that the direction of
groundwater flow determines the emergence of effluent plumes into lakes. It
is also highly likely that rate of flow, along with other factors such as
distance from sewage disposal point to the shore and soil characteristics,
influences the strength of plumes and their effects on lakes.
After issuance of the Draft EIS, additional studies were concluded.
These studies and their major conclusions are:
Studies Completed After the Draft EIS
Sanitary Survey - EPA conducted an on-site sanitary survey of residences
and resorts around Otter Tail Lake from July through September 1979. The
survey provided information regarding the types of existing on-site sys-
tems, the nature and extent of noncompliance with the Otter Tail County
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FIGURE 4 GROUNDWATER FLOW PATTERNS SURROUNDING OTTER TAIL LAKE
LEGEND
GROUNDWATER FLOW DERECTIONS
(BASED ON DARCY'S EQUATION)
GROUNDWATER FLOW DIRECTIONS
MEASURED BY THE GROUNDWATER
FLOW METER
MILES
o
1325 APPROXIMATE GROUNDWATER ELEVATION
7
Source: Kerfoot 1979
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Shoreline Management Ordinance, and the nature and extent of problems with
these systems. The results indicate that 56% of the residences surveyed
did not meet the Otter County Shoreline Management Act sanitary design
provisions. Only 11% claimed malfunctioning septic systems. All malfunc-
tions cited were backups or sluggish flow in the buildings plumbing. Most
of the malfunctions noted during the survey process were related to high
groundwater levels around the lakeshore. A number were also caused by
excessive water use on weekends or holidays. The complete sanitary survey
is included in Appendix H.
Well Water Sampling - During the sanitary survey, 75 well water samples
were collected for analysis by the Fergus Falls Health Department to
ascertain groundwater quality. The water samples were analyzed for
coliform bacteria to determine if there was any direct evidence of sewage
contamination of water supplies. Fecal coliform bacteria are found in the
intestines of warm-blooded animals and are universally found in untreated
sewage. Presence of fecal coliform bacteria in wells is presumptive, but
not conclusive, evidence of contamination by sewage. Due to the high
number of very old and improperly protected wells, other parameters had
to be evaluated to determine if sewage was causing the problem or if con-
tamination was due to improper well construction and protection. Nitrate-
nitrogen was chosen as the accompanying parameter because of its close link
with sewage, its persistence as it travels through groundwater aquifers,
and its public health effects. High levels of nitrate-nitrogen in a pot-
able water supply can lead to methemoglobinemia ("blue-baby") in infants.
Of the 75 samples taken, 13 (17%) showed some signs of contamination. Of
the 13, four (5%) violated drinking water standards. More detailed infor-
mation on these 13 samples is shown in Table 1. Wells that had bacterial
colony counts of one or more or that had detectable nitrate-nitrogen levels
(1 ppm or greater) were considered to have some evidence of contamination.
Only one well had nitrate-nitrogen levels above 10 ppm, the national stand-
ard set for drinking water. The owner estimated the depth of the well to
be very shallow (between 15 and 20 feet).
Data for the wells with detectable contamination do not clearly indicate
that on-site sewage dispoal systems were the sources of the contamination.
Several of the wells that had evidence of contamination met the well-to-
septic tank and drainfield separation distances established in the Shore-
land Management Act. These wells were in almost all cases shallow and
driven. This points out that the wells themselves may not be constructed
properly or that they should be drilled to a greater depth.
Septic Leachate Study - A second investigation of septic leachate dis-
charges around Otter Tail Lake took place in September 1979. The pat-
terns of erupting plumes from on-lot septic systems were compared to those
of the winter survey. The summer 1979 survey indicated that, as during the
winter survey, the highest frequency of plumes occurred along shoreline
segments adjacent to satellite lakes - Blanche Lake, Long Lake, Walker
Lake, and Nylandyr Lake (see Figure 5). As during the winter conditions,
the highest frequency of plumes was found along shoreline segments where
infiltration rates averaged 8 to 10 feet per day. Contrary to expecta-
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tions, the higher frequency of plumes and greater phosphorus content of
affected surface waters occurred during winter rather than during the more
populated summer period. Chemical analyses of erupting groundwater plumes
and their associated surface water condition indicted lower phosphorus con-
tent and fewer reducing conditions (indicated by reduced ammonia-nitrogen
content) during summer sampling. The complete septic leachate study is
presented in Appendix E.
Near-Shore Hydrology Study - A second determination of nearshore ground-
water flow patterns was made during the summer of 1979 along the shore
of Otter Tail Lake. Flow was found to be into the lake on the south and
east shores and out of the lake on part of the north and most of the west
shorelines (see Figure 6). Flow rates averaged around 5 feet per day
(FPD), ranging from as high as 16 FPD and as low as 1 FPD. There appeared
to be a general southeast to northwest movement of water around the lake,
even though some measurement sites on the northern shores indicated flow
into the lake. This corresponds to the overall orientation of the Otter
Tail River drainage basin and flow from east to west.
A distinct change in pattern of flow direction was apparent when the summer
results were compared to winter measurements (KVA, 1979). Increased sum-
mer evapotranspiration had probably decreased the height of groundwater
elevations surrounding the lake relative to the lake height, thereby induc-
ing greater outflow. In addition, the lake level was higher than aver-
age. This was most striking along the northern shoreline of the western
lobe of the lake, where all flow measurements except in the shoreline seg-
ment adjacent to Nylandyr Lake indicated flow out the lake (exfiltration).
Aquatic Productivity Study - During August 1979, an aquatic productivity
study was conducted at Otter Tail Lake. Nutrient modeling reported in
the Draft EIS indicated that septic tank systems are not contributing
significantly to eutrophication of Study Area lakes. However, observa-
tions on similar midwestern lakes suggested that septic tank effluents
might stimulate localized plant growth at the points where it enters a
lake. To evaluate this relationship in Otter Tail Lake, six on-site sys-
tems were selected for detailed monitoring. The sites were selected for
their proximity to the lake (soil absorption systems were 50 to 185 feet
from shorelines), shallow depth to the water table (18 to 60 inches of un-
saturated soil), and dwelling age ( 8 or more years old). Samples were
collected of well water, septic tank contents, groundwater between the
effluent disposal field and lake, groundwater in the lake sediments, soils,
sediments, and plants in the lake near the shoreline. Soil, sediment, and
water samples were analyzed for nitrogen and phosphorus compounds and other
chemical parameters. Water samples were tested for fluorescence and con-
ductivity with the Septic Leachate Detector. Surface waters near the
shores were scanned at one-foot depth intervals with the Detector. The
direction and rate of groundwater flow was monitored along the shoreline of
each site.
The major conclusion drawn from these studies is that septic tank effluents
were not stimulating nearshore plant growth. Plants were found off-shore
at each site, but nowhere was their density or location indicative of the
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localized stimulation of aquatic productivity such as has been documented
in other lakes. Light to moderate growths of Chara, a complex green algae,
were found at all sites along with assorted rooted vascular plants (Najas,
Potamogeton, Sagittaria and Ceratophyllum). At all six sites there was a
clear pattern of zonation in which plant biomass increased with depth and
distance offshore. Environmental factors such as asexual propagation,
water depth, light intensity, wave characteristics, and sediment type
appear to be the factors controlling plant distribution. Effects of septic
tank effluents on plant distribution were not evident. This finding might
be explained by results of groundwater flow monitoring, which showed that
groundwater was not flowing directly toward the lake of any of the sites.
It is possible that persistent flow of groundwater toward the lake during
the growing season might result in effluent stimulation of plant growth.
Effects of effluent disposal on groundwater quality are localized to the
immediate vicinity of the soil absorption systems. Groundwater samples
taken at 1, 3, and 5-foot depths below the water table at the shorelines
and at the soil absorption systems showed the following ranges and averages
for total phosphorus, nitrates, and ammonia.
Soil Absorption System
I1 3' 5'
Total P (Range)
(Average)
Total N (Range)
(Average)
Ammonia-N (Range)
(Average)
Nitrate-N (Range)
(Average)
<.01-34.2
7.0
2.35-200.
44
.08-190
36.0
.02-9.7
5.0
.01-16.7 <.01-.22
3.0
.76-62.5
39.4
.92-60
32.4
<. 01-1. 25
.24
.05
3.2-95
20.3
.18-80
14.5
.05-2.15
.73
Shoreline
Total P (Range)
(Average)
Total N (Range)
(Average)
Ammonia-N (Range)
(Average)
Nitrate-N (Range)
(Average)
<.01- . 13
.06
.52-4.5
1.51
.30-1.9
.56
<. 01-1. 94
.34
<.01- . 17
.06
.52-3.2
1.24
.03-. 69
.22
<. 01-2. 08
.36
<.01-.06
.01
.51-2.04
1.1
<.04-.32
.15
<.01-.04
.02
Since the effluent plumes were not sampled at their cores (the densest
area of a plume, which generally tails off in the direction of preva-
lent groundwater flow), percent breakthrough of nutrients from these
dwellings into the lake cannot be calculated. However, the low nitro-
gen and phosphorus concentrations at shorelines supports a conclusion
based on similar data from other lakes: noticeable degradation of
13
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groundwater by on-site systems in homogeneous, saturated soils is
typically limited to the immediate vicinity of the soil absorption
system and the core of its effluent plume. It is also notable that
significant decrease in total nitrogen, 54%, and in total phosphorus,
99%, were found between the one foot and five-foot depths immediately
below the soil absorption systems. This is because the effluent plume
is travelling for the most part on the surface of the groundwater
column.
14
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CHAPTER II
ALTERNATIVES
A. THE FACILITY PLAN PROPOSED ACTION
The Facility Plan proposed treatment of all wastewater at a land applica-
tion site that would handle 0.56 million gallons per day (mgd). Regional
collection would be accomplished through a system of gravity sewers supple-
mented with pressure sewers utilizing grinder pumps in some low-lying areas.
Wastewater would be conveyed to a site about one-third mile west of Otter Tail
Lake in Amor Township.
To maintain comparability of alternatives for purposes of cost analysis,
the Facility Plan Proposed Action was slightly modified for consideration in
this EIS. The following changes were included:
The design flow of 65 gpcd used in the Facility Plan was reduced
to 60 gpcd, not including infiltration and inflow which was added
separately;
The population projections for the year 2000 presented in this EIS
are slightly more (0.9%) than the Facility Plan projections;
Total flows were adjusted to accommodate the change in population and
per capita flows;
The net effect of these changes is a reduction in the total flow by
12% from 0.56 mgd to 0.50 mgd; and
Grinder pumps were replaced with septic tank effluent pumps (STEP)
because of a slight cost advantage of the STEP system.
Costs developed in the Draft EIS for the Facility Plan Proposed Action
are:
1980 Construction Costs -
(including engineering, legal, and contingency costs) $10,146,500
Future Construction Costs - $39,000
Annual Operation and Maintenance Expense - $93,300
1980 Average Annual User Charge - $350/house
The 1980 Average Annual User Charge includes all operation and main-
tenance costs for the year, plus annual payment on the debt of privately as
well as publicly financed construction costs at an interest rate of 6-7/8% and
with a payback period of 30 years. Figure 7 is a map of the Proposed Action.
Appendix K-2 of the Draft EIS lists major components of the Alternative, and
the detailed cost of these components.
15
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B. THE EIS RECOMMENDATION - MODIFIED LIMITED ACTION
As described in the Draft EIS, the Limited Action Alternative would
continue the use of on-site systems throughout the Proposed Service Area.
Upgrading or replacement of on-site systems would be included where the exist-
ing systems were of obviously inadequate design, were malfunctioning, or could
be expected to malfunction based on comparisons with similar systems. For
segments having great frequencies of high groundwater, the alternative
included very low flow toilets, holding tanks, and off-site treatment for
toilet wastes.
After publication of the Draft EIS, EPA conducted several field studies
which substantially improved our knowledge of the condition and the effects of
the existing on-site systems (see Chapter I). On the basis of this new
information, the following modifications were incorporated into the Limited
Action Alternative:
Greywater/blackwater separation will be omitted, except for replacing
holding tanks as described below and for individual dwellings where
separation will provide some benefit. Well and shallow groundwater
samples failed to implicate on-site systems as a source of significant
groundwater contamination.
The problem most frequently encountered during the sanitary survey was
periodic backing up of cesspools. An estimated 176 cesspools are
located in the Proposed Service Area, approximately one-third of which
back up or require frequent pumping. All of these systems are con-
sidered to be inadequate since they lack any form of waste stabiliza-
tion prior to soil disposal. Septic tank/soil absorption systems will
be installed to replace cesspools. The type of soil absorption system
in the replacements will depend on soil depth above groundwater:
dosed mounds for depths from 0 to 2 feet, dosed shallow placement
drainfields or beds from 2 to 4 feet, gravity fed shallow placement
drainfields or beds from 4 to 6 feet, and conventional drainfields for
depths over 6 feet.
The high number of unsupervised holding tanks is the most severe
threat to public health in the Proposed Service Area. Illegal pumping
of holding tanks into the lakes has been reported. This is an abso-
lutely unacceptable practice that can be abated by public control
over holding tank pumping. It is recommended that, where it is envi-
ronmentally acceptable and cost-effective for individual dwellings,
holding tanks will be converted to receive only toilet waste from very
low flow toilets and that other wastewaters be discharged to new sep-
tic tank/soil absorption systems. Design of the soil absorption sys-
tems will be based on depth to groundwater, as described above for
cesspool replacements. It is recognized that some holding tanks will
have to be retained for environmental or economic reasons.
Compared to cesspools, systems with septic tanks have a much lower
failure rate. Shallow depth to groundwater contributed to all ST/SAS
problems recognized during the sanitary survey. Therefore, dosed
mound systems will replace soil absorption systems that have insuf-
ficient hydraulic capacity because of high groundwater.
17
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Several resorts present special problems in that space and groundwater
conditions are more restrictive to on-site improvements than is the
case with individual lots. Resorts also were found to have a much
higher frequency of holding tanks and sluggish soil absorption sys-
tems. While each case needs to be considered individually, for the
Modified Limited Action Alternative half of the resort units will be
served by low pressure sewers and off-site, multi-family filter fields
(cluster systems).
The Applicant will provide information on use, cost, and benefits of
flow reduction devices to residents and owners of businesses:
in segments 1, 2, 11, 13, 21 through 25, 28 through 31, and 34
in other locations with high groundwater,
whose systems will be upgraded with Federal funds
Commercial establishments other than resorts were not surveyed. Costs
to upgrade on-site systems for commercial establishments are, there-
fore, estimated on the basis of dollars per dwelling unit equivalent
for all other buildings in the Proposal Service Area.
The upgrading and repair estimated to be necessary are itemized in Table
2. The present worth of the Modified Limited Action Alternative is estimated
to be $4,763,100 as detailed in Appendix D of this EIS. This compares to
$7,152,200 for the Limited Action Alternative described in the Draft EIS and
$10,358,600 for the Facility Plan Proposed Action.
In other respects, particularly the requirements for house-by-house site
analysis and community supervison of on-site systems, the Modified Limited
Action Alternative represents the same concept as the Draft EIS's Limited
Action Alternative; that is, maximum use of existing on-site systems with
upgrading and repairs as necessitated by system performance, plus continuing
community supervision of all wastewater facilities. While many of the ele-
ments of this approach have been estimated, described, and costed, the final
details will not be known until: 1) house-by-house analysis allows a selec-
tion of treatment methods for each house, and 2) the Applicant and community
decide on the method and degree of management to be provided. These two
considerations are discussed below.
1. TECHNOLOGY SELECTION
Identification of on-site system problems and the causes of their pro-
blems is the first step toward selection of technologies for individual resi-
dences. Site-specific analysis is necessary to accomplish this. The analysis
should be sequential, beginning with accessing available health department
records, interviewing residents on the use and maintenance of their systems,
inspecting the site for obvious malfunctions, and inspecting the locations and
conditions of any on-site wells or springs. Based on the information
gathered, additional investigations may be warranted to identify the cause and
possible remedies for recognized problems. Examples of additional investiga-
tions, keyed to problems, are:
18
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Table 2. Upgrading and Repairs of Existing On-Site Systems - Modified Limited Action
Existing Systems
Suggested Upgrading and Repairs
Cesspools Number
Otter Tail 135
Lake
Other Seg- 41
ments
Holding
Tanks Number
Otter Tail 56
Lake
Other Seg- 17
ments
ST/SAS with Limited Hydraulic
Number
Otter Tail 19
Lake
Other Seg- 6
ments
Resorts with Holding Tanks or
Otter Tail Lake
Other Segments
Install
Septic
Tank
135
41
Stay on
Holding
Tank
10
3
Capacity
Dosed Conv en-
Dosed Shallow Shallow tional
Mound Drainfield Drainfield Drainfield
27 27 27 54
8 8 8 17
Dosed
Dosed Shallow Shallow
Mound Drainfield Drainfield
20 20 6
662
Dosed
Mound
19
6
Inadequate Soil Absorption Systems
% of
Seasonal
Units
50%
50%
Number
Cluster of Units
Systems Connected
8 54
5 27
19
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Problem
Recurrent Backup into House or
Evident Ground Surface Malfunction
Inadequate Separation Distance
from Septic Tank or Soil Adsorp-
tion System to Well
Inadequate Separation Distance
from Septic Tank/Soil Absorption
System to Lakeshore, or Inadequate
Separation Distance from Soil
Absorption system to Groundwater
or Evidence of Increased Plant
Growth
Septic Tank or Soil Absorption
System Size or Design Suspected
of Being Less than Code Requires
Investigations in Sequential Order
Install and monitor water meter
Uncover, pump out, and inspect
septic tank for obstruction and
groundwater inflow
Rod house sewer and effluent line
Excavate and inspect drainfield
distribution lines, if present
Determine soil absorption system
size and degree of clogging by
probing and sample pit excavation.
Note soil texture and depth to
groundwater
Inspect well for proper seal, vent,
drainage, and grouting
Sample well and analyze for fecal
coliform bacteria, nitrates, and
fluorescence
Monitor groundwater flow if drink-
ing water aquifer is shallow or
unconfined
Monitor groundwater flow direc-
tion and rate
Locate effluent plume in vicinity
of lakeshore, using groundwater
probe and fluorescent analysis
Sample groundwater in leachate
plume at lakeshore. Analyze for
total phosphorus, total Kjeldahl
nitrogen, nitrate, nitrogen, and
fecal coliform bacteria
Inspect property to assess feasi-
bility of replacement or upgrading
If feasible, document system
inadequacies by probing and
sample pit excavation
20
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Septic Tank or Soil Absorption Inspect property to assess feasi-
System Size or Design Known to bility of replacement or upgrad-
be Less than Code Requires ing
In the selection of technologies for individual sites, this EIS strongly
recommends that:
Alternatives other than those covered by existing codes be considered
This process involve state and local officials legally responsible
for permitting on-site systems
The availability and cost of skilled manpower for maintaining and
monitoring innovative or sub-code systems be weighted against the
feasibility and cost of requiring conventional on-site systems or off-
site systems
That there be a multidisciplinary team, consisting of the sanitarian-
administrator and available specialists in a number of fields (see
Community Management, Section II.B.2) to advise the Sanitary Review
Board on a case-by-case basis
The individual homeowner should be informed of the different options
being considered (and their costs) when technology selections are
being made. The owners opinion and advice should be solicited.
Utilizing information gained from the site by site analysis, a technical
expert should discuss with the owner feasible approaches to solving any
problems. Primary criteria for identifying the appropriate technology should
be costs, benefits, and risk of failure. Undoubtedly, the analysis will also
consider eligibility for Construction Grants funding. General guidelines for
eligibility of on-site technologies are presented below:
Replacement of facilities of obviously inadequate design will be
eligible if feasible. Cesspools are an example of obviously inade-
quate facilities. Septic tanks in very poor repair or substantially
smaller than required by state codes are another example. Small
drainfields, dry wells, or unusually designed systems are not con-
sidered to be of obviously inadequate design and thus are ineligible
unless they are covered by the following guidelines.
Parts of systems that cause recurrent surface failures, backups, or
contamination of potential drinking water aquifers are eligible for
repair or replacement. This does not apply to water-using fixtures.
Systems that fail because they are abused will not be eligible unless
the abuse is terminated and the usage of the system is documented by
water meter readings and/or reinspection of the system.
Facilities which are not currently causing public health or water
quality problems may be eligible for repair or replacement if similar
systems in the area are failing. "Similarity of systems" includes
design and site characteristics which are shown to be contributing to
failures.
21
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This process should aspire to comply with state and local on-site
design regulations in design of repairs and replacements where feasi-
ble and effective. Compliance is not a condition of eligibility
if sub-code design or alternative processes can reasonably be ex-
pected to eliminate or substantially mitigate public health and water
resources problems. Innovative designs will similarly be eligible
with the added condition of assured inspection and monitoring com-
mensurate with the degree of risk. For sub-code, alternative or inno-
vative systems, it is expected that water conservation devices com-
mensurate with the degree of risk for hydraulic overloading will be
installed at owner or applicant's expense.
For this Study Area, methods will be eligible which modify the flow
or chemical characteristics of effluent plumes that enter Otter Tail
Lake if the modification results in localized water quality benefits.
Construction Grants guidelines consider such methods innovative.
However, they do require monitoring of effectiveness.
On-site systems built after December 1977 are not eligible for repair
or replacement but will be eligible for site analysis. Accommodation
of new water-using devices added since December 1977 will not be a
basis for determining eligibility. Systems adequately designed for
the building they serve but malfunctioning because of hydraulic or
organic overloading or other abuse will not be eligible, except as
explained above.
It is recognized that some developed lots may never be serviceable by
on-site technologies. Off-site treatment and disposal systems then will be
eligible for Federal funding if:
1) a public health or water resource contamination problem is documented
that any combination of on-site conventional, innovative, sub-code,
flow reduction, or waste restriction methods cannot abate, or
2) the life cycle costs of off-site treatment and disposal for an indi-
vidual building or group of buildings is less than costs of appro-
priate on-site technologies for the same buildings.
The recommendations apply only to existing systems. EPA is recommending
and funding the Modified Limited Action Alternative to help the community and
system owners minimize the risk, of water quality and public health problems.
For systems to be built for new housing, EPA makes no recommendations on the
permitting process, since the Agency does not presently expect to be funding
remedies for their failures.
2. COMMUNITY MANAGEMENT
In regard to funding privately owned on-site systems, current EPA regula-
tions (40 CFR 35.918-1) require that
...the grant applicant shall:...Certify that such treatment
works will be properly installed, operated, and maintained
and that the public body will be responsible for such actions.
This requirement also applies to publicly owned on-site systems.
22
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Within this limitation, communities have a wide range of options avail-
able. Many of these options are discussed in the Draft EIS, Section III.E.2.
Three additional topics and their interrelationships are discussed here. They
are: risk, liability, and scope of the Applicant's responsibilities.
"Risk" as used here refers to the probability that wastewater facilities
will not operate as intended, thereby causing water quality or public health
problems or inconvenience for the user. Whether centralized, small-scale, or
on-site, all'wastewater facilities have inherent risks, the degree of which is
dependent on skill in design, construction, operation, and maintenance.
"Liability" as used here refers to the responsibility of various parties
to minimize risk and to accept the consequences of facility failure. In the
past, the state or county has accepted liability for facilities around Otter
Tail Lake only insofar permitting and inspection activities minimized risk.
The consequences of facility failure rest with system owners. In building a
sewer around Otter Tail Lake, the proposed Otter Tail Sanitary District (OTSD)
essentially would have accepted liability for all failure except plumbing and
house sewer blockages. With the Modified Limited Action Alternative, the
community still has the opportunity to assume increased liability in whatever
manner it sees fitthe only limitation being that the Otter Tail County
Department of Land and Resources Management (OTCDLRM) will be responsible for
actively identifying failures of interest to the community (inconvenience for
the user not included) and attempting to remedy the failures. Strictly
speaking, the OTCDLRM responsibility under 40 CFR 35.918-1 applies only to
those individual systems funded by EPA.
Many of the assumptions made in describing and costing the Modified
Limited Action Alternative were based on the Applicant's playing a very active
role in improving, monitoring, and maintaining all wastewater facilities
around Otter Tail Lake. EPA encourages this but does not require it. The
scope of responsibilities depends on how much liability for wastewater facili-
ties the Applicant wants, and is capable, legally to assume. EPA will, by
funding facility planning, design, and construction, assist the Applicant in
meeting those liabilities it assumes that reduce the risk of water quality and
public health problems.
To illustrate the range of approaches the applicant might take, three
management scenarios are described below:
Minimum Management Requirements
The Applicant would act as the recipient and distributor of Construction
Grant funds. Homeowners who wished to improve their on-site facilities could
voluntarily apply to the Applicant for this assistance. After documenting
that minimum requirements for on-site system eligibility are met, the Appli-
cant would receive the funding and distribute it to homeowners who show proof
of satisfactory installation. These homeowners would be assessed an annual
fee thereafter to cover the cost of a site inspection perhaps every three to
five years and would be required to show proof of appropriate maintenance
activities as part of the site inspection. A groundwater monitoring program
would include taking well water samples during the site inspection.
23
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With this approach, the Applicant would not incur any long-term debt.
The Applicant would not necessarily have any responsibility for, or interest
in, permitting future on-site systems. Without a comprehensive site inspec-
tion and evaluation program, it is unlikely that all water quality and public
health problems would be identified and abated, since property owners would
not be required to participate. Liability for facility malfunctions would
remain wholly with the owners.
Comprehensive Wastewater Management
This is the approach recommended for adoption by the Applicant. It
involves instituting the small waste flows district concept discussed in the
Draft EIS (see particularly pages 123-128, 184-186, and DEIS Appendix J).
All buildings within the district's service area boundaries would be included.
At a minimum each building's wastewater system would be covered in the site
specific analysis, and would be inspected at intervals. Owners or residents
of each building would be responsible for a user charge to repay their share
of necessary operating costs. The local debt for construction of each system
can be directly assessed to individual homeowners, as in the Minimum Manage-
ment scenario, or they could be funded as long term debt.
This approach should identify all wastewater generation, treatment, and
disposal problems in the service area, and should ensure that future problems
are minor or short-lived. In contrast to the Minimum Management scenario, the
higher level of responsibility resulting from this approach would allow the
authority greater discretion in sharing liability for facility operation with
the resident or building owner.
Technical expertise would be provided by any one of a number of different
options. The OTCDLRM could expand their staff to accommodate this type of
operation for Otter Tail Lake as a demonstration project, with additional
projects possible in other parts of the county.
Watershed Management
The Applicant's concern with prevention and control of water pollution
need not be restricted to wastewater facilities. It is obvious from comments
on the Draft EIS that citizens of the Study Area are greatly interested in
maintaining the water quality of Otter Tail Lake. If that interest is
expressed in the form of willingness to pay for additional governmental ser-
vices, the Comprehensive Wastewater Management scenario could be augmented by
the following functions:
non-point source monitoring
non-point source control
Education of residents and visitors about individual pollution control
practices, costs, and benefits
Inventory of the biological resources of the lakes and their tribu-
taries
24
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Research on the chemical, hydrological, and biological dynamics of the
lakes
Coordination with other local, state, and Federal agencies on pollu-
tion control activities and funding.
3. IMPLEMENTATION
As concluded in the Draft EIS, the Recommended Action is to construct
on-site systems on an as required basis with administrative powers being given
to the Applicant. Please note that the Modified Limited Action Alternative
may vary from the technology assumptions listed in Appendix B of this EIS.
This is because the detailed step 2 or 3 site-by-site work needed to finally
decide the level of on-site upgrading for each house may indicate that parti-
cular dwellings have problems requiring different technologies from those
incorporated in the Modified Limited Action Alternative. These changes while
affecting specific houses, should not greatly impact the total amount of work
for any one segment, much less the entire Study Area. When upgrading of
existing conventional septic tank/soil absorption systems is found to be
impractical, alternative on-site measures should be evaluated. These include
technologies such as composting or other alternative toilets, flow reduction,
holding tanks, and separate greywater/blackwater disposal.
Specific aspects of implementing the Otter Tail Lake project were dis-
cussed in Section VI.E. of the Draft EIS. Modifications to those discussions
are:
Ownership of On-Site Systems Serving Seasonal Residents - The state-
ment was made in the Draft EIS that privately owned systems serving
seasonally occupied residences are not eligible for Federally funded
renovation and replacement. EPA Program Requirements Memorandum 79-8,
issued very shortly before the Draft EIS went to print, modified this
policy to allow eligibility of seasonally used, privately owned on-
site systems as long as the responsible public agency is given "com-
plete access to and control of" the system. See Section V, Comments
and Responses, under the "Implementation/Management" heading.
Completion of Step 2 Requirements for the Small Waste Flows District -
The Minnesota Pollution Control Agency (MPCA) has favored the comple-
tion of sufficient site analysis to support preliminary technology
selection during Step 1 for all buildings in the Proposed Service
Area. MPCA has requested that this partial site analysis include
completion of the sanitary survey for most of the buildings involved.
EPA has responded to this request by funding completion of the sani-
tary survey. The Otter Tail County Department of Land and Resources
Management will perform this work.
The question of whether detailed site analysis should be considered
necessary for cost-effectiveness analysis in Step 1 or be defined as
design work fundable in Step 2 has also been raised by other state
agencies. In response, EPA Region V developed a new memorandum clari-
fying project needs documentation. It provides that at most a repre-
25
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sentative sampling (15 to 30%) of on-site systems need be developed in
Step 1 for a site-specific data base. The remaining 70 to 85% should
be done in Step 2 (see Appendix A). Other remaining Step 2 require-
ments remain as stated in the Draft EIS.
USEPA has determined that a county ordinance providing for access,
inspection and upgrading of systems as needed would satisfy the re-
quirements for public ownership (see Appendix G).
For the purposes of technology selection and organization development in
Step 2 and construction supervision in Step 3, the grantee should establish a
Sanitary Review Board. This board can consist of members of the Lake Shore
Property Owners Association or be an independently elected body. The board's
responsibilities will be to:
Supervise the direction and progress of the site-specific analysis
Ensure homeowner input to technology selection
Encourage community participation in the management and technology
decisions to be made
Review and act on any proposed facilities designs that are not in
conformance with present regulations
Provide an appeal process for owners who object to the technology
selected for their property
« Ensure that a multidisciplinary team conducts the analysis and techno-
logy selection. The team should consist of persons with knowledge and
experience in soil science; water chemistry; geohydrology; wastewater
characteristics; innovative; alternative, and conventional decentra-
lized treatment technologies, and practical aspects of decentralized
system construction and maintenance.
The application for Step 2 funds should include a description of the
grantee's organization for this review board and the qualifications of indi-
viduals proposed for the Step 2 site analysis and technology selection. The
Step 2 grant will be contingent upon review and approval of the application by
the Technology Section of EPA Region V's Water Division.
The Applicant currently has power to manage and enforce the Shoreland
Management Act within 1,000 feet from the normal high water mark of a lake,
pond or flowage and 300 feet from a river or stream or the landward extent of
flood plain. They also have the legal power to enforce all provisions of the
act. In the future, these powers could be expanded by Otter Tail County to
include the ability to collect fees for maintenance of on-site systems.
This EIS recommends that the necessary technical expertise for on-site
management and design be sought from several sources, such as:
Corporate consultants
26
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Individual consultants
University of Minnesota Extension Service
West Central Regional Development Commission
Fergus Falls Health Department
US Soil Conservation Service
Similarly, if assistance in developing the organizational structure of
the review board and supporting activities is needed, legal and management
consulting services should be sought and, within reason, they will be grant
eligible.
C. THE NO-ACTION ALTERNATIVE
The No-Action Alternative is broadly defined as an EPA rejection of
Construction Grants applications for the Study Area. The following results
are expected with the No Action Alternative:
The Otter Tail County Department of Land and Resources Management will
enforce the County's Shoreline Management Ordinance. The Ordinance is
based on construction standards (sizing and setback requirements) and
does not recognize the actual performance of existing systems or the
assimilative capacity of local soil and groundwater resources. Al-
though the Ordinance allows variances, personnel of the Land and
Resources Management Office have stated that they will not grant
variances except for the use of sand mound systems.
The site-specific analysis required for the Modified Limited Action
Alternative will probably not be conducted. This type of analysis is
not normally performed to support enforcement of the Shoreline Manage-
ment Ordinance.
Maintenance of wastewater systems will remain the responsibility of
property owners. After existing systems are upgraded to meet code
requirements, supervision provided by the Department of Land and
Resources Management would probably be limited to permitting new sys-
tems and following up on complaints. Of primary concern with this
level of supervision is illegal pumping of holding tanks into streams
or lakes. Secondarily, there will be a lack of information regarding
water quality impacts of on-site systems in the future, since monitor-
ing would not be conducted.
Without actual performance data and the ability to provide long-term
monitoring, the Department of Land and Resource Management will not
have the information necessary to identify and implement innovative
treatment methods or to responsibly allow variances to Ordinance re-
quirements. It is estimated that the conservative designs required by
the Ordinance will cost approximately $2,700,000 (present worth) more
than the performance-based decisions of the Modified Limited Action
Alternative.
27
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At present, approximately 68% of the 847 systems serving residences
around Otter Tail Lake do not conform to the Shoreline Management Ordinance.
The Otter Tail County Office of Land and Water Resources typically allows
three means for existing non-complying residences to achieve compliance:
construction of an off-site cluster system, installation of a new well, or
installation of a holding tank. Revised state regulations expected to be
enacted in the near future would also allow elevated sand mounds as an alter-
native to holding tanks. Depending on lot size data and sanitary survey
information, the following facilities would be required for residences around
Otter Tail Lake and other shoreline segments in the Proposed Service Area for
the No-Action Alternative:
Connect to Cluster
Systems
(approx. 12 clusters)
New
Holding
Tanks
Dosed
Mounds
New
Wells
Otter Tail Lake
Other Segments
232
94
61
12
47
9
443
84
No Action does not mean no cost. Property owners will bear the costs of
replacement wastewater systems and wells, continued pumping of holding tanks,
other operation and maintenance costs, and installation of future systems.
The present worth of No Action is estimated to be $7,505,300 (see Appendix C
for details).
D. OTHER ALTERNATIVES
Many other alternatives have been considered in the Applicant's Facility
Plan and in EPA's Draft EIS. Alternatives considered and reasons for their
rejection or other status are summarized below:
FACILITY PLAN ALTERNATIVES
Alternatives
Septic tank/soil absorption
systems in conjunction with holding
tanks
A central collection system
with wastewater treatment at
an activated sludge treatment
plant with phosphorus removal
A central collection system with
treatment by stabilization ponds
and a single land application site
A central collection system
with multiple stabilization ponds
and two land application sites
Status
Rejected in the Facility Plan
because it did not contribute to
water quality objectives, had high
cost, lack of reliability, and
difficult implementation proce-
dures. Reconsidered in the EIS.
Rejected on basis of water quality
impacts and high cost.
Accepted as the Facility Plan
Proposed Action and Application
for construction grants funding.
Rejected on the basis of low re-
liability and operability.
28
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No Action Rejected in Facility Plan on
basis of failure to address pol-
lution problems.
EIS ALTERNATIVES NOT ALREADY CONSIDERED IN FACILITIES PLAN
Residential flow reduction by
main-various devices
mini-
Laundry detergent phosphorus ban
Pressure sewers
Vacuum sewers
Small diameter sewers
Alternative toilets, various designs
On-site treatment and disposal,
various designs
Off-site treatment and disposal,
various designs (cluster systems)
Septage disposal by co-treatment at
local sewage treatment plants
Septage disposal by land application
Expected to be effective in
taining the operability and
mizing impacts of on-site systems
in the EIS Recommended Action.
Implemented by Minnesota PCA dur-
ing the EIS process.
Extensive use of pressure sewers
rejected because of lack of need.
Could be advantageous in the de-
sign of small waste flows systems.
Rejected in preference to pressure
sewers for comparison with gravity
sewers. Could be advantageous in
the design of small waste flows
systems.
Rejected because of marginal cost
advantage over conventional
gravity sewers for large collec-
tion systems. Could be advan-
tageous in the design of small
waste flows systems.
Not specifically incorporated in
EIS Recommended Action, but could
be useful where control of nu-
trients is sought.
Incorporated in EIS Recommended
Action, for Otter Tail Lake area -
discharging systems excluded from
use.
Incorporated in EIS Recommended
Action for Otter Tail Lake area
where shown to be worth the ex-
pense, especially resort areas.
Mentioned as a possibility -
needs additional analysis.
Mentioned as a possibility -
needs additional analysis.
29
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CHAPTER III
AFFECTED ENVIRONMENT AND IMPACTS OF NO ACTION
A. SOILS
Soils in the Study Area were formed from materials deposited by glaciers.
They generally contain high proportions of sand and are rapidly permeable.
Their suitability for subsurface waste disposal and land application of
waste has been rated as poor in half of the shoreline areas of Otter Tail Lake
by the USDA SCS. However, as a result of the various field studies conducted
by EPA (see Chapter I), it can be concluded that most ST/SAS's are working
well, with the exception of a small percentage whose operation is being
hampered by high groundwater levels.
Because of the soil's permeability in most developed places, backups of
existing on-site systems are expected to recur--but at a low rateeven with
the No-Action Alternative. High permeability of lakeshore soils also suggests
the possibility that septic tank effluents may not be adequately treated
before emerging into the lake. Survey data and detailed site investigations
suggest that treatment, particularly removal of nutrients, is variable.
Building of new dwellings and on-site systems will continue under the No
Action Alternative. Some erosion will occur because of this activity.
B. SURFACE WATER RESOURCES
Otter Tail Lake occupies approximately 23 square miles; its tributary is
the Otter Tail River. Other major lakes in the Study Area include Lake
Blanche (2.1 sq. mi.), Long Lake (1.8 sq. mi.), Walker Lake (1 sq. mi.), Deer
Lake (0.7 sq. mi.), and Round Lake (0.3 sq. mi.).
Otter Tail Lake, with a retention time of 2.4 years, is generally clean,
clear, and bordering on oligotrophic-mesotrophic. Round Lake, the only other
lake for which adequate data are available, is highly oligotrophic. For both
lakes, phosphorus has been identified as the limiting nutrient. The lakes in
this particular geographic region are alkaline. This condition in itself may
significantly affect the lake water quality in terms of phosphorus concentra-
tions. Under certain circumstances, chemical precipitation in a hardwater
environment effectively removes phosphorus from the water column, making it
unavailable to algae for growth. Algal growth may be naturally regulated by
this mechanism. With the No Action Alternative, Otter Tail Lake is certain to
remain oligotrophic-mesotrophic.
C. GROUNDWATER RESOURCES
Groundwater serves as the source of drinking water for the entire Study
Area, and is derived from the outwash aquifer. These outwash aquifers of
stratified sand and gravel vary in thickness from 50 feet in the east to about
100 feet in the west of the Study Area. Throughout most of the Study Areas
the groundwater reservoir is under water table conditions; the surface of the
water touches the overlying zone of aeration.
31
-------
Otter Tail Lake acts like a large withdrawal well, and groundwaters flow
toward Otter Tail Lake along all but the western shoreline. Flow is parti-
cularly rapid along those lakeshore areas adjacent to satellite lakes. How-
ever, studies have shown that the rate and direction of this flow vary sea-
sonally and with lake level (see Chapter I).
The construction of wells on most residential lots consists of a small
diameter galvanized steel pipe, which is driven to a shallow depth (generally
less than 30 feet). These are referred to as sand point wells. Many of these
wells are poorly constructed and in some cases dangerously close (less than 50
feet) to soil absorption systems.
Results of a well sampling program (discussed in Chapter I) indicated
that, in the few cases where wells had detectable contamination, no clear
conclusion could be drawn about the role of sewage disposal systems. Several
of the wells that evidenced contamination met the separation distances in the
Shoreland Management Act. These wells were in almost all cases shallow and
driven. This points out that the wells themselves may not be constructed
properly or that they should be drilled to a greater depth.
The results of the aquatic productivity study (see Chapter I) indicates
that subsurface waste disposal may have localized effects on groundwater but
no major impacts in terms of stimulating near-shore aquatic vegetation in
Otter Tail Lake.
The impacts of the No Action Alternative will be minor, since most on-
site systems are already in place. However, cluster systems, holding tanks,
and deeper wells (to a depth of 50 feet) provide additional insurance in
preventing groundwater contamination, especially in shallow groundwater areas.
D. POPULATION AND LAND USE
Residential single-family land use has been mostly confined to areas
around the various lakeshores and Otter Tail Village. Lakeshore development
is in a single-tier pattern, for the most part. The most densely populated
lakeshore areas include: most of the Otter Tail Lake shoreline, the north
shore of Lake Blanche, the south shores of Walker Lake and Long Lake, Round
Lake, and the north shore of Deer Lake. Many of the lots around Otter Lake
are small, with about 40 to 50% being less than 20,000 square feet. The
extent and distribution of lot sizes is shown in Figure 8. Only small
incremental increases in residential acreage are anticipated regardless of the
wastewater management alternative adopted.
Approximately 83% of the Proposed Service Area population are seasonal
residents, located primarily around Otter Tail Lake. Table 3 presents data on
the existing and future number of dwelling units and population in the
Proposed Service Area.
The total in-summer population of the Proposed Service Area in the year
2000 is projected to be approximately 7,600, a 19% increase over the 1976
figure. The seasonal population will increase by more then 700 people (65%).
The population projections assume an increasing proportion of year-round
residents in previously seasonally occupied districts.
32
-------
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in population growth approximately equal to the baseline population projec-
tions (19% increase over total existing population by the year 2000).
E. ENVIRONMENTALLY SENSITIVE AREAS
Environmentally sensitive areas within the EIS Study Area include wet-
lands, prime agricultural lands, flood hazard areas, and the possibility of
archaeological sites. Of these, only prime agricultural lands around Otter
Tail Lake are likely to be adversely impacted by any of the decentralized
alternatives, including No Action. Centralized wastewater options have the
potential for disturbing valuable wetland areas. Pressures to develop mar-
ginally suitable sites with on-site systems will increase as more favorably
located sites are developed. Accelerated soil erosion that could result from
construction activities and vegetation removal can be mitigated by adherence
to the Sediment and Erosion Control Regulations for Otter Tail County.
Since a great deal of archaeological work has not been done in the Otter
Tail area, and since the few excavations conducted indicate a surprising range
of cultural materials, it is difficult to predict exactly what archaeologcal
resources are present. The Minnesota Historical Society has recommended that
undisturbed or minimally disturbed areas within 1,000 feet of natural shore-
line (which would be affected by the construction of sewage treatment facili-
ties) be examined for prehistoric archaeological sites. Prior to construction
of any wastewater facilities on publicly owned land in the Study Area, the
Minnesota State Historic Preservation Officer will require an archaeological
survey.
F. ECONOMICS
The permanent population of the Study Area is characterized by a rela-
tively low income that is below the average for Minnesota. The 1978 median
income for the Proposed Service Area has been estimated to be $12,000 for
permanent residents. No data are available for seasonal resident income
characteristics (this inadequacy is discussed in the Comment and Response
section, No. 48).
The costs of No Action in the Study Area will fall most heavily on pro-
perty owners whose on-site systems do not meet the Shoreline Management Ordi-
nance Requirements. The homeowner will be required to choose and pay for one
of the following options, depending on the nature of the violation:
Construction Cost
Operation and
Maintenance Cost
Initial
Investment
Drill a new well
(50' deep)
Install a holding tank
Connect to a cluster system
Install a new ST/SAS
ST/Sand mound
$
700
450
5,350
1,270
8,850
Annual
Equivalent
$65/yr
42/yr
500/yr
119/yr
827/yr
Permanent
Residence
Seasonal
Residence
-0- -0-
$3,300/yr* $720/yr*
75/yr 67/yr
20/yr 12/yr
75/yr 67/yr
Although this cost could be reduced substantially by installation of effec-
tive flow reduction devices and negotiation with the hauler, the cost would
still be substantial. The high cost would be an incentive for the home-
owner to find other, perhaps dangerous, means of disposing of wastewater.
35
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As long as their systems do not fail, other homeowners could get by with
very minimal expense, perhaps $45 every 10 years for maintenance pumping of
their septic tank. Residents whose systems fail but who can make a standard
repair would incur a one-time expense of perhaps $1,000 to $3,000. If dosed
mound systems were necessary, costs could be as high as $9,000.
36
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CHAPTER IV
ENVIRONMENTAL CONSEQUENCES OF THE ACTION ALTERNATIVES
This chapter presents the environmental impacts of the conceptual or
system alternatives embodied in the Facility Plan Proposed Action and in the
EIS's Modified Limited Action Alternative. Please note that the Modified
Limited Action Alternative is not at present a set of explicit construction
proposals for every single buildingit is a segmented approach, based on the
assimilative capacity as well as the environmental sensitivity of the local
natural resources, that relies on environmental management in the form of
continuing attention to the use and effects of small-scale systems, and the
ability to make balanced decisions in the best interest of the local
environment.
A. SURFACE WATER RESOURCES
The future phosphorus loads associated with either the Facility Plan
Proposed Action or the Modified Limited Action to Otter Tail Lake, Deer Lake,
Walker Lake, Long Lake, and Lake Blanche would be minimally effected. This is
because the load from septic tanks is very small compared to that from other
non-point sources. Another factor contributing to the small change in
nutrient loads is that neither alternative is anticipated to induce signi-
ficant growth, which would increase the non-point source load. The trophic
status of the lakes is not projected to change in the future with implemen-
tation of either alternative.
In contrast, the phosphorus load to Round Lake could be increased by as
much as 100% over the planning period by implementation of the Modified
Limited Action Alternative. Septic tanks contribute a large percentage of the
phosphorus load because non-point sources are limited by the small watershed
areas and by the land locked nature of the lake. The Facility Plan Proposed
Action would significantly decrease phosphorus loads. However, neither alter-
native is expected to alter the high water quality of the lake (oligotrophic).
The Facility Plan Proposed Action would eliminate septic tank effluent
discharges to Otter Tail Lake and its satellites. However, as discussed in
Chapter I, septic tanks do not currently have significant impacts on water
quality and aquatic vegetation in the lakes. In the Facility Plan Proposed
Action there exists the possibility of pumping station breakdown and signi-
ficant raw wastewater discharges to the lake. Careful design and close super-
vision of the pumping stations would minimize this possibility.
Small wastewater pumping units (300 to 5,000 gpd) may be required for
cluster systems or individual homes. Reliable alarm systems and periodic
maintenance (one to four times per year) will be needed to ensure against
backups or overflow to the lake. Since the size of spills with the Modified
Limited Action Alternative are about two orders of magnitude less than with
the Facility Plan Proposed Action, the possible impacts of equipment failure
are much less.
37
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B. GROUNDWATER
The Facility Plan Proposed Action would eliminate the discharge of waste-
water effluents to the groundwaters around Otter Tail Lake. The threat of
well water contamination from septic tank effluents would be removed. How-
ever, actual improvement of potable groundwater supply would be minor at best.
Well water quality as sampled in 1979 was generally satisfactory, except for
high nitrates of undetermined origin in a few wells, and a few wells with poor
construction that displayed detectable fecal coliform levels.
The Modified Limited Action Alternative would detect and reduce or elimi-
nate potential contaminants in the shallow groundwater around Otter Tail Lake
through the site-by-site environmental and engineering analysis and applica-
tion of appropriate on-site technology. The groundwater plumes have been
shown to vary, depending on season and lake levels. At present, wells driven
within these plumes, particularly ungrouted wells, can possibly receive ni-
trate and other chemical loads.
The Modified Limited Action Alternative would eliminate the hazard to
drinking water by 1) mandating inspection of existing wells and filter fields,
2) allowing sampling of all wells, and 3) allowing selection of on-site or
off-site measures to stop actual or possible drinking water contamination.
These repair measures will include elimination of cesspools and inade-
quately sized septic tanks, replacement of malfunctioning ST/SAS's, and
installation of off-site cluster systems in identified problem areas. Cluster
systems sites will receive geohydrologic surveys, and well water will be
monitored at regular intervals. Costs for these measures are included in
Appendix D. Also, actual repair (grouting, etc.) of wells may often prove
less expensive than treatment modifications.
C. POPULATION AND LAND USE
Population projections used for the design of alternatives in the EIS
were based on recent growth trends and data from a variety of sources. The
design projections did incorporate constraints and/or inducements created by
the amount of developable land. However, other complex economic, demographic,
or land use factors were not considered.
Examination of development potential as an impact of centralized sewage
treatment suggests that both the amount of developable land and the density of
development will be greater with sewers than without. Translated into popu-
lation increases, it is estimated that actual year 2000 population in the
existing and proposed service areas with the Facilities Plan Proposed Action
would be as much as 9% higher than the Modified Limited Action Alternative
population, or 8,235 instead of 7,555 total, in-summer population.
The population projections suggest an increase of 19 and 30% over the
1976 figures, for the Modified Limited Action and Facility Plan Proposed
Action. To accommodate the population projected for the Modified Limited
Action Alternative, approximately 400 to 500 acres of land would be developed.
Only a small increase (50 acres) in residential acreage is anticipated with
the Facility Plan Proposed Action. The amount of new near-shore development
would be constrained with the Modified Limited Action Alternative because the
38
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stock of land developable with on-site systems is small. In contrast, a sewer
would give near-shore acreage high development potential and could support
much higher density uses.
D. ECONOMIC IMPACTS
The main economic impacts of either alternative would be generated by the
direct cost to system users. The estimated direct cost is the most signi-
ficant difference between the two alternatives in terms of either environ-
mental or social impacts. With the Facilities Plan Proposed Action the 1980
average annual homeowner's cost around Otter Tail Area Lakes would be $350.
In contrast, the 1980 average annual homeowner's cost* around Otter Tail Lake
for the Modified Limited Action Alternative is $102.
The impact of these user charges is defined in terms of the percentage of
the population facing significant financial burdens and displacement pressure.
Significant financial burden is defined as a charge greater than 1.5 to 2.5%
of total income, the variable threshold rate being determined by level of
income. Displacement pressure is the stress placed upon families to move away
from the service area as a result of costly user charges. This is measured by
the percentage of families who would have to pay 5% or more of their income.
Table 4 presents the significant financial burden and displacement pressure
rates for permanent residents for the Facility Plan Proposed Action and the
Modified Limited Action.
Table 4. Financial Burden and Displacement Pressure
Alternative
Displacement
Pressure
Financial
Burden
Can
Afford
Facilities Plan
Proposed Action
Modified Limited Action
30-40%
5-10%
60-70%
20-30%
30-40%
70-80%
Although direct demographic information on seasonal residents is not
available, existing information can be utilized to ascertain the financial
impacts of the Modified Limited Action Alternative and the Facility Plan
Alternative. The Modified Limited Action Alternative offers monthly user
charges which are more than two-thirds lower than the Facility Plan Proposed
Action ($102 per month as opposed to $350 per month for the Facility Plan
"Average annual homeowners' cost" includes one residence's equal share of
his community's 1980 debt retirement cost plus 1980 operating expenses
plus a reserve fund contribution of 20% of this debt retirement share.
To this is added an equivalent annual payment for private costs (such as
house sewers) as if they were paid at 6 7/8% for 30 years.
39
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Alternative. Under most circumstances it costs considerably more to maintain
two homes than one. An annual user charge of $102 would place displacement
pressure (over 5 percent of income) only on families with an annual income of
$2,000 or less. The number of families that can live in two dwelling on such
an income (about one-third of the poverty level, as currenly defined) must be
extremely small. Therefore, the Modified Limited Action Alternative offers
little possibility of displacement of seasonal residents.
40
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CHAPTER V
PUBLIC AND AGENCY COMMENTS
Substantive public and agency comments were received on the Draft EIS.
They have been compiled and summarized in this chapter. Those comments that
were offered through testimony at the public hearing on the Draft EIS 5
January 1980 and through written correspondence, and are essential to the EIS
decisionmaking process are responded to herein. The comments and appropriate
responses are organized by Draft EIS subject areas including:
Water quality
Soils
Field data collection
Alternatives
On-site engineering
Funding/eligibility
Implementation/management
Impacts
Socioeconomics
The EIS process
All substantive written comments on the Draft EIS are included.
Water Quality
C. How much of the pollution in Otter Tail Lake is due to motorboats churn-
1 ing up the lake bottom and leaving an oil film on the water? (Talsness)
R. The DEIS section on lake water quality estimated that the sources of
1 nutrient "pollutants" to Otter Tail Lake were precipitation, septic
tanks, tributary (watershed) sources, and the immediate drainage area.
No other study conducted on Otter Tail Lake has indicated that motorboats
are causing impacts on water quality. Comments given at the public hear-
ing by MPCA quotes a study indicating that sometimes oil films are
noticeable from motorboats, but for the most part, the films dissipate
quickly and have no demonstrated impact on water quality.
It is true that much of Otter Tail Lake along its shoreline is shallow,
and boat wakes undoubted stir up the sediments. This wave action could
suspend sediments in the water column and make nutrients from the
sediments available again for algae growth. However, this impact is not
nearly as great as the effects of wave action from winds and ice move-
ment.
41
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C. If only 2 or 3% of the pollution in Otter Tail Lake is from septic tank
2 systems, why spend thousands of dollars per house on sewerage? (Talsness)
R. The DEIS acknowledges that the overall lake water quality is not signi-
2 ficantly deteriorated as a result of on-site wastewater systems and that
the introduction of wastewater collection and treatment technology will
not change this markedly. However, the EIS does document a clear need
due to recurrent in-home sewage backups in 11% of the systems and illegal
pumping of holding tank wastes into the lake. These represent a suf-
ficient water quality and public health problem to require some form of
action in order to mitigate them. The action recommended is appropriate
to solving these problems and to minimizing their reccurrence in the
future.
C. The Minnesota ban on soap and detergents containing phosphorus has gone
3 into effect since publication of the DEIS. (Hall)
R. Comment noted.
3
C. Is Otter Tail Lake polluted or isn't it? (Anonymous)
4
R. The DEIS section on surface water quality indicated that the trophic
4 status of the lake is low mesotrophic to high oligotrophic. This means
that the lake has a modest to low supply of nutrients and is capable of
maintaining low concentrations of algae. Additional studies contained in
the DEIS and this document have shown fecal coliform bacteria counts well
within the state standards. Overall lake water quality is therefore more
than adequate for primary contact recreation and should not be considered
polluted for that purpose.
C. What is the largest source of phosphates in Otter Tail Lake? (Keene)
5
R. The nutrient budget for Otter Tail Lake is shown in Table II-6 of the
5 DEIS. Tributary sources account for 82.2% of the phosphorus load.
Nearly all of this tributary phosphorus is carried by the the Otter Tail
River. These tributary sources are made up of agricultural runoff or
leaching of agricultural fertilizers.
Soils
C. It is not clear what criteria were used to select the Land Application
6 sites. These should be indicated. (Beaton, MPCA)
R. The criteria used for soil properties suitable for land application were
6 defined in Appendix A-3 of the DEIS. These criteria were applied to soil
series characteristics defined in the Otter Tail County Soil Atlas and
found in Table II-l of the DEIS. The proposed land applications sites in
Figure II-7 were selected based upon these soils characteristics, reason-
able transmission distances, and their distances from houses. These
sites would require on-site hydrogeologic verification prior to final
selection.
42
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Field Data Collection
C. Well data does not indicate whether contamination is from septic tanks,
7 whether specific pathogens have been identified or if illness has
resulted.
R. As part of the Sanitary Survey process, 75 well water samples were col-
7 lected for analysis by the Otter Tail County Health Department for
nitrates and fecal coliforms. Fecal coliform bacteria are found in the
intestines of warm blooded animals and are universally found in un-
treated sewage. Presence of fecal coliform bacteria in wells is presump-
tive, but not conclusive, evidence of contamination by sewage. Due to
the high number of very old and improperly protected wells, other para-
meters had to be evaluated to determine if sewage was causing problems.
Nitrate-Nitrogen was chosen as the accompanying parameter due to its
close link with sewage, its persistence in groundwaters, and its public
health effects.
None of the wells sampled were found to have contamination due to both
coliform bacteria and elevated nitrate-nitrogen levels. Two wells showed
signs of contamination by coliform group organisms but no evidence of
nitrate contamination. Based on this limited data, no positive link can
be made between on-site sewage disposal and well contamination around
Otter Tail Lake.
EPA recommends a complete sampling and analysis of wells in the Proposed
Service Area. This should include inspection of the well and conditions
which would relate to their contamination. Fluorescence, nitrates, and
fecal coliforms should be analyzed for well water samples. The well
sampling and analysis are eligible for Construction Grants funding as
part of the site analysis for Step 2 or 3. EPA has found no evidence of
illness resulting from septic tank systems or poor well water quality.
C. The field survey data need to be presented in a site specific format.
8 (Beaton)
R. The data collected for the sanitary survey, septic leachate study, and
8 groundwater study have been included as a separate Appendix to this
document. However, in order to assure privacy of homeowners in the
Study Area, these studies will be distributed to officials directly
involved in design and planning of facilities for the area.
C. It is not clear whether the new techniques used in preparation of the
9 Draft EIS would be eligible as part of a Facility Plan started today.
(Skuza)
R. Subsequent to the publication of the Facility Plan for Otter Tail Lake,
9 EPA promulgated a program requirements memorandum (PRM) to give further
guidance as part of EPA's Sewage Treatment Construction Grants Manual.
This PRM (78-9, 3 March 1978) states that a "facility plan must also
document the nature, number and location of existing disposal systems
(e.g., septic tanks) which are malfunctioning." A community survey of
individual disposal systems is recommended for this purpose, and is grant
eligible. Examples of community surveys, conducted for this study that
43
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are grant eligible are the sanitary survey and the septic leachate sur-
vey. Additional EPA Region V Guidance for Site Specific Needs Determina-
tion and Alternative Planning for Unsewered Areas is found in Appendix A
and demonstrates that the survey work accomplished to date would be
eligible for 75% Federal funding as Step 1 facility planning. Additional
site-by-site work called for in this EIS for needs documentation and
on-site design specification is eligible for 85% Federal funding for
alternative and innovative technology.
C. The EIS is not complete without detailed documentation of need on a
10 house-by-house basis. (Hall, MPCA)
R. The data collected on Otter Tail Lake's on-site systems is more extensive
10 than has been available for facilities planning in communities of this
size. EPA recognizes that additional observation and analysis of these
systems may alter our understanding of their use and their effects on the
environment. However, it is the Agency's judgment that changes, based
upon new data, in the recommended action will be changes in detail, not
in concept. The Agency is prepared to fund 85% of the detailed site
evaluation as a Step 2 or 3 grant (75% if conducted with a Step 1 grant)
in order to, first, provide necessary information for site specific
facilities design and, second, verify or modify our conclusion that
continued use of on-site systems will be environmentally acceptable in
the Study Area.
The Agency feels that the alternatives' feasibility is presented in
sufficient detail to determine cost-effectiveness. For those alterna-
tives that include continued use of on-site systems, EPA estimated fac-
tors subject to uncertainty conservatively high, especially the percent
replacement of septic tanks and drainfields. In addition, EPA reexamined
costs for operation and maintenance and for the site-specific analysis
for this Final EIS in more detail and with conservative estimates.
Boosting these cost estimates has made no difference in the ranking of
the recommended alternative. It appears unlikely that additional
improvements in the cost estimates based on actual designs will alter the
rankings either.
To clarify the site-specific work needed, EPA Region V prepared a memo-
randum clarifying needs documentation procedures (Appendix A). The great
majority of any such work should take place in Step 2 or 3. For these
reasons and because of the 50% savings to the applicant, EPA will fund
the site-specific evaluation as a Step 2 or 3 grant.
C. Is there any way that an on-site inspection can determine whether or not
11 any system is working properly. (Anonymous)
R. Identification of on-site system problems and their cause is the first
11 order of priority in the site-by-site analysis. Once the small waste
flows district is established, existing systems will be evaluated as
defined in Section II.B.I, Technology Selection. This evaluation will
take a number of different approaches to identifying existing problems,
which would reveal whether a system is working properly or not.
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C. The person who does not want to pay for repairs to his system may not
12. respond honestly to an inspector's questions. (Anonymous)
R. Any on-site system found to be causing public health or water pollution
12 control problems is eligible for 85% Federal funding and 9% state fund-
ing. A homeowner required to upgrade his on-site system will thus only
have to pay 6% of the cost to construct the system. In the worst case
cost of $8,850 for a new septic tank and elevated sand mount system, a
homeowner would pay only $531 with Federal and state funding. If the
homeowner were to not participate and his on-site system were to fail at
a later date, repair or replacement of the on-site system would be at his
own expense.
Alternatives
C. Since the Facility Plan Proposed Action was redesigned and re-costed with
13 flow-reduction measures, then all other alternatives should be so de-
signed and costed. (Beaton, MPCA)
R. EPA agrees that this analysis would have been informative. We did pre-
13 pare cost estimates of both the present worth savings and total home-
owners savings resulting from one level of water conservation if used
with the Facilities Plan Proposed Action. Many other means of water
conservation could have been evaluated with any of the alternatives. We
believe the analyses presented adequately made the point that many
analysts have substantiated, i.e., that water conservation pays.
C. Calculations of cost-effectiveness involving replacement of existing
14 fixtures should be based on full replacement cost, not on the difference
between standard and water-conserving fixtures. (Beaton, MPCA)
R. If fixtures have to be replaced immediately in order to acheive the
14 objectives intended, full replacement cost should be used. In our pre-
sent worth analysis of flow reduction for a centralized alternative, the
objective does not have to be met immediately. Fixtures can be replaced
any time during the 20-year design period as rooms are remodeled or
existing fixtures wear out. In that analysis, only the incremental cost
is appropriate.
C. The cost data are not sufficiently detailed to show the inherent assump-
15 tions. (Beaton, MPCA)
R. Design and costing assumptions were published in Appendix K of the DEIS.
15 This appendix outlined specifications for spray irrigation, rapid infil-
tration, a prefabricated contact stabilization plant, cluster systems,
and centralized collection for the whole lakeshore. Additionally, the
appendix gave information on data used in the cost-effectiveness analysis
of all alternatives. The limited action and the no action alternative
have been revised for this FEIS. Assumptions used in analyzing these
costs are found in Appendixes C and D.
"Unit costs for various facilities are available in an alternatives
report. This report is as lengthy as the published Draft EIS. It was
45
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not reproduced because of its size and because of the limited audience
for which it would be useful. Copies have been made available since
publication of the Draft EIS to concerned agencies."
C. The Minnesota Pollution Control Agency recommends EIS Alternative 1, with
16 the provision that the decision to upgrade on-site, cluster, install or
retain holding tanks, or install pressure sewers be made based on a site
specific basis. (Beaton, MPCA)
R. As indicated in Section II.B.I of this Final EIS, EPA is on total agree-
16 ment with the need to base technology selection on site-specific informa-
tion. Our best estimate, based on the data we have obtained so far, is
that the measures incorporated in the FEIS's Modified Limited Action
Alternative will be selected.
Please note, and it is an important point, that EPA has not decided to
fund one of the EIS alternatives to the exclusion of all others. Our
decision is to fund an approach to wastewater management that depends on
site-specific information, that depends on the skill of technical per-
sonnel, that depends on local initiative and judgement to select and
implement appropriate technologies for the communities and individual
properties, and that recognizes the need for continuing supervision of
on-site systems. Elements of our decision are the site-specific analy-
sis; technology selection with professional, community, and owner input;
implementation of a responsible management district; and recognition of
the apparent high assimilative capacity of this Study Area's soil and
water resources to accept small-scale wastewater flows.
C. Hydrogen peroxide treatment of drainfields is not justified.
17 (Beaton MPCA)
R. Hydrogen peroxide (^02) can be used to oxidize organic particles which
17 fill and clog small soil pore spaces in soil absorption systems. Because
the soils in the Otter Tail Lake are sandy soils with large soil pore
spaces, this comment is well taken and hydrogen peroxide treatment has
been removed from the Modified Limited Action Alternative.
C. Replumbing costs and some hook-up costs are omitted from some alterna-
18 tives making them appear to be more attractive then they should. (Skuza)
R. Appropriate replumbing and hook-up costs have been omitted from both
18 on-site wastewater management options as well as centralized options. If
they were included, it would change the costs, but not the relative rank-
ing of alternatives in terms of total cost.
On-Site Engineering
C. Data on alternatives are not site-specific enough. It is difficult to
19 relate locations of segments to locations of problems and site limi-
tations. (Beaton, MPCA)
R. See Response No. 8.
19
46
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C. Concern has been expressed that post-EIS detailed field surveys are
20 expected. (Beaton, MPCA)
R. This concern led to the development of "EPA Region V Guidance on Site
20 Specific Needs Determination and Alternative Planning for Unsewered
Areas" found in Appendix A of this EIS. This guidance indicates that the
site-by-site engineering and environmental data base necessary to accom-
plish technology selection as well as detailed design should be accom-
plished as part of Step 2 or 3. EPA is prepared to fund 85% of the de-
tailed site evaluation as a Step 2 or 3 grant (only 75% would be made
available with a Step 1 grant) in order to completely verify that con-
tinued use of on-site systems will be environmentally acceptable in the
Study Area.
C. Assumptions about the number of residences requiring upgrading are
21 arbitrary and made with little or no regard for actual conditions.
(Beaton, MPCA)
R. As noted in Section II-B, the Limited Action alternative has been revised
21 based upon the results of a sanitary survey which investigated on-site
systems at 32% of the homes on the lakeshore. These revisions are based
on a representative sample (32%) of the total of 847 homes on the lake-
shore. This data has given sufficient detail to determine the alter-
natives' feasibility and cost-effectiveness. For those alternatives
which include continued use of on-site systems, EPA estimated factors
subject to uncertainty conservatively high. This has included costs for
the detailed site-by-site analysis as well as operation and maintenance.
The design work for the Modified Limited Action Alternative will be
totally dependent upon the actual conditions that the site-by-site analy-
sis uncovers.
C. Greywater soil treatment systems will be subject to the same site limita-
22 tions as standard soil absorption systems. Therefore, use of greywater/
blackwater separation will rarely provide any advantages that outweigh
the cost or inconvenience of alternative toilets or black water holding
tanks. (Beaton, MPCA)
R. Greywater treatment systems do not pose problems of potential nitrate
22 contamination of drinking water and are thus useful in situations where
that is a concern. Based in part on comments received on the DEIS, the
limited action alternative has been revised and includes only a small
percentage of greywater/blackwater separation. The approach now proposed
in the limited action alternative is based on local data regarding per-
formance of existing systems. The majority of systems around the lakes
in the Service Area are operating satisfactorily. Upgrading of on-site
systems with elevated sand mounds, shallow placement systems, standard
septic tank/soil absorption systems, as well as greywater/blackwater
separation will provide satisfactory service for the life of the project.
C. While flow reduction is highly appropriate for holding tanks and existing
23 systems which cannot be enlarged, it is not clear that it should be
practiced in cases where construction of new drainfields in "light" soils
is contemplated. (Beaton)
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R. As the commentor notes flow reduction is desirable in areas of limited
23 hydraulic treatment capacity. This includes instances of overloaded
centralized collection and treatment systems, holding tanks as well as
greywater/blackwater systems, or elevated mounds in areas of seasonal
high water table where groundwater effluent mounds may reach the ground-
surface. Flow reduction is still desirable for a notable percentage of
the lakeshore area. Additionally, the spring septic snooper survey found
a one-to-one correlation between permanent residences and effluent plumes
entering the lake. With the high rate of permeability in many of the
study area soils, it would still be desirable to practice water con-
servation to limit the potential of effluent plume breakthrough into the
lake.
C. Already thousands of dollars have been spent on EPA reports and engineer-
24 ing reports. If even a fraction of this money had been used for a
door-to-door check on the status of individual systems we would all be
far ahead right now. (Talsness)
R. This EIS is being conducted to evaluate the impacts of the original
24 Facility Plan Proposed Action as well as alternatives to that plan. In
order to evaluate alternatives, investigation had to be made as to what
existing conditions are in the service area and what the assimilative
capacity of the soils are for on-site wastewater treatment. Only when
this data was in hand could viable alternatives be developed. This data
has led to the selection of the modified limited action alternative which
would result in a saving in total present worth of the project of 55%
over the original cost of the project. When translated to an average
annual user charge, this means that a homeowner would pay $102 per year
instead of $350 per year for the Facility Plan Proposed Action.
The next step of the project is the site-by-site work necessary to con-
duct designs for individual homes. This step could not have been reached
until the other alternatives had been screened out. The cost for this
site-by-site evaluation is included in the present-worth cost mentioned
previously and will be funded with 85% Federal grants and 9% state funds.
Thus the cost to Otter Tail Lake homeowners of 6% of the proposed action
should not burden local homeowners. EIS money has already been used for
a check of approximately 32% of existing systems the basis of our alter-
native design.
C. The EIS is not complete without detailed documentation of need on a
25 house-by-house basis. (Hall)
R. The data collected on Otter Tail Lake's on-site systems is more extensive
25 than is ever available for communities of this size. EPA recognizes that
additional observation and analysis of these systems may alter our under-
standing of their use and their effects on the environment. However, it
is the Agency's judgment that changes, base upon new data, in the recom-
mendation for EIS Alternative 6 will be changes in detail, not in con-
cept.
The Agency is prepared to fund 85% of the detailed site evaluation as a
Step 2 or 3 grant (75% if conducted with a Step 1 grant) in order to,
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first, provide necessary information for site specific facilities design
and, second, verify or modify our conclusion that continued use of on-
site systems will be environmentally acceptable in the Study Area.
C. Disposal methods for black water should be described. (Hall)
26
R. Blackwater from on-site holding as well as septage is currently being
26 disposed of by either land application or disposal at lagoons at local
sewage treatment plants. This method is currently acceptable and also
suitable for all future needs (by phone, Mr. Bill Kohler, Otter Tail
County Department of Land and Resources Management to Mr. Edward Wandelt,
WAPORA Inc., 24 July 1980).
C. If my property is inspected and found to be operating properly, I won't
27 get a grant to upgrade my system. What if it has a problem two years
from now, will I have to pay for that myself? (Anonymous)
R. Yes. However, if the site analysis steps listed in this EIS are fol-
27 lowed, we expect that any system liable to fail within this short a
period will be recognized and will be eligible for upgrading. It may be
possible to keep the grant open for amendment for two years after
construction to guard against sush likely contingencies.
Funding/Eligibility
C. Clarify eligibility of seasonally used on-site systems for Federal
28 funding. (MPCA)
R. About the same time that the Draft EIS went to press, EPA Headquarters
28 issued Program Requirements Memorandum 79-8, which states:
Perpetual or life-of-project easements or other binding covenant
running with the land affording complete access to and control of
wastewater treatment works on private property are tantamount to
ownership of such works.
Therefore, seasonally used, on-site systems can qualify for funding.
USEPA headquarters has also issued a recent memorandum (16 July 1980)
indicating that a county ordinance giving such access and control would
also be considered equivalent public ownership.
C. Minnesota currently will fund collector sewers. (Skuza, Ulteig Engineers)
29
R. This is correct. The MPCA currently provides 15% funding for conven-
29 tional collector sewers and 9% funding for alternative seweage collec-
tion systems as long as they are eligible for Construction Grants Funding
under Program Guidance Memorandum 78-9.
49
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C. The cost to the homeowners of $156 per year for the Limited Action Alter-
30 native is not justified by the 3% phosphorus contribution to Otter Tail
Lake from septic tank systems.
R. The cost to the homeowner has been lowered in the Modified Limited Action
30 Alternative and is now $102 per year. The EIS acknowledges that the
overall lake water quality will not change markedly with the introduc-
tion of wastewater collection and treatment technology. However, the EIS
does document a clear need due to the recurrent problems in 11% of the
systems and on an intermittent basis with approximately 20%. These
malfunctions represent a sufficient water quality and public health
problem. EPA and Minnesota PCA have determined them to be grant eligible
for upgrading and replacement as well as for the construction of cluster
systems for resort areas.
C. Does the 94% state and Federal funding apply to newly constructed on-
31 site systems or just to existing system? (Sutherland)
R. Federal participation for on-site wastewater management only applies to
31 homes constructed prior to December 1977. All other homes will be
excluded from Federal Construction Grants funding.
Implementation/Management
C. Suggest decision include firm committment from local authorities to
32 require flow reduction devices, and pass special ordinances to protect
surface and groundwaters from degradation. (Lisella - US Department of
Health, and Welfare)
R. These is currently no mandatory water conservation program in Otter Tail
32 County. The County has the power to do this if they passed an ordinance
or modified local plumbing codes to require certain water-conserving
plumbing devices for new homes. To our knowledge, no legal means exists
for mandatory retrofitting of existing dwelling units with flow-conserv-
ing plumbing fixtures. EPA supports the use of flow reduction devices
and nonstructural water conservation measures where justified for water
quality or economic reasons. In addition, some water conservation de-
vices could be distributed on a voluntary basis.
C. Minnesota Pollution Control Agency (MPCA) will not accept maintenance of
33 on-site STEP or grinder units by the homeowner. (MPCA)
R. Under the management alternative recommended in the Final EIS, STEP and
33 grinder pump units would be maintained by the Applicant or his agents.
C. The EIS should recommend a detailed management plan, not just describe
34 a range of management functions to be performed and list management
questions to be answered. (MPCA)
R. In regard to funding privately owned on-site systems, current EPA regu-
34 lations (40 CFR 35.918-1) require that
"...the grant applicant shall:..Certify that such treatment works will be
properly installed, operated, and maintained and that the public body
will be responsible for such actions."
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This requirement also applies to publicly owned on-site systems.
Within this limitation, communities have a wide range of options avail-
able. Many of these options were discussed in he Draft EIS, Section
III.D.2. Three additional topics and their interrelationships are dis-
cussed in the Final EIS. They are: risk, liability, and scope of the
Applicant's responsibilities.
To illustrate the range of approaches the Applicant might take, three
management scenarios are described in the Final EIS, including minimum
management requirements, comprehensive wastewater management, and water-
shed management. The EIS recommends adoption of the Comprehensive Waste-
water Management Alternative for Otter Tail Lake. In this approach, all
buildings within the district's service area boundaries would be in-
cluded. At a minimum each building's wastewater system would be covered
in the site specific analysis, and would be inspected at intervals.
Owners or residents of each building would be responsible for a user
charge to repay their share of necessary operating costs. The local debt
for construction of each system can be directly assessed to individual
homeowners, as in the Minimum Management scenario, or they could be
funded as long-term debt.
This approach should identify all wastewater generation, treatment, and
disposal problems in the service area, and should ensure that future
problems are minor or short-lived. In contrast to the Minimum Management
scenario, the higher level of responsibility resulting from this approach
would allow the authority greater discretion in sharing liability for
facility operation with the resident or building owner.
C. The EIS should clearly specify the nature of variances recommended.
35 Granting of variances is within the purview of the County. (MPCA)
R. The following design recommendations made in the Final EIS may require
35 a variance from the current Shoreline Management Ordinance: dosed sand
mounds and dosed shallow placement drainfields or beds specified in high
groundwater areas. The Final EIS recommended that existing dwelling
units which have no demonstrated problems with on-site wastewater manage-
ment systems other than inadequate separation distances be exempted from
being abandoned under authority of the Shoreland Management Act.
C. County Shoreland Management Ordinance and a history of variances granted
36 should be included in the Final EIS. (MPCA)
R. The Shoreline Management Ordinance is readily available from the Otter
36 Tail County Department of Land and Resources. Malcolm Lee of the
Department of Land and Resources stated that his agency does not give
variances for new construction because current law does not allow it.
C. Enforcement of the sewage disposal code is too inflexible. Many property
37 owners have decided to live with their existing systems, knowing that
they are polluting, but they do nothing rather than attempting to work
out a partial solution with the County. (Talsness)
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R. The Shoreline Management Ordinance and the Department of Land and Re-
37 sources do make allowance for existing systems that are not in com-
pliance. A property owner has the alternative of installing a holding
tank, drilling a new well to 50 feet depth, connecting to a cluster
system, or replacing the existing system with an acceptable ST/SAS which
may include alternative systems such as dosed sand mound systems.
C. As an individual involved in this project, I would like to see the Otter
38 Tail County Department Land and Resources Management take over and
administer this project. In the end we can get the job done better and
more cheaply if we can do it locally. (Smith)
R. See response to comment #39.
38
C. At the public meeting in August, you recommended that a wastewater man-
39 agement district be set up. Now you are saying that the Otter Tail
County Department of Land and Resources Management would administer the
alternative. What is the difference? (Mickelson)
R. Under the Shore Land Management Act, the Department of Land and Resources
39 Management already has all of the authority necessary for inspection and
maintenance that such a district would need. Therefore, they are an
ideal group to manage on-site systems for the area.
C. What is going to be done about the 95+ percent of the phosphate that
40 doesn't come from septic tanks? (Abbott)
R. See response to comment #41.
40
C. Commercial fertilizers probably contribute more nutrients to lakes than
41 our septic tanks, yet no one controls that. (King)
R. The concern about the other sources of nutrient, nitrogen and phosphorus
41 to surface water bodies of the state have been a concern of both the
Federal government and the state for some time. The State of Minnesota
Pollution Control Agency is just concluding a three-year-long study of
nonpoint source pollution runoff from a variety of sources: urban run-
off, rural runoff, feedlots, pesticides, and a whole host of other kinds
of problems that have not been dealt with in the past.
The MPCA has proposed a program to address these kinds of sources, and in
particular the problem of agricultural runoff and the nutrients which
find their way into surface waters of the state. It is recommended to
continue dealing with those through the Soil Conservation Service and the
local watershed districts to accelerate the soil conservation programs
that they have attempted to implement on agricultural land. The basic
philosophy behind this is that if the soil is kept in place on agricul-
tural lands, then the fertilizer and the pesticides are kept on the soil
and out of the water.
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C. There is a law which prohibits the spreading of oil on roadways within
42 1,000 feet of lakes, but there is no control over motorboat oil. (King)
R. A study was conducted five years ago that focused on the problem of
42 water contamination and pollution from outboard motors. The basic con-
clusion was that there was not a significant water quality impact from
the operation of outboard motors. There are sometimes visible oil films
that are short-lived and have had no demonstrated significant long-term
impact on water quality.
C. [Responding to a statement by Mr. Malcolm Lee, Otter Tail County Depart-
43 ment of Land and Resources Management on enforcing the Shoreland Manage-
ment Act] What is your method for enforcing the Act?
R. [By Malcolm Lee] The state law is based on construction requirements,
43 not on performance. It is hard to tell whether a system is working
properly or not. Even if it is working well today, it may not work well
tomorrow. The construction requrements include minimum distances from
the septic system parts to groundwater, to wells, to the house, and to a
lake.
We never give variances to the construction requirements because the law
does not allow this. We could be sued if someone gets sick in a house
where we had given a variance.
Impacts
C. The Draft EIS assessment of project impact on population and land use is
44 inadequate. (MPCA)
R. The year 2000 permanent and seasonal baseline population projections
44 considered the three growth factors influencing future population levels
in the Otter Tail Lake Facilities Planning Area: 1) the rate of growth
or decline of the permanent population; 2) the rate of growth or decline
of the seasonal population; and 3) the potential conversion of seasonal
to permanent dwelling units. The best available information regarding
each of these factors was utilized and resulted in the following methodo-
logy and assumptions:
All lots in the proposed service area that were found to be devel-
opable in accordance with environmental constraints and the provi-
sions of the Otter Tail County Shoreland Management Ordinance were
projected to be "built out" by 2000. The use of this "built out"
assumption was based on the rapid population growth rates in the
four townships and the high levels of residential construction
activity for the area reported in the C-40 Construction Reports. The
additional consideration that nearly the entire Service Area consists
of desirable lakeshore or near-lake properties further supported this
assumption.
The only exception to the assumption that the area would be built out
is Otter Tail Village, where, based on past population trends, it was
projected that no population growth would occur during the planning
period.
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The number of nursing homes, commerical establishments, and restau-
rants was assumed to remain constant.
The population increase attributed to the growth of resort areas was
determined by a telephone survey of resort owners. These anticipated
increases in resort population were translated into dwelling unit
equivalents and subtracted from the control total.
The remaining increase in dwelling units was distributed across the
segments according to the number of developable lots in each segment.
A conversion rate of approximately .5% per year was applied to exist-
ing seasonal residences to reflect the conversion of seasonal to
permanent units resulting from retirement age households. This re-
resulted in 100 seasonal units converted to permanent units during
the planning period.
Smaller household sizes of 2.8 for permanent and 4.0 for seasonal
residences were used to transform the dwelling unit equivalents into
population totals. The smaller household sizes were used to reflect
the decline in family sizes projected to occur both nationally and
in rural areas of Minnesota.
Based on these assumptions and the methodology described above, popula-
tions and dwelling unit equivalent projects for the year 2000 were
developed for each segment and subarea (Table F-2 in the DEIS).
C. Assessment of wetlands impacts are inadequate. (MPCA)
45
R. Wetlands of the Otter Tail Lake Study Area are described thoroughly in
45 Section II.D.2 in the DEIS. Primary and secondary environmental impacts
are discussed in Section V.D.I. Primary impacts to identified wetlands
areas could occur as a result of selection of a centralized wastewater
management option. Detrimental impacts would result because of pipeline
construction activity in wetlands and concomitant filling measure. In
addition, residential development would no longer be restricted by high
groundwater levels.
Many of the wetlands around Otter Tail Lake are shrub wetlands, which are
not protected under state statute. The Modified Limited Action Alterna-
tive and the No-Action Alternative would, however, have minimal impacts
on these areas because of the very high groundwater table, which would
preclude the use of on-site wastewater management.
C. Mitigative measures for economic impacts on permanent residents should
46 be addressed, including specific programs available. (MPCA)
R. The Modified Limited Action Alternative was chosen in the Final EIS for
46 many reasons, including its reduced economic impact to homeowners over
centralized options and the No-Action Alternative. Depending on the
management and financial strategy chosen by the Otter Tail Department of
Land and Resource Management, some permanent residents could be impacted
54
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by requirements for high initial capital outlays. The MPCA has pointed
out that several state assistance programs are available. The Minnesota
Housing Finance Agency administers two assistance programs. The Home
Improvement Grant Program provides outright grants to qualified reci-
pients. The Home Improvement Loan Program provides low-interest loans,
depending upon income.
Socioeconomic
C. The existing Shoreland Management Ordinance of Otter Tail County may
47 provide adequate protection for wetlands and floodplains, provided these
provisions are enforced. A discussion of the historical pattern of
variances granted by the county should be provided. (Beaton, MPCA)
R. The Shoreland Management Ordinance, Otter Tail County, Minnesota, re-
47 quires that all grading and filling in shoreland areas must be authorized
by a special use permit. In the past 9 years, only one permit has been
granted in a wetland area (by telephone, Malcolm Lee Otter Tail County
Land Use Office 24 July 1980). Additionally, the ordinance requires that
development may not occur under three feet above the high water mark.
High water mark is defined as the area where the natural vegetation
changes from predominantly aquatic to predominantly terrestrial. This
area covers not only wetlands, but the majority of the 100-year
flood-plain as well.
C. There is no reason to believe that the demographic and socioeconomic
48 characteristics of the proposed service area are the same as those for
the surrounding townships. (MPCA)
R. The existing information on population, employment, income, poverty
48 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 several Townships in the Study
Area. Consequently, 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.
C. No attempt is made to evaluate the demographic and socioconomic charac-
49 teristics of the seasonal population. This information could be obtained
through a survey of a reasonable sample. (MPCA)
R. The almost complete lack of employment and income data for the seasonal
49 populations is stated on page 81 of the DEIS. The only accurate way to
acquire this type of data is by a special census. This obviously was not
conducted for this EIS. In addition, the Office of Management and Budget
(OMB) in Circular A-40 requires prior approval of any information-gath-
ering by Federal agencies contacting more than nine people. OMB approv-
al time is currently months. EPA will be considering the advisability of
funding special surveys for other rural wastewater projects.
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C. Various assumptions regarding demography have not been justified. (MPCA)
50
R. Various factors for fine tuning the demographic projections have been
50 suggested by MPCA. These include household size, seasonal to principal
occupant conversion rate, number and extent of commercial establishments,
number of developable lots, and resort projections. The Draft EIS used
the best available data and suitable information which could be obtained.
The complete methodology is presented in Appendix F of the Draft. It is
felt that fine tuning of the population projections will not alter the
basic conclusions reached in this Final EIS.
Many of the points that were made by MPCA in regard to population pro-
jections and socioeconomic data point out the inherent difficulties for
making accurate projections in rural areas where databases are much
smaller than urban areas. These types of problems are currently being
considered in the Generic EIS on rural wastewater management currently
being prepared by EPA.
The EIS Process
C. MPCA expects that EIS to be sufficiently complete so that the project
51 can go to Step 2, the design phase, without further delay. (Hall, MPCA)
R. The data collected on Otter Tail Lake's on-site systems is more extension
51 than is ever available for communities of this size. EPA recognizes that
additional observation and analysis of these systems may alter our under-
standing of their use and their effects on the environment. However, it
is the Agency's judgment that changes, based upon new data, in the recom-
mendation for the Modified Limited Action Alternative will be changes in
detail, not in concept. The Agency is prepared to fund 85% of the
detailed site evaluation as a Step 2 or 3 grant (75% if conducted with
a Step 1 grant) in order, first, to provide necessary information for
site specific facilities design and, second, to verify or modify our con-
clusion that continued use of on-site systems will be environmentally
acceptable in the Study Area.
The Agency feels that the alternatives' feasibility is presented in
sufficient detail to determine cost-effectiveness. For those alterna-
tives which include continued use of on-site systems, EPA estimated
factors subject to uncertainty conservatively high, especially the per-
cent replacement of septic tanks and drainfields. In addition, EPA
reexamined costs for operation and maintenance and for the site-specific
analysis for this Final EIS in more detail and with conservative esti-
mates. Boosting these cost estimates has made no difference in the
ranking of the recommended Alternative. It appears unlikely that addi-
tional improvements in the cost estimates based on actual designs will
alter the rankings either.
To clarify the site-specific work needed, EPA Region V prepared a memor-
randum clarifying needs documentation procedures (Appendix A). The great
majority of any such work should take place in Step 2 or 3. For these
reasons and because of the 50% savings to the applicant, EPA will fund
the site-specific evaluation as a Step 2 or 3 grant. If funded in Step 3
the evaluation could easily be combined with the installation of access
pipes or septic tanks.
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C. If the proposed alternatives undergo major changes, we suggest EPA hold
52 another hearing to discuss these. (Hall-MPCA)
R. The recommended alternative in both the Draft and Final EIS remains the
52 same. Although EPA's estimate of the numbers of systems requiring re-
placement and the overall costs have changed somewhat, it is felt that
this is not a major change.
C. Why was the public hearing on the Draft EIS held during the winter when
53 6,340 of the 7,434 residents were not here? (Larsen)
R. The hearing was held in January because Federal regulations state that
53 a public hearing be held within a certain amount of time after publica-
tion of the Draft EIS. This hearing was basically the same type of
meeting that was held at the end of August 1979, when all the seasonal
residents were in Otter Tail.
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APPENDIX A
EPA Region V Guidance Site Specific
Needs Determination and Alternative
Planning for Unsewered Areas
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REGION V GUIDANCE
SITE SPECIFIC NEEDS
DETERMINATION AND ALTERNATIVE PLANNING
FOR UNSEWERED AREAS
I. Objective
The objective of this guidance is to simplify fulfillment of the
requirements regarding the demonstration of need for sevage treatment
associated with the application of Program Requirements Memorandum
(PRM) 78-9, "Funding of Sewage Collection System Projects," and PRM
79-8, "Small Wastewater Systems." This guidance is written particu-
larly with respect to the needs of small, rural communities and the
consideration of individual on-site and small alternative technology.
It suggests procedures which may be utilized to reduce the time, effort,
and expense necessary to demonstrate facilities needs. It is also
intended to provide guidance pertaining to the selection of alternatives
for a cost-effectiveness comparison. It is not intended to allow indis-
criminate definition of need based upon "broad brush" use of a single
criterion.
The procedure recommended herein may not be the optimum procedure for
all projects. Compliance with this analysis will be prima facie evidence
for the acceptability of the "needs" portion of a proposed plan of study.
If another method is proposed for obtaining and documenting the needs
justification, it is recommended that the grant applicant discuss the
proposed approach with reviewing authorities prior to the submission of
the plan of study and the Step 1 grant application.
This guidance is predicated on the premise that planning expenditures
should be commensurate with the cost and risk of implementing feasible
alternatives for a specific planning area. The guidance further recog-
nizes the complexity of planning alternative technology. It presents
procedures for, and rationally limits, the amount of detailed site
investigation necessary to determine the suitability of alternative
technology for site specific areas within the community, and allows for
a degree of risk inherent to limited data gathering.
II. Goal
The goal of this guidance is Co enable the community to categorize the
residences into three groups. The three groups are those residences
experiencing: (a) obvious sewage treatment problems with clearly defined
solutions, (b) no problem, and (c) exposure to potential problems repre-
senting a planning risk that requires resolution by the acquisition of
original data.
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Region V Guidance
Page 2
III. Criteria for site-specific needs determination
A. Direct evidence that demonstrates obvious need due to malfunctioning
systems includes:
1. Failure by surface (breakout) ponding of filter field discharges
can be identified through direct observations, mailed question-
naires, and remote imagery (infrared photography).
2. Sewage backup in residences can be identified through response
to mailed questionnaires, knowledge of local septage haulers, or
knowledge of local health or zoning officials.
3. Detected sewage effluent or tracer dye in surface water, by
means of site visit or various site effluent detection systems.
4. Flowing effluent pipe detected by remote infrared photography,
site visits, knowledge of local officials, or results of mailed
questionnaires.
5. Contamination of water supply wells (groundwater) can be demon-
strated by sampling and analyses for whiteners, chlorides,
nitrates, fecal coliform bacteria, or other indicators, and a
finding of their presence in concentrations which significantly
exceed background levels in groundwaters of the area or primary
drinking water quality standards. Demonstration of trends
toward groundwater pollution due to malfunctioning systems could
aid in concluding a problem exists.
B. Indirect evidence that may demonstrate inferred need due to limita-
tions of treatment systems includes:
1. Seasonal or year-round high water table considering possible
water table mounding by residential use. Seasonal or annual
water table can be determined by taking transit sightings from
a known lake level, if the dwelling in question is adjacent to
a lake or other surface waters. Elsewhere, Soil Conservation
Service maps may indicate depth to groundwater. If these data
are unavailable, soil borings may be employed during an on-site
investigation described below.
2. Water well isolation distances (depending on depth of well and
presence or absence of impermeable soils). Isolation distances
may be addressed in part by lot size. In cases where a community
water system is installed or is concurrently planned, this
criterion will not be considered. Lots, including consolidated
lots, which are less than 10,000 square feet in area, will be
assumed to have insufficient isolation distances. However,
before this criterion may be used as areawide evidence, a
correlation with results of limited representative sampling
which substantiate water well contamination must be made.
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Region V Guidance
Page 3
3. Documented groundwater flow from a. filter field toward a water
supply well can often override seemingly adequate separation
distances.
4. Bedrock proximity (within, three feet of filter field pipe) can
be assessed by utilizing existing SCS soils maps. If reasonable
suspicion exists that bedrock will be a site limitation and it
cannot be quantified, an on-site investigation may include
representative soil borings as appropriate.
5. Slowly permeable soils with greater than 60 minutes/inch perco-
lation rate.
6. Rapidly permeable soil with less than 0.1 minutes/inch percola-
tion rate. Soil permeability will be assessed by evaluting
existing SCS soils maps and related use limitations data. Should
the data be unavailable, and should other data indicate strong
possibility of permeability-related lot limitations, appropriate
numbers of soils borings may be made during the on-site investi-
gation.
7. While holding tanks, in certain cases, can be a cost-effective
alternative, for purposes of site-specific needs determination,
a residence equipped for a holding tank for domestic sewage
should be considered as indirect evidence of need for sewage
treatment facilities. Location of holding tanks will be
identified through records of local permitting officials, septage
haulers, and results of mailed questionnaires.
8. On-site treatment systems which do not conform to accepted prac-
tices or current sanitary codes may be documented by owners,
installers, or local permitting officials. This category would
include cesspools, inadequately sized system components (the
proverbial "55 gallon drum" septic tank), and systems which
feature direct discharge of septic tank effluent to surface water.
9. On-site systems: (a) incorporating components, (b) installed
on individual lots, or (c) of an age, that local data indicate
are characterized by excessive defect and failure rates, or non-
cost-effective maintenance requirements.
IV. Needs determination for unsewered communities
For projects in which the scope of work is difficult to assess during
the Step 1 application, it is recommended that Step 1 be divided into
2 phases to more effectively allow estimation of the planning scope and
associated costs. Phase I will consist of a review of existing or
easily obtainable data. Phase II will consist of on-site investigation
and representative sampling necessary to confirm assumptions based on
indirect evidence identified in Phase I. Alternatives development for
those lots determined to have need may be completed and incorporated
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Region V Guidance
Page 4
into the facilities plan. Both phases should be addressed in the plan
of study and grant application. This is discussed in greater detail
below.
A. Phase I
The review of existing or easily obtainable data may include the
following as appropriate:
1. A mailed questionnaire regarding each resident's knowledge of
on-site system and its performance
2. Review of soils maps
3. Review of local permit records
4. Lot evaluations to estimate depth to water table (lakeshore
areas)
5. Calculation of lot sizes
6. Remote photographic imagery (e.g., infrared)
7. Leachate detection sensing of ground or surface water in the
area.
This preliminary data will be used to categorize each lot within
the planning area into one of three groups:
1. Obvious-problem
2. No-problem
3. Inconlusive.
The "obvious-problem" group consists of those lots where at least
one criterion of direct evidence of a need (specified on page 2 of
this guidance) is satisfied or where, by summarizing indirect
evidence validated with limited sampling, there exists a high
potential that a problem does exist. (See Phase II Work, On-Site
Investigation, as outlined below.)
The "no-problem" group consists of those lots where there is evidence
that the present system is adequate and functioning properly and
likely to continue to do so with proper cost-effective operation
and maintenance, based upon the review of available information.
The "inconclusive" group consists of the remaining lots where avail-
able information does not substantiate their placement into either
the "obvious-problem" or "no-problem" category.
The next step is to attempt to recategorize the "inconclusive" group
into either group (a) or (b) by making reasonable assumptions based
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Region V Guidance
Page 5
upon the interred evidence criteria noted in Section III.B. The
on-site investigation would also be the source of information on
those lots where information was not previously available.
For example, on-site systems located on lots with apparent continuous
high groundwater and very tight soils could be placed in the "obvious-
problem" category, even though there is no direct evidence of failure.
The on-site investigation, however, should validate the assumption
fay representative sampling to confirm that indeed there is high
groundwater and tight soils in this area and obtain further infor-
mation that this is causing a problem with on-site systems.
In addition, it may be necessary to gather field data on a minimum
number of lots where the evidence is not available to substantiate
the placement of these lots into either the "no-problem" or "obvious-
problem" group.
Indirect evidence, which is based primarily on construction standards,
generally identifies lots which probably do not have adequate on-site
systems. This probability is verified by a small amount of on-site
investigation as explained in Phase II. Indirect evidence does not
identify lots which have no site limitations but which in fact do
not have an adequate operating system. The use of indirect evidence,
alone, may result in the erroneous conclusion that the on-site system
is adequately operating. This situation is especially prevalent in
areas with high percolation rates, where system failure is not evident
to the observer. Thus, a sampling program should consider, to some
extent, lots that exhibit no indirect evidence of need.
B. Mid-Course Review
At the end of Phase I, the results of the Phase I effort should be
presented for review and concurrence before proceeding to Phase II.
The Mid-Course Meeting facilities plan review is an appropriate time
for the presentation and discussion of the Phase I results. Phase II
will consist of on-site investigation and sampling, alternative
development for specific need areas and completion of the facilities
plan.
The following should be considered at the Mid-Course Meeting:
1. It may become apparent during Phase I that on-site alternative
technology systems will not approach the cost-effective solution
for the substantially defined obvious used area. In this case,
a preliminary cost estimate for conventional collection and
treatment should be compared to that for the innovative/alterna-
tive treatment solution. If cost estimates and technical analysis
indicate that the use of alternative technology is not cost-
effective, the analysis may be terminated and a cost-effective
collection and treatment solution developed without proceeding
into the on-site investigation of Phase II. This would also
apply in areas where a substantial obvious need has been
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Region V Guidance
Page 6
justified, where a high concentration of dwellings occur in a
municipality, and where on-site systems would not be a viable
solution because of site limitations. Any such exclusion of
on-site treatment should be clearly quantified and supported by
documentation in accordance with PRM 78-0 and PRM 79-8.
2. The number of lots to be investigated during the on-site evalua-
tion should be reasonably estimated. If the original estimation
of on-site work included in the Step 1 Grant Agreement is found
to be in error at the end of the preliminary evaluation (Phase I),
a request.to amend the grant amount, if necessary, may be sub-
mitted and a grant amendment expeditiously processed provided
there is concurrence at the Mid-Course Meeting.
3. The manner of presenting this data in the Facilities Plan is
discretionary, although it should be clearly apparent to anyone
reading the Facilities Plan upon what basis a given residence
was determined to have or not have a need for wastewater treat-
ment. Should need be demonstrated for a given residence,
sufficient information should be acquired to determine potential
treatment alternatives. (For example, if a residence is deter-
mined to need treatment facilities on the basis of an illegal
discharge of septic tank effluent, additional information will
be required to determine if any limitations to on-site treatment
exist.)
C. Phase II work
Indirect evidence requires reasonable verification in order that a
lot be placed into the "obvious-need" category. This is accomplished
by identifying combinations of indirect evidence criteria that
indicate an increased risk or potential of a problem, and representa-
tive sampling. Sampling results supporting a significantly increased
risk justify placement of a lot into the "obvious-need" category.
For example, an on-site system located on a lot with marginal soils
(i.e., a percolation rate of about 60 minutes/inch) would be con-
sidered a low risk situation. If, however, this same lot has
adjacent lots with direct evidence of malfunctioning systems and has
a short-duration of seasonal high groundwater, for example, the
combining of low risk factors elevates the net risk to a high risk
situation. After representative sampling of these parameters during
the on-site investigation to confirm these assumptions, placement of
all similar lots into the "obvious-need" category can be made.
Representative Sampling Method
The planning of representative sampling should address the following
considerations on the basis of Phase I results:
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Region V Guidance
Page 7
1. Delineate areas that exhibit indirect evidence and/or inconclu-
sive need.
2. Delineate areas, if possible, that exhibit one or more common
limiting physical parameters that may be associated with a
type of indirect evidence of need.
3. Sample to confirm the assumed physical constraint for on-site
sewage treatment or the indirect evidence of need and correlate
with actual occurrence of wastewater treatment deficiencies.
The number of lots, public areas, or rights of way adjacent to
private lots exhibiting inconclusive or indirect evidence of
need that are to be further analyzed normally should not exceed
30% but should be at least 15% of the total lots within a
discrete.area assumed as exhibiting an inconclusive need or
indirect evidence of need. Measurable constraints to sewage
treatment may be: high groundwater and its depth, predicted
duration and recurrence interval, groundwater flow direction
and velocity, depth to bedrock, highly permeable or impermeable
soils that do not allow for treatment, and the physical condi-
tion of existing on-site systems. Sampling may be random or
stratified according to the requriements of the analytical
design selected as appropriate to test the strength of an
assumption. In any event, decisions about what is to be sampled,
the sampling design, and the size of the sample should meet the
test of cost-effectiveness.
4. Water quality parameters that can be evaluted and utilized as
pollution indicators include, but are not limited to: chlorides,
nitrates, phosphate, fecal coliform, surfactants, whiteners, and
other synthetic organics inherent to domestic wastewater.
5. The analysis should be completed and study areas classified as
exhibiting direct evidence of pollution problems, indirect
evidence of pollution problems, the combination of direct and
indirect evidence, and no need. If, after the Phase II analysis
is completed, discrete areas of the Plan of Study Area (POSA)
remain inconclusive as to evidence of need, no need may be
construed for those areas.
V. Planning for treatment alternatives
Based upon data assembled during Phase I and Phase II, residence should
be categorized as follows:
A. Residences having adequate treatment facilities (no-problem).
If a conveyance system determined to be cost-effective to transport
wastewater passes a lot that has no need for sewage treatment,
there will be no limitations on hookups to the sewer. However, a
sewer will not be funded by EPA if the sewer is purposely routed
to areas exhibiting no need.
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Region V Guidance
Page 8
B. Residences not having adequate treatment facilities.
1. Capable of on-site upgrading of septic tank and filter field
(standard system).
2. Capable of on-site upgrading with non-standard on-site treatment.
3. Not capable of on-site upgrading (treatment must be off-site).
Preliminary alternatives to be compared for cost-effectiveness should
include a combination of selective no-action, on-site upgrading, and
off-site treatment alternatives. For each discrete area, the generally
determined generic alternative should reflect the specific need defined
by the common physical limitation of the discrete area.
Standard system ypgrading is defined as expansion of an existing filter
field, construction of a filter field, repair or replacement of defec-
tive components or construction of an entire on-site system in compliance
with approved specifications. This alternative is viable where lot
limitations such as small size or slow percolation would not preclude it.
Non-standard on-site system upgrading may include a mounded filter field,
alternating beds, pressure distribution systems, aerobic systems, sand
filters, and other alternatives permissible under the State and local
code. These should be considered where lot size and water well isolation
distances are adequate, and where other limitations such as high ground-
water and slow percolation preclude standard systems. Off-site treat-
ment such as cluster systems should also be considered in such cases,
and possibly graywater/blackwater separation.
Septic tank replacement should be considered only as necessary. For
purposes of cost-effectiveness calculations, the number of septic tanks
requiring replacement should be estimated on the basis of permits issued
and knowledge of local septic tank pumpers and installers regarding the
type, life, age, and condition of existing installations. Information on
the size and condition of the current treatment systems, gathered during
home-to-home interview surveys, sampling, and inspections, should also
be used. For those systems for which information pertaining to septic
tank conditions cannot be obtained, cost-effectiveness calculations should
should assume 100% replacement.
When a system is found to be malfunctioning on the basis of direct
evidence, information pertaining to lot limitations must also be obtained.
This information should be sufficient to allow for alternatives planning,
and should include all relevant parameters listed under Item III.B of
this memorandum.
Limitations on Planning
Estimation of the cost-effectiveness of on-site treatment in general,
and of particular types of on-site treatment, should be based on infor-
mation acquired during Phase I and Phase II, including any representative
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Region V Guidance
Page 9
sampling. Only the limited amount- of on-site investigation, normally
less than 30% of the total lots that exhibit inconclusive need and/or
indirect evidence of need, should be conducted in the Phase II portion
of the Step 1 grant.
When generic on-site solutions are generally determined for discrete
areas, it is contemplated that it will normally be cost-effective to
specify construction requirements through the use of generic component
designs; plans; performance, quality, and workmanship specifications;
and unit price/estimated -quantity procurement.
Field work necessary to select the design of individual drainfields
including on-site soil borings, percolation tests, surveying, work to
specifically identify present septic tank and soil absorption field
location and inspection is generally to be viewed as Step 3 work. For
practical purposes, site specific design and construction should normally
proceed in tandem on a lot-by-lot and area-by-area basis. The estab-
lishment of a management district's authority must be completed before
a Step 2 or 2+3 award. The development of a management district's
program must be completed before a Step 3 grant award or before authori-
zation to proceed with construction procurement is granted under a
Step 2+3 grant.
VI. Public participation
The following comments are intended to demonstrate how this guidance
relates to the standard requirements for public participation. It is
not all inclusive.
A. A useful "mailing list" may include all owners of residences within
unsewered areas in the planning area and other interested and
affected parties.
The requirement for consulting with the public set forth in 40 CFR
35.917-5(b)(5) will be considered satisfied if questionnaires are
submitted by individuals on the "mailing list."
B. The public meeting required by 40 CFR 35.917-5(b)(6) provides an
opportunity for property owners to be informed of whether or not
they have been found to need wastewater treatment facilities.
During the meeting they can respond to the consultant's determina-
tion of their need status. A map with each lot designated as
no-need, obvious-problem, or inconclusive would be helpful for
public understanding. This meeting could be conveniently scheduled
at the end of Phase I.
C. The final public hearing required by 40 CFR 35.917-5 should be
scheduled at the end of facilities planning.
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APPENDIX B
Modified Limited Action Site Analysis and Costs
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APPENDIX B
Modified Limited Action Site Analysis and Costs
Description of Work To Be Done
The first step in adopting the Modified Limited Action Alternative will
be a site analysis of existing wastewater disposal units and wells in the
Study Area. This site analysis will consist of a sanitary survey, sampling
and metering of wells, soil sampling, inspection and excavation of on-site
systems, and shallow groundwater sampling near lake shores.
A survey team will conduct a sanitary survey of each home, resort, and
business in the Study Area. The team will ask residents to complete a ques-
tionnaire regarding their wastewater systems and wells, will inspect waste-
water systems sites and wells, and will take samples of well water from all
homes or businesses surveyed. The well samples will be analyzed for fecal
coliform bacteria and for nitrates and the results of the survey will be used
to plan work to be done for the remainder of the site analysis.
When the survey has been completed, septic tanks reported or likely to be
undersized will be inspected. The inspection team will locate tanks to be
inspected, will uncover and pump them, and will inspect them for construction,
size, leaks condition, and types of sanitary tees and baffles. The team will
also rod influent lines (noting roots, other obstructions, and collapsed pipe)
and effluent lines (noting these items plus distances to headers, distribution
boxes, bends, and obstructions).
Next, soil samples will be taken for lots with a) past and present sewage
system malfunctions not explained by the sanitary survey or septic tank
inspections, b) substandard soil disposal units and c) soil disposal units for
which there are no records. The samples will be examined to determine soil
texture and color, depth to the seasonal high groundwater level, and water
table depths at suspected areas of soil disposal units and at alternative
disposal sites on or near the lots. The soil sampling team also will probe
the suspected part of the soil disposal unit for depth, size, and type.
After soil samples have been taken, a team of laborers will inspect
subsurface disposal units of those on-site systems having recurrent backups or
past surface malfunctions not explained in prior steps. The team will hand
excavate effluent lines, will hand excavate test pits (to examine size, depth,
and type of soil disposal unit), and will evaluate soil hydraulics (soil
crusting, decomposition and silting in of aggregate, soil distribution) as
reasons for on-site system failures.
Then well water meters will be installed to monitor flows to those on-
site systems with limited hydraulic capacity as determined by the sanitary
survey, soil sampling, and excavation of the soil disposal unit.
Finally, the impact of wastewater disposal on lake water will be investi-
gated by examining shoreline groundwater. The direction of groundwater flow
along lake shores will be determined at \ mile intervals four times over a one
year period. Also, emergent plumes from on-site systems will be detected by
-------
scanning the lake shore with a fluorescent meter; sites having plumes will be
further analyzed using a shoreline transect and 5 samples per plume (to be
analyzed for bacteria and nutrient levels).
The results of the site analyses described above will be used to identify
specific measures that can be taken to correct malfunctioning on-site systems
and polluted wells in the Study Area.
Assumptions
Numbers of
Systems
Number of
Problems
1,134
63
17
1,214
25
806
176
73
27
Step 1-- 284
Sanitary 24
Survey & 308
well sampling
Residences (30% permanent, 70% seasonal)
Resort (3 EDU/system, 14% permanent, 86% seasonal)
Businesses (24% permanent, 76% seasonal)
ST/SAS's with limited hydraulic capacity
ST/SAS's which may have undersized tanks*
Cesspools
Holding tanks
Holding tanks or inadequate soil absorption systems
in 13 resorts
person-days (1,134 residences -f 4/person/day)
person-days (47 businesses and resorts f 2/person/day)
person-days (Sanitarian 23, Sr. Engineer 23, sur-
veyors 205, W.Q. Scientist 21)
Step 2--
Septic
tank
inspection
Additional Costs - well sample test @ $5/sample x 118
150
150
person-days (900 systems T 6/person/day)
person-days (Jr. Engineer 150)
Additional costs - 3-man crew @ $450/day x 150
- waste disposal @ $20/tank x 900
Step 3--
Soil
sampling
Step 4
Disposal unit
inspection
Step 5--
Well water
Meters
364
364
40
243
283
44
44
person-days (60% x 1,214 systems T 4/2 persons/day)
person-days (soil scientist 189, surveyor 175)
person-days (13% x 938 systems -r 3/supervisor/day)
person-days (13% x 938 systems -r \ persons/day)
person-days (Sanitarian 40, laborers 243)
person-days (15% x 1,181 wells
inspections/person/day)
person-days (Surveyor 44)
x 6 inspections -r 24
Total number of systems minus number of septic systems (107) certified
according to the County Office of Land & Water Resource permits minus
number of other problem systems.
-------
Additional costs - Meter installation @ $175/meter x 177
Step 6-- 20
Shallow 80
Groundwater 100
Sampling
person-days (10 days x 2 persons for scan)
person-days (80 plumes -r 2 plumes/day x 2 persons)
person-days (Sanitarian 25, W.Q. Scientist 50,
Surveyor 25)
Additional cost - Nutrient analyses @ $15/series x 5/plumes
x 80 plumes
Step 7-- 40
Shore ground- 40
water hydro-
logy survey
Step 8-- 260
Supervision,
documentation,
clerical
Labor Summary
Sanitarian
Sr. Engineer
Jr. Engineer
Soil Scientist
W.Q. Scientist
Surveyors
Laborers
Secretary
OTCDLRM* Costs
Salaries
person-days (5 days/survey x 2 persons x 4 surveys)
person-days (Sanitarian 20, W.Q. Scientist 5,
Surveyor 15)
Work-days (Sanitarian @ 100% including above time,
Sr. Engineer & 25% + 20 days to prepare report,
Secretary @ 100%)
Person-Days Per Step
123
23
23
23 150
13 189
21
205 175
308 150 364
Sanitarian @ $25,000/yr
Surveyors @ $ll,000/yr
Laborers @ $12,000/yr x
Secretary @ $12,000/yr
20% fringe benefits
456
40 25
50
44 24
243
283 44 100
x 260 days
x 464 days
243 days
x 260 days
Subtotal
Subtotal
7 8 Total
20 152 260
62 85
173
202
5 76
15 464
243
260 260
40 474 1,763
$25,000
19,630
11,215
12,000
67,845
13,569
81,414
Rent
Office @ $300/mo. x 12 months
$ 3,600
Otter Tail County Department of Land and Resource Management.
-------
OTCDLRM CostsContinued
Service Contracts
Equipment &
Sampling
Summary
Consultant Costs
Direct Labor
Other Direct
Costs
Travel
Summary
Total Costs
OTCDLRM
Consultant
Well sample analysis @ $5/sample x 1,181 $ 5,905
Septic tank inspection - $450/day x 150 67,500
- $20/tank x 900 18,000
Well water meters @ $175/meter x 177 30,975
Plume sample analyses @ $15 x 5 x 80 6,000
Fluorescent meter $14,000
Groundwater flow meter 4,000
Field sampling equipment 2,000
Paper supplies 2,000
Cameras & film for documentation 3,000
2 vans @ ($350/mo + $120 gas-oil/mo) x 12 11,280
Salaries $ 81,414
Rent 3,600
Contracts 128,380
Equipment & Supplies 36,280
Total OTCDLRM $249,674
Sr. Engineer @ $35,000/yr x 85 days $11,440
Jr. Engineer @ $20,000/yr x 173 days 13,310
Soil Scientist @ 25,000/yr x 202 days 19,420
W.Q. Scientist @ 25,000/yr x 76 days 7,310
$51,480
Report & Reproduction 150
Communication 1,000
Graphics, report preparation 1,500
$2,650
House rental for office, sleeping x 12 mo's 6,000
Other per diem @ $20/day x 536- 10,720
65 RT x 250 miles x $0.20/mile 3,250
$19,970
Direct labor x 3.0
Other direct costs
Travel x 1.2
x 1.2
Total consultant
Total
154,440
3,180
23,964
$181,584
$249,674
181,584
$431,258
Assuming that the consultants work 5 days/week.
-------
APPENDIX C
No-Action Alternative Present Worth Analysis -
Otter Tail Lakes Project Area
-------
APPENDIX C
No Action Alternative Present Worth Analyis -
Otter Tail Lakes Project Area
Assumptions
Existing Systems* -
Sanitary Survey &
followup
Future Systems0
Salaries
Construction Costs
Operation &
Maintenance
(0 & M)
Costs
Salvage
Values
Sanitarian - 250 days to survey each home,
resort and business in the area (1,134 residences -t
5/day, 47 others * 2/day)
Sheriff - 148 days to serve notice to owners of
systems needing repair or replacement (1,181 x 1 hr/
service)
Sanitarian - 376 days to permit replacements (653
systems x 4 hr/permit, 25 clusters x 16 hr
Add 389 ST access pipes*
Replace 270 ST's*
Continue use of 73 existing HT's*
Replace 73 systems with HT's*
Replace 56 systems with ST/SM's*
Replace 326 systems with ST/cluster DF's*
Connect 27 resort systems (81 EDU) to cluster DF's*
Replace 527 wells*
Add 361 ST/SAS's
Add 229 ST/SM's
Add 15 resort systems (46 EDU) to cluster DF's
Sanitarian - 887 days to permit new systems
[(590 systems + 1 cluster) x 12 hr/permit]
Sanitarian - $18,000/yr
Sheriff - $18,000/yr
$ 100/ST access pipe
450/ST & HT
1270/ST/SAS
8850/ST/dosed SM
5350/EDU for cluster systems
700/50' well
$ 60/ST pumping (70% once/5 yrs., 30% once/3 yrs.)
60/HT pumping (70% 12 yr., 30% 55/yr.)
55/yr./dosed SM for electricity & pump maintenance
55/yr./residence for cluster system DF's
50 year useful life for STs, HTs, ST access pipes
20 years for all other items
$2,124/residence for cluster systems
* Includes 1,134 Residential, 17 Business, and 63 Resort Systems
By staff of the Otter Tail County Dept. of Land/Resource Mgmt.
o ST-septic tank, SAS-soil absorption system, SM-sand mound
HT-holding tank, DF-drainfield
# Estimated repairs shown are based on Shoreline Management Act
regulations
-------
Costs
Capital
Item Costs
Preliminary Work:
Sanitarian @ $18,000/yr x 626 day 43.3
Sheriff @ $18,000/yr x 148 days 10.2
Cluster system design - 26 clusters 130.0
SUBTOTAL 183.5
Existing Systems:
389 ST access pipes 38.9
270 new STs 121.5
73 existing HTs -0-
73 new HTs 32.8
56 new ST/SMs 495.6
326 new ST/cluster DFs 1,744.1
81 EDU ST/cluster DFs 426.2
527 wells 368.9
SUBTOTAL 3,228.0
Future Systems:
Sanitarian @ $18,000/yr x 887 day
361 ST/SASs
229 ST/SMs
46 EDU ST/cluster DFs
SUBTOTAL
Total - as of 1980
- increment 1980-2000
Present Worth
3.07/yr.
22.92/yr.
101.33/yr.
12.30/yr.
139.62/yr.
3,411.5
139.6/yr.
($ x 1000)
O&M
Costs
-0-
-0-
-0-
-0-
5.60/yr.
3.89/yr.
109.06/yr
109.06/yr.
3.89/yr.
22.62/yr.
5.62/yr.
-0-
259.74/yr.
-0-
0.26/yr/yr.
0.79/yr/yr.
0.16/yr/yr.
1.21/yr/yr.
259.7 /yr
1.21/yr/yr.
Salvage
Value
-0-
-0-
-0-
-0-
23.3
72.9
-0-
19.7
15.1
692.4
167.8
-0-
991.2
-0-
130.0
82.4
97.7
310.1
991.2
310.1
Present Worth Cost =3,411.5 + 10.9099 (399.3) + 81.155 (1.21) - 0.2772 (1301.3)
= 7,505.3 (65/8%) TPW=7505.3
-------
APPENDIX D
Modified Limited Action Present Worth and User Charges -
Otter Tail Lakes Project Area
-------
APPENDIX D
Modified Limited Action Present Worth and User Charges -
Otter Tail Lakes Project Area
Assumptions
Existing Systems"* 938 ST/SAS's
176 Cesspools
73 HT's
Future Systems"'
Labor
Add 389 access pipes to ST's
Replace 525 ST's
Add 25 flow reductions + dosed SM's
Replace 71 with ST/SAS's
Replace 35 with ST/shallow DF's
Replace 35 with ST/dosed shallow DF's
Replace 35 with ST/dosed SM's
Add 73 flow reductions
Add 8 ST/shallow DF's (greywater)
Add 26 ST/dosed shallow DF's (greywater)
Add 26 ST/dosed SM's (greywater)
27 Resort Systems Join to 13 cluster system DF's (81 EDU)
361 ST/SAS's
115 ST/dosed shallow DF's
114 ST/dosed SM's
15 ST's joined to cluster systems (46 EDU)
Sanitarian to provide administrative, engineering, and
planning services - 260 days/yr
Surveyors to sample wells and lake shore groundwater during
summer - 2 @ 60 days/yr
Soil Scientist on retainer to inspect sites of proposed
systems - \ day/site - 15 days/yr
Secretary - halftime - 130 days/yr
Construction Costs $ 100/ST access pipe
450/ST
1,010/flow reduction
8,400/dosed SM
Operation &
Maintenance
(O&M) Costs
1,270/ST/SAS
1,270/ST/shallow DF
3,270/ST/dosed shallow DF
8,850/ST/dosed SM
5,350/EDU for cluster systems (less $265 if ST not needed)
$ 5/yr/residence for flow reduction devices
60/ST pumping (70% once/5 years, 30% once/3 year)
60/HT pumping (13 x 5 pumpings/yr, 12 x 3 pumpings
48 x 1 pumping/yr)
* ST - septic tank, SAS - soil absorption system, SM - sand mound, DF - drainfield,
EDU - equivalent dwelling unit.
Includes 1,134 residential, 17 business, and 63 resort systems.
o Includes 572 residential and 33 resort systems.
-------
D
Salvage Values
55/yr/dosed DF for electricity and pumping maintenance
55/yr/residence for cluster system DF's (ST separate)
8/well water sample to test for bacteria-nitrate
(1/5 yr/well except 2/yr/3 wells at clusters)
15/shallow groundwater sample to test for bacteria and
nutrients (50 tests/yr 3 samples/test)
50 year useful life for ST's, HT's
20 years for dosing pumps, DF's, SM's, flow reduction,
$2,124/residence for cluster systems if existing ST's used,
1965/residence for cluster systems if existing ST's used.
Salaries
Costs
$25,000/yr Sanitarian's]
$12,000/yr Secretary's >
$12,000/yr surveyor's J
$325/day Soil Scientist's
Capital
Item Costs
Existing Systems:
389 ST/SAS's - Add Hatches 38.9
524 ST/SAS's - Replace ST's 235.8
25 ST/SAS's - Add Flow Redl, SM's 235.3
71 Cesspools - ST/SAS's 90.2
35 Cesspools - ST/shallow DF's 44.4
35 Cesspools - ST/dosed sh. DF's 114.5
35 Cesspools - ST/dosed SM's 309.8
13 HT's - Add Flow Reduction 13.1
8 HT's - Add Flow Reduction +
ST/Shallow DF 18.2
26 HT's - Add Flow Reduction +
ST/dosed shallow DF 111.3
26 HT's - Add Flow Reduction +
ST/dosed SM 256.4
81 EDU ST/Cluster Systems 426.2
Subtotal 1,894.1
Future Systems:
361 ST/SAS's 22.92/yr
115 ST/dosed shallow DF's 18.80/yr
114 ST/dosed SM's 50.44/yr
46 EDU ST/Cluster Systems 12.30/yr
Subtotal 104.5/yr
+20% fringe benefits
($ x 1,000)
O&M*
Costs
Salvage
Value
5.60/yr
7.55/yr
1.86/yr
1.02/yr
0.50
2.43/yr
2.43/yr
3.90/yr
23.3
141.5
-0-
19.2
9.4
9.5
9.4
-0-
0.82/yr 2.2
4.10/yr 7.0
4.10/yr 7.0
5.62/yr 167.8
39.93/yr 396.3
0.26/yr/yr
0.40/yr/yr
0.40/yr/yr
0.16/yr/yr
1.22/yr/yr
130.0
41.4
41.0
97.7
310.1
Operation and Maintenance.
-------
Salaries:
Sanitarian @ $25,000/yr x 260 day
Surveyors @ $12,000/yr x 120 day
Secretary @ $12,000/yr x 130 day
20% Fringe Benefits
Subtotal
Subtotal
Retainer:
Soil Scientist @ 325/day x 15 day
Water Sample Analysis:
Wells @ $8/sample x 312/yr
Wells @ $8/sample x 6/yr/yr
Shallow Groundwater @ $15 x 3 x 50
Subtotal
Rental:
Office @ $300/mo x 12
Office supplies, telephone, etc.
Van lease, gas & oil
Small motorboat - 4 wks/yr
Subtotal
E&A Costs:
Contingencies - 9% of 1980 costs
Site Analysis
Cluster System Design"
-0-
-0-
-0-
-0-
-0-
-0-
25.00/yr
5.54/yr
6.00/yr
36.54/yr
7.31/yr
43.85/yr
-0
-0-
-0
-0'
-0'
-0'
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
170.5
431.3
70.0
671.8
4.88/yr
-0-
2.50/yr -0-
0.05/yr/yr -0-
2.25/yr -0-
-0-
-0-
-0-
-0-
4.75.yr -0-
0.05/yr/yr
3.60/yr
2.00/yr
6.00/yr
0.40/yr
12.00/yr
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
Total - As of 1980
- Increment 1980 - 2000
Present Worth
2565.9
104.5/yr
105.4/yr 396.3
1.27/yr/yr 310.1
($ x 1,000)
Present Worth Cost = 2565.9 - 10.9099 (209.0) - 81.155 (1.27)
= 4763.1 - 0.2772 (706.4)
Assumptions
Number of Units
1,134 Residences
30 Resorts
17 Businesses
1,181 Total
* Assuming that several (~ 5) are designed at the same time.
-------
D
Federal Funding 85% of cost of site analysis & capital cost of
replacement systems
State Funding 9% of above cost
Debt Retirement 30 year loan @ 6 7/8%
1980 capital costs only
20% debt reserve
User Charges (as of 1980)
($)
Debt Retirement - 0.07958 (6%) ($2,565,900) 12,252
Debt Reserve - 20% (11,917) 2,450
Annual O&M 105,400
Total annual local cost $120,102
User charge = Total annual local cost/number of units
= $102,102 * 1,181 = $102
-------
APPENDIX E
Septic Leachate and Groundwater Flow Survey -
Otter Tail Lakes, Minnesota, September 1979
-------
SEPTIC LEACHATE AND GROUNDWATER FLOW SURVEY
OTTER TAIL LAKE, MINNESOTA
September, 1979
Prepared for
WAPORA, Inc.
Washington, B.C.
Prepared by
K-V Associates, Inc.
281 Main Street
Falmouth, Massachusetts 02540
-------
TABLE OF CONTENTS
Page
1.0 Introduction 1
2.0 Methodology 1
2.1 Sample Handling 2
2.2 Leachate Detector Calibration 3
2.3 Groundwater Flow Measurements 3
3.0 Comparative Results 4
4.0 Groundwa ter Flow Determinations 12
5.0 Nutrient Transport Comparisons 15
6.0 Cone lus ions.... 18
References 20
Appendix 21
-------
-1-
1.0 INTRODUCTION
During September 1979, K-V Associates performed a septic leachate
survey along the shorelines of Otter Tail Lake in Otter Tail, Minnesota.
The field investigation determined the position and frequency of plume
discharges into open water, as opposed to discrete through-the-ice
sampling conducted during a prior winter survey (KVn, 1979). Only
Otter Tail Lake was examined in the September study; the satellite lakes
were not included. Groundwater direction and flow rates were determined
at twenty-eight beach front measurement sites. The resultant vectors
were plotted to give better definition to shallow groundwater infiltration
and exfiltration patterns around the Otter Tail Lake shoreline. Ground-
water inflows correlated well with plume eruptions.
2.0 METHODOLOGY
The field team of two scientists performed the continuous shore-
line leachate scans in a counter-clockwise direction around Otter Tail
Lake. The basic equipment platform was a 14-foot aluminum skiff with
small outboard. Portable equipment included the battery-powered leachate
detector instrument, hand-driven well points and plastic water sampler
and filtration apparatus.
As a routine, the team first surveyed each lake with the leachate
detector gear, taking appropriate center and background discrete water
-------
-2-
samples from areas showing no obvious indications of pollution. At
those points along the shore where the instrument recorded a significant
event above background, the crew secured surface and groundwater samples
while charting location and logging any supporting visual observations
of the local surroundings. The team walked or motored the boat around
the lake within 15 feet of shore in shallow water. Specific conductance
of each sample was measured on the boat as each sample was prefiltered
and bottled. Each groundwater plume location was profiled vertically
by conductivity with at least two groundwater sampling depths taken for
each plume in search of local maximum conductivity level characteristic
of core centers. Relative fluorescence and conductivity were continuously
plotted on separate strip recorders with positional cross-references to
detail maps of the lake areas.
After completing the leachate survey of a lake, the team returned
for bacterial sampling of selected plumes and surface flows, and took
groundwater flow data in the beach sand at distributed points around
the lake.
2.1 Sample Handling
Both ground and surface water samples were collected in the field
at plume locations during the septic leachate survey. Samples were
filtered to .45 jum and acidified to pH 2. The samples were kept
chilled and shipped to WAPORA, Inc. in Cincinnati, Ohio for nutrient
analyses.
-------
-3-
Additionally, bacterial water samples were collected in sterilized
glass bottles at selected plume locations, stream inflows and in canals.
These samples were shipped within 24 hours of collection to the Environ-
mental Protection Laboratories, Inc. in St. Cloud, Minnesota to be analyzed
for fecal coliform bacteria content.
2.2 Leachate Detector Calibration
The shoreline scanning work day began with calibration of the
septic leachate instrument. Two solutions were required: the first, a
blank sample drawn from an unaffected central portion of the lake; and
the second, a sample of New York Mills Sewage Treatment Lagoon effluent.
Calibration was by method of additions, a 27. addition of effluent to center
water being scaled to cover 24 percent of full meter span for each channel.
Static syringe injection was employed to introduce solutions to the sensing
chamber.
2.3 Groundwater Flow Measurements
The survey team utilized the K-V Associates, Inc. Model 10 Dowser
groundwater flow meter. To obtain flow measurements, shallow holes were
dug to groundwater along sandy shores at spaced intervals around the
lake. The sensor unit of the small probe head was inserted about three
inches into loose saturated sand substrate. The battery-powered unit
required about three minutes to give a digital indication of flow velocity
and direction. The unit was calibrated in a simple flow chamber using
local beach sand.
-------
-4-
3.0 COMPARATIVE RESULTS
This survey was carried out as a means of comparing the ability of
soils in the area to properly treat domestic wastes under different loading
conditions: heavy loading in summer versus light loading in winter.
Here, comparisons are made between the results of septic leachate surveys
performed in the winter and in summer.
Nutrient analyses of samples taken from Otter Tail Lake during
the two seasons showed evidence of seasonal variability. Measurements
of total phosphorus were very similar in surface waters, but were shown
to be lower in groundwater samples taken during the summer month. Winter
survey mean concentrations were .016 mg/1 for surface waters and .097 mg/1
for groundwater. In summer, .012 mg/1 and .024 mg/1 were the average
concentrations for surface and groundwater samples respectively.
Surface waters were seen to contain only about 1/5 as much ammonia-
nitrogen during the September collection period compared to values obtained
during the March survey. Groundwater samples were shown to be 507. higher
in ammonia in the summer, although high concentrations of 9.0 mg ammonia-
nitrogen per liter in winter and 11.5 mg/1 (#14G) in summer were found
in the vicinity of Walker Lake on the north shore.
Average values of ammonia-nitrogen concentrations for the two seasons
were .26 mg/1 for surface waters and .79 mg/1 for groundwaters during
the winter season and .06 mg/1 for surface waters and 1.26 mg/1 for
groundwaters during the summer survey.
-------
-5-
-------
-6-
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-------
-10-
Table 2. Bacterial count of shoreline water samples around Ottertail Lake,
Ottertail, Minnesota. September, 1979
Station
Bl
B2
B3
B4
B5
B6
B7
B8
B9
BIO
Bll
B12
B13
B14
B15
B16
B17
B18
B19
B20
Fecal Co li form
No/100 ml
0
0
0
10
0
0
0
0
50
20
10
10
0
10
0
0
0
0
0
0
Location
Old Canal, near Long Lake
FN 53 Opposite Long Lake
FN 52 new house
Walker Lake entrance
Ottertail Campground Marina
Ottertail River outlet
Rearing Pond canal (FN 713)
Balmoral Creek
Pelican Bay, under bridge
Ottertail River, old canal entrance
Ottertail River, north end bridge
Ottertail River, new (mid) canal entr
Point just before Ottertail cmpgrnd.
Small bay before Ottertail cmpgrnd.
Nursing home
FN 1056
FN 1051
FN 1197
FN 722
FN 697
-------
-11-
Combined nitrate-nitrite as N (NO -NO as N) showed a similar
increase during winter conditions and a lower level during late summer.
The median NO.-NO. as N concentration in surface water samples was .11
ppm - mg/1 in winter samples compared to .03 ppra - mg/1 (as combined
N0,+N0 -N) in late summer samples. Groundwater samples taken during the
September survey exhibited a median content of .03 ppra - mg/1 NO, + NO - N
compared to a median concentration of .05 ppm - mg/1 for winter samples.
The specific conductance (pmho/cm) of surface water samples was
very close for the two seasons with averages of 311 ^mho/cm in winter
and 346 jamho/cm found in summer. Groundwater sample conductivities
were shown to be about twice as high and to contain a much greater spread
during the summer survey (563 "* 131 in summer vs. 272 - 74 in winter).
During the winter, the rapid inflow of groundwater originating from
snow-melt apparently depresses the specific conductance of near-shore
surface water samples. The summer values did not include a value of
1620 umho/cm found in front of the nursing home on the western shore of
the lake, but did include high values of 920 which was a background
location and 855 ^mho/cm taken from Westvig Canal on the northern end
of the lake.
Levels of fecal coliform bacteria were found to correspond between
the two seasons with most samples indicating few or no organisms per
100 ml. Groundwater erupting plumes have often been found to hold little
bacterial content as the biological particles are filtered out during
passage. Noticeable bacterial instances were related to surface inflows.
-------
- 12 -
One high value was recorded from the winter survey for a sample taken
under the Route 1 bridge over the Otter Tail River. This sample contained
356 organisms/100 ml of water, the highest level found during winter
sampling. The highest level found during the summer was 50 organisms
per 100 ml of water which was seen in a sample taken under the bridge
to Pelican Bay.
4.0 GROUNDWATER FLOW DETERMINATIONS
Measurements were made in the field to determine rate and direction
of shallow groundwater flow around the shoreline of Otter Tail Lake. Flow
was found to be into the lake on the south and east shores and out of the
lake on part of the north and most of the west shorelines. Flow rates
averaged around 5 feet per day, ranging from as high as 16 FPD and as
low as 1 FPD. There appeared to be a general southeast to northwest
movement of water around the lake even though some measurement sites on
the northern shores indicated flow into the lake (see Table 3, Figure 4).
This corresponds to the overall orientation of the Otter Tail River
drainage basin and flow from east to west.
A distinct change in pattern of flow direction was apparent when the
summer results were compared to winter measurements (KVA, 1979). Increased
summer evapotranspiration was probably decreased the height of groundwater
elevations surrounding the lake relative to the lake height, thereby
inducing greater outflow. This was most striking along the northern
shoreline of the western lobe of the lake where all flow measurements
except in the shoreline segment adjacent to the no-name satellite lake
indicated flow out of the lake (exfiltration).
-------
-13-
Table 3. Observed Rates of Groundwater Flow
Station
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Location
FN 326 B
FN 346
FN 357-FN 358
FN 368-FN 369
FN 429
FN 430
pN 440 - 520
FN 560
FN 580
FN 589 - FN 592
FN 611 - FN 612
FN 713
FN 1205
FN 1197
FN 1083
FN 622
FN 687
FN 61
FN 53
FN 47 - FN 48
FN 1240
FN 1064
FN 1035
FN 932
FN 691
FN 725
FN 838
FN 898
Flow
Direction
355° N
280 W
61 NE
258° W
247 W
302 NW
327Q NW
300 NW
270 W
272 W
296° NW
349 N
169° S
279 W
270° W
303° NW
315° NW
288 W
291° W
316 NW
70° E
348° N
224 SW
250° W
305° NW
308° NW
246° W
283° W
Flow Rate FPD
3
6
3
6
4
5
5
5
2
2
3
16
3
3
3
8
9
6
4
7
5
5
8
1
8
5
4
3
-------
-14-
-------
-15-
5.0 NUTRIENT TRANSPORT COMPARISONS
By the use of a few calculations, the characteristics of the sub-
surface wastewater plumes can be compared to previously studied winter
discharges. Using the mean concentration of background samples, the
nutrient concentration found in plumes are first background-subtracted
and then adjusted to the equivalence of full-strength effluent character-
istic of the lake area. Because the well-point sampler does not always
intercept the center of the plume, the nutrient content of the plume is
partially diluted by surrounding ambient background groundwater concen-
trations or downward dispersion of lake water. To correct for the
uncertainty of location of withdrawal of the groundwater plume sample,
the nutrient concentrations above background values found with the ground-
water plume are corrected to the assumed undiluted concentration anticipated
in standard sand-filtered effluent and then divided by the nutrient
content of raw effluent. Computational formulae can be expressed:
a) for the difference between background (C ) and observed (C.)
values:
Ci ' Co -
conductance
TP. - TP = ATP. total phosphorus
i o i
-------
-16-
TN. - TN =ATN total nitrogen (here sum of NO -N,
NH -N, and organic N)
b) for attenuation during soil passage:
0
/AC f\ ATP.
100 xl) -== = 7. breakthrough of phosphorus
\£l>. / A lr_ e
i ' " ef
100 x(7T-) r^rr- = % breakthrough of nitrogen
where: C » conductance of background groundwater (umho/cm)
C. =» conductance of observed plume groundwater (umho/cm)
&C , = conductance of sand-filtered effluent minus the background
conductance of municipal source water (umho/cm)
TP = total phosphorus in background groundwater (ppra - mg/l)
TP, » total phosphorus of observed plume groundwater (ppm - mg/l)
TP , « total phosphorus content of standard effluent (ppm - mg/l)
TN = total nitrogen content of background groundwater, here
° calculated as NC>3-N + NH4-N + org. N (ppm - mg/l)
TN, = total nitrogen content of observed plume groundwater, here
calculated as N03-N + NH4-N + org. N (ppm - mg/l)
TN , » total nitrogen content of local standard effluent (pom - mg/l)
New York Mills effluent was used as a local reference effluent. Previous
analyses indicated a 950:20:4.0 ratio of AC:AN:AP. For background
groundwater a value of 430:.60:.00 was used as reference.
Not only was the frequency of plumes reduced during summer, but
few were found to contain mobile phosphorus. Groundwater plume analyses
taken adjacent to Blanche Lake and no-name lake showed roughly 407.
of the nitrogen content expected in the reference effluent. However,
-------
-17-
phosphorus was 157. or less, indicating considerable renovation of the
wastewater during passage through the soil. Near Long Lake with greater
soil to groundwater depths, the nitrogen transfer had increased to
double that on the lower soil profiles.
Table 4. Calculations of estimated breakthrough of nutrients in ground-
water plumes near certain satellite lakes.
Sample
Number
Blanche Lake
4G
22G
23G
No-name lake
17G
18G
Long Lake
10G
12G
AC
210
40
130
280
50
425
60
Breakthrough*
A N £P N P
1.8 .13
.2 .02
1.2 .01
2.9 <.01
.4 <.01
8.8 <.01
1.1 .01
417.
(247.)
447.
497.
(387.)
987.
(877.)
157.
(127.)
27.
<.87.
(<4.77.)
<.67.
(47.)
*those in parentheses based on a AC, value of less than 100 ;umhos.
Sources of Error
The purpose of the computational formulae is to correct any shallow
groundwater samplings to a closer estimate of conditions which exist
at the core of erupting plumes0 Shallow probing is not necessarily
representative of breakthrough for the entire plume. To increase the
accuracy of evaluation of nitrogen and phosphorus breakthrough, a
vertical profiling of the groundwater sample was performed to locate
nearer core areas. As a worst-case estimate, breakthrough at the center
of plumes could be used, providing that adequate background conductivities
-------
- 18 -
were obtained. For the purpose of reducing errors, calculations based
upon a AC value of 100 or greater should be used.
The samples of effluent from local treatment plants were used as
estimates of the mean concentration of detergent wastewater fluorescence
and of mean dissolved solids loading. The actual increase in conductivity
due to on-site sewerage facility inputs could be much more variable for
individual residences.
6.0 CONCLUSIONS
A septic leachate survey and groundwater flow study was conducted
along the shoreline of Otter Tail Lake during September 1979. The patterns
of erupting plumes from on-lot septic systems were compared to a previous
survey conducted during March 1979 along the same shoreline. The following
conclusions were apparent:
1. During both periods, winter and late summer, the highest frequency
of plumes occurred along shoreline segments adjacent to satellite lakes -
Blanche Lake, Long Lake, Walker Lake, and a no-name lake (northwest shore).
2. The plume pattern was distinctly correlated with groundwater
flow conditions:
a) Opposed to the winter survey, with the exception of a
shore 1500 foot section near the no-name lake, no discharges occurred
from the existing Otter Tail River on the southwest corner along the
entire western and northwestern shorelines until the vicinity of Walker
Lake.
b) Groundwater flow measurements confirmed that during late
summer lake water flowed outwards towards the land (exfiltrated) along
-------
- 19 -
the shoreline from the campgrounds on the southwest shore until Walker
Lake, with the exception of the shoreline segment adjacent to no-name
lake. This represented a substantial increase in exfiltration from the
small section (ca. 3000 feet) on the west shore observed during winter
near the Otter Tail River outflow.
3. As during the winter conditions, the highest frequency of plumes
was found along shoreline segments were infiltration rates averaged 8
to 10 feet per day.
4. Contrary to expectations, the higher frequency of plumes and
greater phosphorus content of affected surface waters occurred during
winter rather than during the more populated summer period.
5. Generally, a higher dissolved solids content occurred in summer
groundwater samples compared to winter samplings. This probably reflects
the influence of low dissolved solids snowmelt inflow during winter as
contrasted with higher evapotranspiration of recharge waters during summer.
6. Chemical analyses of erupting groundwater plumes and their
associated surface water condition indicated lower phosphorus content and
less reducing conditions (indicated by reduced ammonia-nitrogen content)
during summer sampling.
-------
-20-
REFERENCES
EIS, 1979. Draft environmental impact statement; Alternative wastewater
treatment systems for rural lake projects, Case Study No. 5: Otter
Tail County Board of Commissioners, Otter Tail County, Minnesota.
Prepared by the U.S. Environmental Protection Agency, Region V,
Chicago, Illinois and WAPORA, Inc., Washington, D.C.
K.VA, 1979. Investigation of septic leachate discharges into Otter Tail
Lake, Deer Lake, Lake Blanche, Walker Lake, and Round Lake. K-V
Associates, Inc., Falmouth, MA 02540.
Kerfoot, W.B. and S.M. Skinner, Jr., 1979. Septic leachate surveys for
lakeside sewer needs evaluation. Journal Water Pollution Control
Federation (MS submitted for publication).
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.
Winter T.C., L.E. Bidwell, and R.W. Maclay, 1969. Water resources of
the Otter Tail River Watershed, west-central Minnesota. Hydrologic
Investigations Atlas HA-296. U.S. Geological Survey, Reston, VA.
-------
-21-
APPENDIX
-------
Table 5. Supplemental analytical nutrient results for water samples
taken during the March, 1979 survey of Otter Tail Lake (KVA, 1979).
Sample Number NH -N (ppra) NO.-NO -N (ppm)
54G
71S
71G
79S
79G
81S
83S
85S
85G
87S
105G
106S
111G
118G
149G
190G
201 S
201G
207S
309S
310S
310G
314G
326G
333S
340S
443S
448 S
448G
486S
500S
533G
550S
550G
584S
584G
686S
686G
696S
696G
734G
752S
752G
760S
773S
.53
.13
.55
.10
.33
.18
.12
.08
.28
.49
.11
.93
.69
.25
.11
.05
.15
.04
.05
.31
.12
9.0
.25
.49
.84
.64
.50
.50
.19
.11
.13
.69
.25
.31
.42
.20
.35
.12
1.4
.19
2.1
.18
.39
.24
.086
.24
.09
.08
.05
.03
.05
3.8
.33
.02
<.02
.04
.05
.16
.04
.37
.11
-------
Table 5. (cont.)
Sample Number NH -N (ppm) NO -NO--N (ppm)
773G
777S
777G
816A
816A/G
822S
822G
827S
827G
836S
836G
845S
845G
854S
854G
869S
869G
888S
888G
Westvig Canal S
Westvig Canal G
Charney well water G
Balmoral Creek S
Walker Lake Canal S
Center #1 S
Center #2 S
Pelican Bay S
Otter Tail River
Outlet S
Aeres Home Realty
well water G
Otter River inlet
at bridge S
Otter River canal
inlet S
Otter Supper Club G
softened well water
FN 1061 - well water G
.47
.05
.42
.16
.20
.17
.48
.24
.50
.31
.50
.38
1.1
.03
.56
.44
.38
.20
1.5
.87
1.0
.07
.08
.30
1.2
.08
.22
.03
.02
.04
.04
.01
.03
.08
.02
.02
<.02
.11
.02
.09
.07
.08
.04
.07
.06
.04
.03
.04
.06
.22
.05
4.02
<.02
.02
.12
1.7
.09
.08
.96
.30
.26
<.02
<.02
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APPENDIX F
Letters and Written Comments
-------
p
P.O.BOX ^34
BROOTEN,MN.56316
JAN.7,1930
U.S.ENVIRONMENTAL PROTECTION AGENCY
EIS SECTION
ENVIRONMENTAL BRANCH 5 WEE
230 SOUTH DEARBORN,
CHICAGO,ILL.60604
Sear Sirs;
Here is my reply to the notice of the waste-water treat-
ment facilities for OTTER TAIL LAKE area.
As for myself and family,we were at the Lake Cottage only
8 days during 1978 and only 5 days-in 1979 nostly to keep up
the lawn end repairs.
The cottage was bought by my Father and Mother in 1923
as a, place to spend time fishing and to get out of town(Fergus Falls)
where we were victims of a tornado in 1919 and my sister was killed.
The cottage had a tornado celler and Jhey felt quite safe there.^heir
stays there ended in 1935 when my Mother was in her final illness.
Dad kept the cottage but was there only rarely.My family
(from Brooten)used to go ther e for our vacation and a few week-ends
and Dad would come too.Dad died in 1950,and 1 inherited the pro-
perty.It is not winterized|[_single walls,air space beneath thef"
floors,so can be used only in Summer.For water,there is a hand-
pump ;no toilet in the housejust an out-house,so there is no
need for a septic tank or sewer;the lot is 109 Ft, deep end the
out-house is at the vipry back of the lotr-no seepage into the lake.
I recently received a letter from CLIVUS MULTRUM(CAM*
BRIDGE,MASS.)which stated that:
"Recently,the Environmental Protection Agency drafted
an Environmental Impact Statement(EIS) for the OtterTail Lake
area which recoamended a Limited Action Alternative as opposed
to sewering i$& the area which was the reason for the differing
opinion and wasdue to high cost of sewering and t.
-------
in the cities -tnere is no chance anymore to live somwhat pri-
atively or the simple life -a chance toget away furm city ways.
Pretty soon only the wealthy can ovn a second home by a lekm.
I would choose tne compost system preferably.
Please send additional information.I could not be present at
the Jan.5 meeting at Otter Tail Lake,and the place of the meeting
was omitted, from the form litter.Please keep me informed and send
a copy of the Otter Tail Lake Draft EIS. ,
A cottage owner, V/,^;' iX-/-,-
Mrs.Irene Imsdahl.
-------
no
C "O
January 19, 1 980
United States itfivironmental Protection ;
Agency
Region V
230 South Dearborn Street
Cnicago, Illinois 60601).
Attn: (jene toojcik, Section Chief - ?2
Tnis is in response to hPA. published draft £ilb "Alternative
waste Treatment systems For hural Lake Projects, Case Study
iMumber 3 Ottertail County board of Commissioners Ottertail ^
County, Minnesota",two volumes, dated November 1979.
1 am a property owner on the northeast shore of Lake Ottertail.
iviy family and 1 utilize tne property for vacationing only, for
approximately two and one-half months each year. Ours is one
of the narrow frontage lots that was orginally sold by Simmons:
Simmons hesort. The lot is outfitted with a "sand-point"
driven water well and with what the 'locals' cakl a septic tank,
located approximately 33 feet from the well location.
Although 1 have read most all the pertinent portions of your
report, there may nave been some points that I missed...but
I do not think so. First, 1 would like to say that the report
is truly filled with much valuable information ana next, it
will remain an important reference source for some time.
Further, I appreciate that several alternatives were presented
to consider along with the primary approach originally proposed.
however, naving also some appreciation for the scientific
approacn to tne solution of problems, I believe that the alter-
natives fell short of the more practical possibilities as well
as those that are supported by reasonable and practical tech-
nolo&y. 1 disagree totally with the recommendation given; the
recommendation has no solid basis and was formulated subjectively.
idealizing that one must try and maintain an open mind when
seeking the better scientific solution, the same is not neces-
sarily true when seeking a better engineerinR solution. TiLe
latter also implies that there are also sociological consider-
ations that may override a better scientific solution.
Aiow these ideas could lead one to the formulation of precondi-
tions or guidelines to be used in finding the acceptable answers.
The ground rules will certainly help narrow tne scope of study.
Suggested Sociological Guidelines:
I. The first guideline for seeking possible solutions is the
test of urgency. Does a condition exist that demandsim-
-------
mediate attention? The answer to this, fiom the information
you have gaiered, is no.
II. The second guideline in finding the solution is: is there
a situation or condition being created that will require a
timely solution? The answer to that question is(from your
information): "quite likely, yes.
III. Next groundrule: if money is a limiting factor and a sol-
. ' ;mtion must fall within a definite amount, no alternatives
should be seriously presented which fall outside this
figure. This answer could not be found in the study.
In other words, of all possibilities that can be formu-
lated, those that fall into the correct economies should
be studied further, and the remainder thrown out.
IV. I believe, lastly, that the various possible solutions
should not be foreign, e.g., the solution must not be out-
side the norm of accepted life styles and usual technology.
If this is not to be used as a criterion, then the possible
solution is not likely to be practical. The solution must
must be simple, i.e., a "conventional sewage handling sys-
tem"... so as to keep down the operating costs to a bare
minimum. The system decided on should also require a min-
imum of governmental policing and administration...again
because of costs. The technology should not be new for
newness sake.
The first steps that should be taken in the interim are:
1) On-site inspection of each lake dwelling or location using
ground water and disposing of sewage and waste water on site.
If there is an immediate hejjlth hazard or a source of obvious
pollution, the owner(government or individual) should be given
specific directions as to what must be done and a reasonable
time to correct and enforced by law.
2) If no immediate action is required on an individual site,
then the owner should be provided with a specific list of
longterra actions that must be taken to insure that possibili-
ties remain under control and no future problems will arise.
3) Any other actions, not mandatory, but recommenfied should be
iterated for the consideration by the property owner.
if) After the three items above Jaave been initiated, fchen a
new sewage system should be studied using conventional ideas
and based on the amount of money that is available or can be
obtained.
A phased approach may be required. Provide hook-ups on a
limited basis at first...building-in methodically planned
phases of growth to accommodate and merge with the economics
of the problem.
A gravity operated sewage system is obviously far ahead of any
other present day system. If the LlhiTtiU solution is at an
approximate cost of 75ft of a modified gravity system, then
quite obviously too the LIMITKD WfiB&S&tefA solution is not
THi- solution.
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3.
For a point that you should reconsider: the size of the sewage
system should not be based on a figure of bOgpcd, at least in
the first phases. The figure to be used in the initial design
should be closer to i|.0-l4.5gpcd. These latter figures are used
by the U.S. Army in similar applications and for the purposes
proposed, I would contest the use of a much higher figure.
Enforceable restrictions should be made, e.g., no automatic
washers (dish or clothes) waste water may ever be discharged
into the system. Bath tubs connected into the system should be
strictly forbidden in all new construction or modifications
and only showers permitted. All floor, roof, and patio drains
must be totally disconnected from the sewer. Greater design
efforts must be made to preclude the I/I and a new technology
monitoring system should be applied. Whereas the above may be
difficult to enforce at first, it will cause but minor adjust-
ment to daily lives... if any I... it will be much more practical
thaft other solutions suggested in the report.
With the smaller gpcd figure used in the design aS" - well as the
other considerations iterated above, slightly lower capital
costs will be incurred.
In the long ran, a gravity system is probably the lowest cost,
when all things are considered. It is not understood why the
"pump-pressure" system was a prime consideration. Why was a
"pump-lift" gravity system no t, proposed? The electric power
and mechanical systems could significantly be reduced with the
pump-lift-gravity system.
lviy recommendation is to re-study the situation and redefine the
problem. Initiate actions as I have outlined above for the in-
terim.
My time for additional study of this problem has been extremely
limited because the draft report was received only three or four
days ago. Your kind attention is greatly appreciated.
Yours truly,
1). Conatser
7917 Hermitage Dr.
Fort Smith, Arkansas 72903
P.S. If you will pass a copy of ray comments to the county
board of commisioners, I will be grateful. Thanks.
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I t r -
Minnesota Pollution Cohtrbl'/Agency
JAN, 3 1 1980
Eugene Wojcik
EIS Section
Environmental Engineering Branch
U.S. Environmental Protection Agency, Region V
Chicago, Illinois 60604
Dear Mr. Wojcik:
Our staff has completed its review of the Draft Environmental Impact
Statement (EIS) on Ottertail Lake, dated November, 1979. While some
improvement over the preliminary draft is noted, we find the draft EIS
substantially deficient. The following comments address major deficiencies
pertaining to Needs Determination, Demography and Socioeconomic Information,
the proposed alternatives, and the discussion of impacts.
Needs Determination And The Need For Site-specific Alternatives Planning.
1. It is our feeling that demonstration of need has not been
adequately obtained by the data in this EIS. In this regard,
completion of the EIS, without inclusion of data from the 1979
Septic Tank Effluent Detection Study or the 1979 Sanitary
Survey, appears to be premature. Need must be established,
utilizing whatever direct or inferred evidence as may be avail-
able, before any proposed alternatives may be intelligently
evaluated. Similarly, it would appear that delineation of
service area segments should be in accordance with site-specific
needs demonstration, as some segments may contain sites not
having a need.
2. It is requested that the final EIS present the data obtained
during the sanitary survey and the summer '79 leachate survey
in a site-specific format.
3. A similar comment applies to the parameters discussed on pages
62 through 65. If observed and inferred failures are presented
in such a manner as to enable identification of need or non-need
for any given dwelling, alternatives planning and segment
delineation can more effectively proceed. Reference our
"Site-specific needs determination and alternative planning
for unsewered areas". (Attached)
1935 West County Road B2, Roseville, Minnesota 55113
Regional Offices Duluth / Bramerd / Detroit Lakes / Marshall / Rochester / Roseville
Equal Opportunity Employer
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4. High groundwater flow rates, per se, are not indicative of a
failing system or water quality problem. The system must be
in contact, or in close proximity, with the groundwater. The
3 foot separation distance stipulated by 6 MCAR 8.040 is based
on information indicating that pathogens are removed in the
unsaturated zone beneath a functioning drainfield.
5. In the discussion of decentralized treatment and disposal,
reference is made to non-compliance with Minnesota's Shore!and
Management Act. While non-compliance with groundwater and
waterwell separation requirements constitutes an inferred need,
other provision's (setback distance from lake, setback from
property lines and building) generally will not, unless they
are clearly related to water quality or public health problems.
6. The description of alternatives is inadequately supported by
data. Since the maps are not to scale, it is very difficult
to relate locations of segments to locations of problems and
site limitations. Numbers of houses slated for clusters
or on-lot upgrades are not presented on a segment basis, and
are extremely difficult to determine since some segments are
scheduled for a mix of treatment alternatives. No justification
is provided for the projected increase (i.e., how many empty
lots are in each segment, and are they truly developable).
In the absence of detailed data, it is impossible for us to
even determine whether the proposed alternatives are appropriate.
Alternatives should be planned on a site-specific basis, and
should reflect need and lot limitations. The EIS discussion of
alternatives should include a level of detail which will afford
review of this site-specific planning.
7. This Agency is concerned to see numerous references to a post -
EIS detailed field survey (for example, pages 112, 124, 126,
and 139). Our expectation was, and remains, that the EIS
would suffice to complete Facilities Planning for the Ottertail
Lake project. It is may be that the data obtained during the
EIS (particularly with regard to leachate detection) will
suffice to complete Step 1, provided it is properly presented,
on a site specific (house-by-house) basis. Any subsequent
data collection deemed necessary to address the issues of the
EIS should be performed as a part of the EIS.
8. On pages 112, 113, and 139, assumptions are made to relative to
the anticipated numbers of residences requiring various im-
provements. The estimated percentages appear to be quite
arbitrary and with little or no regard for actual conditions.
While it is realized that absolute quantification of numbers
of residences requiring a given improvement is quite difficult
(and may be modified during Steps 2 and 3), the data is so
critical to alternatives planning that some attempt must be
made. Information obtained during the Facilities Plan, the EIS,
and this Agency's Needs Determination should allow for the
generation of the following data, on a site-specific basis:
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a. On-site systems which do not require upgrading.
b. On-site systems which may be upgraded with a standard
below-grade system (No lot limitations to standard
system)
c. On-site systems which may be upgraded with a mounded
system (high groundwater, sufficient lot size)
d. On-site systems which, due to space limitations,
may not be upgraded on-site.
9. The statement that "indirect evidence alone cannot justify
Federal funding..." (page 96) is somewhat modified by verbal
agreements made between EPA Region 5 and the MPCA relative to
inferred evidence criteria. (Reference attached memorandum).
Demography And Socioeconomic Information
1. While it is recognized that demographic data for the service
area is non-existent, we feel that two very fundamental flaws
exist in the document's discussion of population and socio-
economics. Firstly, the EIS attempts to draw conclusions about
the residents of the Service Area on the basis of data pertaining
to permanent residents residing in the "Socioeconomic Study Area".
There is no reason to believe that demographic or Socioeconomic
characteristics of one would be identical or even similar to
those of the other. It is noted that, even utilizing the 3.0
persons per household figure assumed by the EIS, the service
area population is barely 60% of that of the Socioeconomics
Study Area. The second basic flaw relating to demographics and
socioeconomics is the fact that the EIS makes no attempt
whatsoever to evaluate the seasonal population (over 80% of the
total summer population, according to data on page 76).
2. Page 81 states that no published statistics are available for
the seasonal population. This does not mean that the information
cannot be obtained through a survey of a reasonable sample.
(During the course of which a better estimate of household sizes
could be obtained). Please refer to comments 7 and 8 of our
letter of March 29, 1979 to Alfred E. Krause.
3. 1970 Household sizes for the Socioeconomic Study Area are;
Amor, 2.87; Everts, 2.88; Girard, 3.11; Ottertail (Twp.),
3.42; and Ottertail (Hamlet), 2.61. These rates must surely
have decreased, in accord with observed Statewide trends.
While they may not appropriately be utilized to estimate study
area population, the 1979 permanent residence household size
of 3.0 appears to be high, and requires justification. We also
doubt the validity of the 5.0 household size utilized for
seasonal residences.
4. The basis for a .5% annual seasonal to principal conversion
rate has not been indicated. Nor has the basis for year 2000
household sizes of 2.8 and 4.0. The EIS uses the term "occupancy
rate". The proper term is "household size". An occupancy rate
is the percentage of houses which are occupied.
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5. The extent to which the inclusion of stores, inns, and res-
taurants in the dwelling unit equivalent totals inflates the
population estimate, since the data is not presented separately.
In any case, stores and restaurants are generally not considered
dwelling units. If flows from such establishments are considered
significant, they should be quantified.
6. Records of homestead filings from the Ottertail County Assessor
would offer a much more reliable assessment of residency status
than the Property owners assocation estimate.
7. The EIS does not indicate the numbers of developable lots
assumed to be fully "built out". Thus it is impossible to
evaluate whether projection methodology has an inflationary
effect. Township growth rates, and township C-40 (housing starts)
reports cannot logically be applied to the Service Area. A
better data base is available in "Minnesota Lakeshores" where
Archival data from 1954 to 1967 were utilized. Building permit
records are also presumeably on file in the County Office of
Land and Resource Management.
8. The 1976 July 1 estimates of the U.S. Bureau of Census indicate
an increase in the hamlet of ottertail to 198 persons. The
Minnesota State Demographer estimated a 1979 population of 207.
This may despute the statement on page 2 of Appendix F.
9. Resort population projections are apparantly based upon the
optimistic thinking of resort owners. This results in a
60% increase in seasonal resort population which requires
more reliable justification.
10. The data pertaining to median values of housing is unclear.
Is this assessed value or market value? The County assessor
should have recent market value information for both seasonal
and permanent residents.
Deficiencies In The Proposed And Selected Alternatives
1. We have certain reservations about the greywater-blackwater
separation proposed for an unspecified number of residences.
No discussion of ultimate treatment of the blackwater is
presented. Installation of the alternative toilet is a po-
tentially high local cost. We doubt that local residents will
enthusiastically receive the composting toilet. Even with
extensive flow reduction, the greywater component must be
treated. Greywater soil treatment systems will be subject
to the same site limitations as standard soil treatment systems.
If a given lot is too small to allow adeqaute separation
of well and standard drainfield, it is unreasonable to expect
that it is large enough to afford separation between the well
and a greywater drainfield. If the lot is large enough to
support a drainfield, but inadequate separation from the ground-
water is a problem, then a treatment mound should be constructed
for both components of the wastewater. It is relatively rare
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to find a lot which is too small to accomodate a standard
system, but large enough to accomodate a smaller system sized
to take advantage of reduced flows. Normally, the limitation
imposed by lot size is a result of well isolation distances
rather than the physical problem of finding space for the drain-
field.
2. If the Facility Plan Proposed Action was redesigned and recosted
with flow-reduction measures, then all other alternatives
should be so designed and costed, where appropriate. The
following comments pertain to flow-reduction:
a. Any calculations of cost-effectiveness involving
replacement of existing fixtures should be based upon
full replacement cost, not on the difference between
fixture prices. Installed cost for a dual flush toilet,
shower flow control insert, and faucet flow control insert
is therefore $155.20, for a saving of 70 gallons per day
and a user charge reduction of $45 per annum, (family of 4).
It is presumed that reduction will be proportionately
reduced to approximately $34 per annum for "average"
permanent household.
b. If the "average" permanent household daily flow reduction is
proportionately reduced to approximately 50 gallons, it
is questionable whether flow reduction will be cost-
effective in terms of total project cost. Fifty gallons of
flow will require, in all likelihood, less than fifty square
feet of drainfield. At $2 per square foot, this is only
$100. Flow reduction will not reduce the primary maintenance
requirement (septic tank pumping). Due to the high perme-
ability of local soils, development of clogging in drain-
fields is not anticipated. Thus incidence of required
drainfield repair is not expected to be reduced by flow
reduction. No estimation of fixture O&M was made. We
suspect that it might increase for a dual flush toilet.
c. Owner-installed flow reduction devies can also be removed
by the owner, assuming that they ever were installed in
the first place.
d. We further speculate that the initial expense of $155 for
flow-reduction may be burdensome for the low-income families,
especially when "break-even" would not be realized for
several years.
e. While flow reduction is highly appropriate for holding
tanks and existing systems (especially those is "tight"
soils) which cannot be enlarged, it is not clear that it
should be practiced in cases where construction of new
drainfield in "light" soils is contemplated. Flow reduction,
in this instance, appears to be "nice to have", but probably
not cost-effective.
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f. Further, the flow reduction discussion relies wholly on
the assumption that wastewater treatment charges will be
based on water usage as metered. The feasibility of
installing water meters is somewhat questionable. It is
further uncertain whether sewer use charges will in fact
be based on water usage.
3. The discussion of ownership and maintenance of STEP stations
on page 122 is erroneous. Under no circumstances can we accept
a management approach which advocates maintenance by the home-
owner.
4. The questions posed on page 124, under discussion of management,
are questions which sho"ld have been answered by the EIS.
Discussion pertaining to the proposed management system, both
here and in Appendix J-3, should address specifically the
situation in the service area. The EIS merely describes a range
of management functions performed by a number of agencies
(Ottertail County, MPCA, Minnesota Department of Health, USEPA).
It would be preferrable to indicate which functions will be
performed by Ottertail County and which by the management
entity. Certain of the listed management functions are presently
being done as part of the Construction Grants participation,
while those same functions will be performed subsequently by the
County or the managment entity, (e.g. existing substandard
systems are being evaluated during Step 1, designed in Step 2,
and constructed by applicants agents in Step 3. Will the manage-
ment entity assume the regulatory role presently performed
by Ottertail County?). What is required, essentially, is a
description, in greater detail, of a management plan recommended
by the EIS.
Any discussion of the management plan should take account of the
fact that the County is participating in the Construction
Grants Program.
5. We are disappointed to find that the limited action alternative
appears to suggest on-site maintenance and upgrade in areas
where lot size is less than 10,000 ft . Recent revisions to the
Waterwell Construction Code (7 MCAR 1.217C1F) requires a 100 foot
isolation distance for wells less than 50 feet in depth and not
encountering at least 10 feet of impervious materials. The
separation required increases to 150 feet if the ST/SAS is
a leaching pit or dry well. It is quite unlikely that these
separation requirements will be met on a lot of less than
10,000 square feet.
6. Conversely, EIS alternative No.l proposes cluster systems in
areas in which lot sizes are indicated to be greater than
20,000 ft. . There is no possible justification for this unless
the groundwater is too high to allow standard below-grade
systems. This information is not presented in the EIS, except
in Figure 11-18, where it is available only as a percentage
figure, for large areas of shoreline which in several instances
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are more than three miles long, and which bear no relationship
to either the segments or the described alternatives where
groundwater is found to impose a limitation to standard below
grade systems, then the cost-effectiveness of both mounded
systems and cluster systems should be evaluated. (Mounds should
not, of course, be proposed where lot sizes are insufficient).
If a lot is of sufficient size, and depth to groundwater is
sufficient to install an on-site system, and the existing system
is shown to be malfunctioning, then on-site upgrading should
be evaluated as an alternative.
7. It is not clear what criteria were used to select the land
application sites. These should be indicated.
8. The EIS alternative number 1 proposes conventional collection,
treatment in a stabilization pond, and land application for
segments 21 through 26 and part of segment 20, citing high
groundwater which made the area "unsuitable for on-site
treatment". We find no information in the EIS which would
indicate that this section of the service area should be handled
any differently from any other section. Further, examination
of the area, both on USGS topographic maps and during a "wind-
shield" survey, indicate that some included dwellings are
located on rather high ground. Furthermore, a relatively small
number of houses are located on lots of less than 10,000 ft. .
There are some portions?of this sub area which are on lots
in excess of 20,000 ft. , well above the groundwater, where
on-site upgrading would be feasible. We recommended that
site-specific needs demonstration be performed and documented
in the Final EIS, and further recommend that the decentralized
alternatives be planned on a site-specific basis.
9. Cost-data should be more detailed. For instance, how many
houses will be served by each cluster? How many square feet
of treatment area will be required, at what unit cost? How
many septic tanks and pumps, how many on-site upgrades, how
many mounds at what unit cost? The cost data as presented in
the Appendix is not even sufficient to show inherant assumptions.
10. Engineering contengencies are not normally included in cal-
culation of salvage value.
11. The multiplier for seasonal population (page 99) should be
selected in accordance with appropriate Federal Regulations.
There is no information in the EIS pertaining to the magnitude
of day-use visitors. If flows attributable to day-use visitors
are felt to be significant, this factor should be quantified.
12. The EIS should clearly specify the nature of variances recom-
mended. While this agency can support the validity of granting
variances from roads, buildings, and property lines categorically,
and the granting of variances from well and lake setback require-
ments on a case by case basis where no public health or water
-------
quality impact is demonstrated, we cannot endorse any variance
from the required 3 foot elevation above groundwater, and we
cannot condone variances for substandard or illegal systems.
In any case, granting of variances is within the purview of the
County.
13. The Minnesota Pollution Control Agency cannot accept the
Limited Action Alternative as presently conceived. We suggest
EIS alternative number one, with the provision that the decision
to upgrade on-site, cluster, install or retain holding tanks,
or install pressure sewers be made on a site-specific basis,
in all segments of the service area.
There is absolutely no information provided in the EIS that
hydrogen peroxide treatment is necessary. Hydrogen peroxide
treatment is appropriate for the restoration of hydraulic
capacity of a drainfield which has become clogged. There is
no reason to believe that any clogged drainfields exist in the
service area. Use of a 25% estimate for H?0? treatment is
therefore totally unwarranted.
Deficiencies In The Discussion Of Impacts
1. The assessment of project impact on population and land use is
inadequate. One of the four issues of this EIS is secondary
development.
No basis whatever is indicated for the estimated projections
of increases above baseline growth. Likewise there is no basis
indicated for the acreages projected under "development potential".
It is desirable to indicate numbers of vacant lots by segments.
It is requested that the final EIS include historical data to
verify the assumptions made in the last two paragraphs in the
discussion of "impacts on population", (page 158), as well
as the last paragraph of the discussion of development potential.
2. It would be desirable to indicate whether the Ottertail County
anticipates any change in lot size requirements for the respective
alternatives. This would be allowed under Shorelands Management
Rules.
3. The above comments apply to the discussion of "changes in
Community Composition and Character". In addition, it is
suspected that displacement pressure might conceivably impact
conversion (or reversion).
4. It is suggested that historical data be evaluated in lake areas
that have been sewered recently, to shed further light upon
the population, land use, and socioeconomic questions. Reasonably
good data may be available from the Minnesota State Planning
Agency, which has custody of data from the Minnesota Lakeshore
Development Study of 1970. Suggested candidates for study include
the Alexandria Lake Area Sanitary District, in Douglas County,
Eagle Lake in Kandiyohi County, and Forest Lake in Washington
County. It is suspected that other sewered lakes might be found
in other states.
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5. Insofar as impact on Wetlands is directly related to the extent
of secondary development, Chapter V, Section D inadequately
addresses the question of Wetlands impacts. The EIS discussion
should include a review of Minnesota DNR authority and rules
regarding Alteration of Beds of Public Waters, a review of
authority of the Corps of Engineers and U.S. Fish and Wildlife
relative to shrub wetlands, and a review of the provisions of
the Ottertail County Shore!and Management Ordinance related to
construction impacts.
6. The existing Shore!and Management Ordinance of Ottertail County
may provide adequate protection for wetlands and flood plains,
provided those provisions are enforced. A copy of the County
SMO should be included in the appendix, and a discussion of the
historical pattern of variances granted by the county in sensitive
areas should be provided.
7. We have already commented on the flaws of Chapter II, Part E
"Population and Socioeconomics". Those comments bear directly
on the discussion of displacement pressure and conversion
pressure, especially relative to the seasonal population,
while according to the EIS is 83% of the total, and about
which no data has been obtained. Without such data, any
discussion of socioeconomic impacts is merely speculation.
8. On Page 18 the statement is made that on-site systems serving
seasonal homes are not fundable. This statement should be
clarified in light of PRM 79-8. Similarly, on page 164, it is
stated that the Minnesota Pollution Control Agency does not
fund collection systems. This policy changed on November 6, 1978,
with the revisions to 6 MCAR 4.8034. If average annual user
charges represent post-grant local costs, Table V-3 and the
entire discussion of economic impact will have to be modified.
The economic impact discussion should recognize that a connection
charge will be assessed. This may vary as a function of the
selected alternative.
9. The discussion of mitigative measures should include mention and
evaluation of sources of assistance for permanent residents in
hardship status. Specifically, the Minnesota Housing Finance
Agency administers two assistance programs. The Home Improvement
Grant Program provides outright grants to qualified receipients.
In Ottertail County, the program is administered by the Ottertail
County HRA (County Courthouse, Fergus Falls, 56537; telephone
218/739/2271 ext. 258). The Home Improvement Loan Program
provides low-interest loans, depending upon income, and is
administered by the First National Bank of Fergus Falls, the
Security State Bank in Fergus Falls, the First National Bank of
Parkers Prairie, and the Pelican Valley State Bank. Funds avail-
able are variable; they should be investigated.
Minor Deficiencies
1. The citation of Minnesota Statutes on page 121 is incorrect
due to a typographic error. The Chapter is 116A.
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10
2. Otis and Stewart, 1976 is cited in the text on page 123 but not
listed in the bibliography.
3. On page 151, Johnson, et al . and Miller (1976) are cited.
Neither reference is listed in the bibliography.
Comments Related To Ottertail Sanitary Survey.
1. No results are presented in the sanitary survey supplement
for the "cladophora survey". The factors which influence the
growth of attached algae are so numerous that we wonder if any
reliable conclusion can be drawn from its presence or absence.
2. We believe the definition of permanent resident as someone who
occupies a home 10 or more months out of the year, is inappropriate.
A much better criteria would be if the homeowner has Homestead
exemption as a resident. This information should be available
from the county.
3. The information on noncompliance with shore! and management
should be presented on a plat map of the Ottertail Lake Area.
Information such as lot size and depth to watertable, should be
presented for the entire area.
We are well aware of the difficulties inherent in the preparation of the Ottertail
Lake Environmental Impact Statement. Much of the data required for this EIS was
not obtainable through normal routes of investigation. It is also apparent that
the study was somewhat unique, insofar as it was related to Facilities Planning.
As an EIS, the document was marginal. As a Facilities Plan, it was not adequate.
In order to bring this project to a speedy conclusion, it is suggested that avail-
able (but unpublished) information be incorporated in the Final EIS, in such a
manner as to allow documentation of need and alternative planning on a site-
specific basis.
We request that the EIS Branch meet with MPCA staff prior to completion of the
Final EIS. It is also considered advisable to involve EPA staff from the
Facilities Planning Branch in the finalization and review of the Ottertail Lake
Environmental Impact Statement. Should you have any questions, please do not
hesitate to contact Eric J. Kilberg at (612) 296-7313. For engineering related
matters, James L. Warner may be contacted at (612) 296-7752.
Perry T. Beaton P.E., Chief
Facilities Section
Division of Water Quality
PTB:EJK:cl
cc: Malcom Lee, Ottertail Co. Land and Resource Management
Chuck Orzehoskie, USEPA Region V
Ottertail County Board of Commissioners, % County Auditor
Ken Skuza, Ulteig Engineering
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Department of
LAND & RESOURCE MANAGEMENT
COUNTY OF OTTER TAI L
Phone 218-739-2271
Court House
Fergus Falls, Minnesota 56637
MALCOLM K. LEE. Administrator
November 6, L979
Alfred E. Krause
Project Officer EIS Preparation
U.S. Env. Protection Agency
Region V, 230 S. DearBorn
Chicago, IL 60604
Gerald Peters
WAPORA Inc.
Suite A
6900 Wisconsin Avenue
Washington, D.C. 20015
Gentlemen:
I have been reviewing the Draft EIS for the Otter Tail Lake
project and although I haven't digested all of it, I thought
several points should be brought to your attention.
The date cited for the adoption of the Shoreland Management
Ordinance by Otter Tail County is a little mis-leading. The
county adopted the ordinance on October 15, 1971. The first
revision was May 1, 1973 and the second revision was April 1, 1978.
While this is problably a relatively minor point, the April 1, 1978
revision may have more serious implications.
Although we do not conduct on-site inspections of wells, we are
required to maintain the required isolation distances between
wells and the various components of on-site sewage systems.
This is where the problem lies. Prior to the second revision
date the isolation distance between a septic tank or drainfield
and a well was 50 feet. This is the figure used in the Draft
EIS. However, we became aware of a change in the water well
contractors code that affected on-site sewage systems and
incorporated that change (as mandated by the state) into our
ordinance on April 1, 1978. Separation remained at 50 feet for
a septic or holding tank, but depending on well depth now re-
quires an isolation distance of up to 100 feet from a drainfield.
SHORELAND MANAGEMENT ORDINANCE - DIVISION OF EMERGENCY SERVICE - SUBDIVISION CONTROL ORDINANCE
SOLID WASTE ORDINANCE - RIGHT-OF-WAY SETBACK ORDINANCE - FUEL AND ENERGY COORDINATION
SEWAGE SYSTEM CLEANERS ORDINANCE - RECORDER. OTTER TAIL COUNTY PLANNING ADVISORY COMMISSION
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Department of
LAND & RESOURCE MANAGEMENT
COUNTY OF OTTER TAIL
Phone 218-739-2271
Court House
Fergus Falls, Minnesota 56537
MALCOLM K. LEE, Administrator
This would undoubtedly raise the number of lake lots that could
not conform to the Shoreland Management Ordinance and on some
lots (even with adequate elevation) would require the use of a
holding tank due to insufficient property to obtain the required
distance. There would also be an added cost factor to those
larger lots for relocation of their wells to conform to the
requirements. This code underwent minor revision this fall and
I have enclosed a copy from the October 22, 1979 issue of the
State Register stating the code requirements as they now stand.
Also enclosed are copies from the Lake Region Co-op Electrical
Association News Flashes, Pelican Rapids, Minnesota 56572, dated
April, 1975 and July, 1979. Hiran Bailey (author of the column)
is a resident of Rothsay Camp and on a collector system.
One other minor point is that Richard Astrup is with the Minne-
sota Department of Health, Fergus Falls office, not the Land
and Resource Management office as stated.
Unfortunately, we were not aware that you were working with an
older copy of our ordinance. Hope this doesn't throw too big
a wrench into the works!
Sincerely,
(M
Larry Krohn
Land & Resource Management
enc: 3
raab
SHORELANO MANAGEMENT ORDINANCE - DIVISION OF EMERGENCY SERVICE - SUBDMSION CONTROL ORDINANCE
SOLID WASTE ORDINANCE - RIGHT-OF-WAY SETBACK ORDINANCE - FU6L AND ENERGY COORDINATION
SEWAGE SYSTEM CLEANERS ORDINANCE - RECORDER, OTTER TAH. COUNTY PLANNING ADVISORY COMMISSION
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Federal Building, Fort Snelling
Twin Cities, Minnesota 55111
IN REPLY REFER TO:
DEC 21 1979
Mr. Gene Wojcik, Chief, EIS Section
Environmental Engineering Branch
U.S. Environmental Protection Agency, Region 5
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
This responds to Mr. McGuire's November 16, 1979 letter
requesting review of the Draft Environmental Impact State-
ment, Volume 1 and 2 for Alternative Waste Treatment Sys-
tems for Rural Lake Projects, Case Study No. 5: Otter
Tail County Bo^ird of Commissioners, Otter Tail County,
Minnesota.
The U.S. Fish and Wildlife Service has reviewed the sub-
ject document and finds it adequate, from the standpoint
of fish and wildlife resources, in presenting the environ-
mental impacts of the proposed subject.
Sincerely yours,
Dr.r.UF. laPointa
Act:?.-.- Assistant
?.'-3iQr-a.il Blructori
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IN REPLY REFER TO
United States Department of the Interior 1793(930)
BUREAU OF LAND MANAGEMENT
EASTERN STATES OFFICE
350 South Pickett Street
Alexandria, Virginia 22304
^ c_ -p
DEC 2 i b/3- ^ H
C-O
rp
Regional Administrator -, s ',"]
U. S. Environmental Protection Agency C,. j- .-,
Region V ^ °:' '"'
230 South Dearborn Street
Chicago, Illinois 60604
Dear Sir:
This is in response to your request for review and comment on the draft
Environmental Impact Statement on Alternative Waste Treatment Systems for
Rural Lake Projects - Case Study Number 5 - Ottertail County, Minnesota.
The Bureau of Land Management, Eastern States, is responsible for the
remaining vacant Public Domain (both surface and minerals) and the
leasing of most Federally-owned minerals within the State of Minnesota.
A review of our records indicates that there are no Public Domain lands
or islands in the vicinity of the proposed project.
There are several Bureau of Land Management islands within ten miles of
the proposed project. However, a review of the proposed action and
anticipated impacts indicates that no Bureau programs will be adversely
effected.
General Comments
We thought this was a very well prepared statement. In general, it
provides a thorough discussion of the natural environment; the alternatives
are clearly described and the assessment of impacts are well thought out.
Specific Comments
Although not directly involved in the instant action, BLM administers
approximately 45,344 acres of public lands and islands in 71 of the 87
counties in Minnesota. Otter Tail County contains approximately 95 islands
with an estimated 175.50 acres.
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Page 2
Attached for your future reference is a copy of BLM's Initial Inventory
Proposals for Public Lands and Islands in Minnesota (September 1979) .
This report contains the findings of the Bureau of Land Management as
a result of its initial wilderness inventory of BLM-administered public
lands and islands in Minnesota.
In the Federal Land Policy and Management Act of 1976, Congress directed
the Bureau of Land Management to review all its lands to determine whether
any areas should be added to the National Wilderness Preservation System.
In Minnesota, BLM lands consist of scattered remnants of the original
public domain, namely: 1) islands and uplands that existed at the time
of Statehood but were omitted from original surveys; and 2) lands and
islands that were surveyed but still remain unpatented.
All of the BLM lands and islands in Minnesota are listed in this report,
grouped according to similarities in characteristics. Each grouping is
identified in a Situation Evaluation, which includes narrative
descriptions and recommendations. Also enclosed are a fact sheet and
state map that show the location of the lands and unit references. More
detailed maps of individual tracts and islands - by lake, river and legal
description - are available form the Lake States Office upon request.
This initial report and map include proposed decisions on lands and
islands that:
1. Clearly and obviously do NOT have wilderness qualities and
will be dropped from further study, and
2. May possibly have wilderness values and will require more
intensive inventory.
Because of the scattered ownership pattern of BLM holdings in Minnesota,
we particularly appreciated receiving a copy of the DEIS and the opportunity
to comment.
Conclusion
Since there are no Bureau lands (islands), minerals, or programs directly
affected by your proposed action, we have no further comments.
S^tncerely yours,
/?
Acting
Director
Eastern States
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
PUBLIC HEALTH SERVICE r>
CENTER FOR DISEASE CONTROL " " ! " * ' ''"-
ATLANTA, GEORGIA 30333
December 26, 1979-q ,,
'- <.<-.- J C. .';,"] |[j
Mr. Alfred Krause - i ,,; p
Project Monitor
230 South Dearborn Street
Chicago, Illinois 60609
Dear Mr. Krause:
We have completed our review of the Draft Environmental Impact Statement
(EIS) for Alternative Waste Treatment Systems for Rural Lake Projects,
Case Study Number 5, Otter Tail County Board of Commissioners, Otter Tail
County, Minnesota. We are responding on behalf of the Public Health Service
and are offering the following comments.
In general, we have no objection with the Limited Action Alternative (the
recommended action) to include decentralized systems for all parts of the
Proposed Service Area. The rehabilitation and replacement of onsite systems
and the provision of gray/black water separation in areas where ground water
contamination or shoreline eutrophication could occur from subsurface treat-
ment of black water should help alleviate existing water quality and public
health problems in the project area. We recognize that the results of
some ongoing water quality studies are still not available and that their
results could affect the final decision.
We suggest that any final decision to decentralize wastewater treatment
should also include a firm commitment from local authorities to require the
installation of flow reduction devices in existing and new homes and the
institution of special ordinances (zoning, building codes, local health
permits, etc.) where nonexistent to adequately protect surface and ground
waters from degradation.
While bacteria contamination of some wells has been cited in the EIS, it
is not made clear if this contamination results from local septic tank
leachate. We believe the EIS should provide more information on the source
of bacteria contamination and whether specific pathogen have ever been
identified in these wells. The EIS should discuss if any illnesses have
been reported in the area that might have resulted from contamination of
well water by septic tank leachate.
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Page 2 - Mr. Alfred Krause
We appreciate the opportunity to review this EIS. Please send us a copy
of the final EIS when it becomes available.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Af:
Environmental Health Se:
Bureau of State Services
w Chief, Environmental Affairs Group
Environmental Health Services Division
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CONSULTING ENGINEERS
ULTEIG ENGINEERS. INC.
P O BOX 1569
1401 OAK MANOR AVENUE
PHONE 701-237-3211
FARGO, ND 58107
January 7,
Mr. Alfred Krause
Project Monitor
Environmental Protection Agency
230 SOUTH DEARBORN STREET
CHICAGO IL 60609
1 3KANCH
J. -.*
SUBJECT: Otter Tail Lake, Minnesota
EIS
In addition to the comments given to you on January 5, 1980, I would
like to submit the following.
On page 164 of the EIS, you summarize the costs of the various alter-
natives. Paragraph "a" indicates that the state does not fund collection
systems whether they are conventional or innovative/alternative. I
don't believe this is true in Minnesota as collection systems are now
being funded. A further source of funds for the local share is the
Farmers Home Administration. Both of these should be re-evaluated in
the EIS to give a true picture of the actual costs.
From the limited information contained in the EIS, it appears that in
several alternatives re-plumbing and hookup costs are not considered
which makes them look very attractive on the surface. In order to
make a fair evaluation, these types of costs must be considered.
Page ii refers to three recommendations with respect to formation of a
small waste flow district. I would recommend that a meeting be estab-
lished with only the concerned parties in the very near future to further
discuss this and establish areas of responsibility.
K. M. Sku&f, P.E.
jz/1-K
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CONSULTING ENGINEERS
PHONE 701-237-3211
ULTEIG ENGINEERS. INC
P O. BOX 1569 1401 OAK MANOR AVENUE FARGO, ND 58107
January 4, 1980
STATEMENT ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
ALTERNATIVE WASTE TREATMENT SYSTEMS FOR RURAL LAKE PROJECTS
CASS STUDY NUMBER 5
OTTERTAIL COUNTY BOARD OF COMMISSIONERS
OTTERTAIL COUNTY, MINNESOTA
Thank you.
My name is Ken Skuza, Vice President of Ulteig Engineers, Inc., in
Fargo, North Dakota.
We would like to thank you for this opportunity to read into the record
the basic differences between some of the items in the Facility Plan
completed by our firm in July 1976 and the draft Environmental Impact
Statement dated November 1979 that you have before you.
Many changes in federal regulations and funidable alternatives have come
about since the inception of this project. EPA regulations as late as
1979 are still not clear as to what is presently fundable and may be
classified as innovative or alternative technology.
The initial causes or reason given by EPA for the development of an
Environmental Impact Statement were to review:
a) The cost effectiveness
b) The socioeconomic impact
c) The secondary fmpact, and
d) The wetland impacts of the project.
From that initial call for an EIS dated July 20, 1977 to date, there have
been many changes in approach and objective as federal regulations
changed, or other treatment techniques became fundable.
Advances in technology allowing for greater in-depth study and water
quality modeling to more fully evaluate pollution potential and pollution
effects are a great benefit to the solution of these problems. At the
same time, however, to indicate that a study conducted in about 1975 is
inadequate because it did not utilize techniques non-exfstent at that
time is somewhat misleading.
-------
Your own statement relating to this draft EIS declares it to be somewhat
different. It further states that a number of remote sensing, surveying
and planning techniques are used here for the first time on a Region V
EPA project.
These include:
Nutrient budget analysis
Aerial infrared photography
Ultraviolet fluorescent "septic snooper"
On-site management techniques
Again, let me stress that the utilization of the new techniques is exciting
when looking at the potential that they possess But, the original
Facility Plan was not funded to do these things nor were any of the
water quality studies you conducted recommended by MPCA or the EPA
in the original Plan of Study. It is not clear if the Facility Plan was
conducted by a private consultant today whether water quality monitoring
or nutrient budgeting analysis would be fundable or even required.
Our experience indicates they still are not fundable.
It is felt that based upon the federal and state criteria which were in
effect at the time of the Facility Plan preparation along with the impetus
for federal funding, that the Facility Plan addressed the issues carefully
and fully and developed the best alternative solution. The quality of
the work done in the Facility Plan is further obvious when the cost of
the recommended alternative is within about one percent of the EIS
evaluated alternatives other than the limited action alternative which
still has some rather broad assumptions and more than likely will run
higher than the estimate.
We feel that all the cost estimates on all the alternatives are so close
that the most cost effective one is a "toss-up."
Finally - we feel that the limited action alternative will be better defined
as the Step II process develops and each individual system is evaluated
thoroughly and specific recommendations for each on-site condition
completed.
We feel there is a need for the project and encourage its completion.
K. M. SkuzaC'P.E.
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MINNESOTA HISTORICAL SOCIETY
690 Cedar Street, St. Paul, Minnesota 55101 . 612-296-2747
December 18, 1979
-.3
co
CD
n
A3
Mr. Gene Wojcik
Chief EIS SECTION
U.S. Environmental Protection Agency
Region V
230 South Dearborn St.
Chicago, Illinois 60604
Dear Mr. Wojcik:
C-
CO
O
RE: Alternative Waste Treatment Systems
for Rural Lake Projects Case Study
Number 5, Otter Tail County, Minnesota.
MHS Referral File Number J639
We have received and reviewed that Draft EIS for the above referenced project.
We concur with the findings stated in the cultural resource section on pages
92-94, and look forward to reviewing the designs and specifications once a
final alternative is selected.
This information should be directed to Ms. Susan Hedin, Environmental Assessment
Officer, State Historic Preservation Office, James J. Hill House, 240 Summit
Avenue, St. Paul, Minnesota 55102, phone (612) 296-0103.
Thank you for your participation in this important effort to preserve Minnesota's
cultural resources.
Sincerely,
RWF/cjb
_.
Rjarssell W. Fridle
tate Historic Preservation Officer
Founded 1849 The oldest institution in the state
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APPENDIX G
EPA Memo on Access and Control
for On-Site System Upgrading
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
&
£
OFFICE OF WATER
AND WASTE MANAGEMENT
MEMORANDUM
SUBJECT: Access and Control for On-Site System Upgrading
FROM: William A. Whittington, Acting Director ' V ^
Facility Requirements Division (WH-595) ,
TO: Charles Sutfin, Director
Water Division, Region V
Thank you for your inquiry of June 16, 1980, regarding the
possibility of grant applicants meeting the requirement for "access and
control of on-site wastewater treatment in compliance with PRM 79-8,
40 CFR 35.9l8-l(h) and 40 CFR 35.935-3(b)(3), through county or municipal
ordinance, using public health and police powers to allow access,
Inspection and the right to require upgrading of on-site systems.
EPA regulations requiring the Regional Administrator to determine
that interests in the land are sufficient to assure undisturbed use and
possession for the purpose of construction and operation for the life of
the project have been satisfied by the use of perpetual or
life-of-the-projeot easements or other binding oonvenants running with
the land.
In our opinion, an ordinance which would assure the grantee a
perpetual (or life-of-project) and assignable right of unlimited access
to each individual system at all reasonable times for such purposes as
inspection, monitoring, construction, maintenance, operation,
rehabilitation and replacement could be used to satisfy EPA funding
requirements for "complete access to and control of wastewater treatment ,
works on private property. . .". Of course the use of any such ordinance^
should be approved on a "by project" basis. - r
We would appreciate receiving samples of any ordinances you may
develop as this may prove to be a very effective means for providing
required access for these on-site systems.
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APPENDIX H
Otter Tail Lake Sanitary Survey -
Otter Tail County, Minnesota
July 3, 1980
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WAPORA
OTTER LAKE SANITARY SURVEY
OTTER TAIL COUNTY, MINNESOTA
JULY 3, 1980
ENVIRONMENTAL PROTECTION AGENCY
Region V
Chicago, Illinois
PREPARED BY:
WAPORA, Inc.
6900 Wisconsin Avenue
Chevy Chase, MD 20015
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H
I. INTRODUCTION
A detailed survey of 268 randomly selected dwelling units and their
disposal systems located around Otter Tail Lake was conducted between July and
September of 1979. This total represents 32% of the total of 847 homes on the
lake shore.
The purpose of this survey was to aid in planning and designing rural
wastewater systems for the Otter Tail Planning Area by defining the need for
improved wastewater treatment. The specific goals of this sanitary survey
were to:
1. Identify possible sources of water quality and public health problems
to aid in determining grant eligibility
2. Evaluate design, usage and site limitations that may be affecting
performance of on-site systems
3. Provide a basis for identifying feasible water conservation and on-
site wastewater technologies to be included in cost-effective analy-
sis of alternative approaches for wastewater management in the Otter
Tail Lake Study Area.
II. DATA COLLECTION
A. SOURCES OF INFORMATION FOR THE SURVEY
Sources of information utilized in this survey included:
1. Interviews with seasonal and permanent homeowners and site
inspections.
2. Interviews with resort and campground owners and site inspections.
3. Well water sampling and analysis.
4. Discussions with local plumbers and septage haulers to obtain general
information about septic tank maintenance practices of homeowners,
ages and types of on-site wastewater systems generally utilized,
and installation procedures generally followed by local contractors.
5. Contact with the Otter Tail County Department of Land and Water
Resources to review building permits which have been issued since
the passage of the Shoreline Management Act. This group is respon-
sible for administering the Shoreline Management Act. These permits
gave detailed information as to homes that were in compliance with all
aspects of the act around Otter Tail Lake, Blanch Lake, Walker Lake,
and Long Lake. It also gave a picture of areas that were poorly
suited for on-site waste disposal techniques due mostly to high ground-
water tables. This was reflected in the fact that holding tanks were
usually constructed in such areas.
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H
The location of dwellings in the survey area were acquired from the 1976
and 1979 "Lakeshore Directories" published by the Otter Tail Lake Property
Owners Assocation. Only the residents directly contiguous to Otter Tail Lake
were included in this study due to time and budget limitations.
B. RESIDENT INTERVIEWS AND SITE INSPECTIONS
The form utilized in this study covered the following topics:
Location and description of the property.
Resident occupancy, size of household, duration of occupancy, intended
use and additions.
Sewage disposal system and potable water supply system description.
Maintenance history of the systems.
Use, number, and type of water using devices and appliances.
Site characteristics.
Type of protection afforded the well from surface drainage and sub-
surface contamination.
Sketch of property, surface drainage facilities and sanitary
facilities.
The purpose of the aforementioned topic areas is documentation of factors
which could result in malfunction of on-site wastewater disposal system or
contamination of a well. A copy of the survey form is included in Appendix 1.
The survey was intended to be a random survey. The original objective
was to survey every fourth house. However, in many cases the 25 percent
sampling rate was unachievable due to unavailability of residents.
Surveyors gave brief introductions and requested to speak with the person
most familiar with the dwelling and wastewater facility. If the resident
could not answer specific questions, surveyors recorded this response as
"N.A.", not available. Interviews averaged approximately 30 minutes in
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H
length. Additional time was required to make the on-site inspection and
travel between residences. A surveyor could expect to complete from 8 to 10
surveys per day. In addition to interviewing residential dwelling units,
resort and campground owners were also interviewed to ascertain the number of
cabins and that they had available and the type of on-site disposal visits
that they utilized.
Dwelling sites were inspected following the residential interview.
Evidence of sewage ponding or other public health problems was noted. Both
the physical layout of the lot, with distances noted between water sources,
the dwelling, sewage disposal system, adjacent lots, and natural environmental
features such as vegetation, topography, and drainage were mapped.
The Otter Tail Lake sanitary survey also included visual observation of
the shoreline beach or breakwater area for locating a macroscopic, bright-
green, filamentous algae called Cladophora. This algae grows only in the
presence of high nutrients or as patches near artesian well overflows. It
grows only on suitable rock, concrete, decayed wood or metal substrates in the
"wash" areas of the shoreline. A study conducted by Tom Weaver, Northwest
Michigan Regional Planning and Development Commission indicated a high corre-
lation between "poorly maintained" or malfunctioning sewage disposal systems,
lawn fertilization, wildfowl feeding, and algae blooms. A "Cladophora Survey"
is included in this study to determine if such correlation occurred also on
Otter Tail Lake.
Data was later transferred from the original survey forms to Tables
(Appendix 2). Information most pertinent to the anaylsis of on-site waste-
water treatment is presented in the Results section. Most of the data is
presented by segment (see segment locations in Appendix 3) so as to be useful
in the analysis of on-site alternatives in the EIS.
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H
C. GROUNDWATER QUALITY SURVEY
At the end of the interviews and site inspections residents were asked if
they would like to have their well water tested as part of a groundwater
quality survey. A day was set aside during the next week when the surveyor
collected samples for delivery to the Otter Tail Health Department. The
following parameters were analyzed by the Otter Tail Health Department: total
coliform bacteria, fecal coliform bacteria, and nitrate nitrogen.
As was mentioned earlier, the survey form utilized for the overall study
included a section for well data. In order to evaluate the effects of on-site
sewage disposal on well water quality using bacterial indicators and nitrate
data, only those wells properly protected from contamination by direct surface
runoff and other non-sewage sources were to have been sampled. However, due
to the large numbers of sand point wells, many exceptions had to be made to
this rule. Inspection of the well for proper surface drainage, grouting of
the annular space around the well casing, integrity of well seal and proper
well venting was seldom feasible.
III. LOCAL SANITARY DESIGN CODES
A. OTTER TAIL COUNTY SHORELINE MANAGEMENT ORDINANCE
The Shoreline Management Ordinance was passed in Otter Tail County in
1971 and revised in 1973 and 1978. The ordinance does the following in rela-
tion to protection water quality in water bodies of the Study Area:
1. Establishes sewage system design standards and separation distances
between water bodies -- sewage system -- and wells.
2. Establishes procedures for issuing building and wastewater system
permits.
3. Allows site inspections to be conducted within the lake and stream
shoreline areas.
4. Certifies on-site system installers operating in the County.
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H
More specifically Otter Tail Lake was given the "General Development" classi-
fication which specifies the following sanitary design standards:
Minimum lot area - 20,000 sq. ft.
Building set back from shoreline - 75 ft.
Septic tank
Minimum distance from nearest well - 50 ft.
- Minimum distance from lake - 50 ft.
Absorption system
Minimun distance for seepage pit to well - 150 ft.*
Minimum distance from drainfield to well - 100 ft.*
Minimum distance from lake or stream - 50 ft.
Minimum distance from bottom of absorption system from
groundwater table (vertical) - 4 ft.
* For wells with casings less than 50 feet in depth and not encountering
at least 10 feet of impervious material.
Homeowners around Otter Tail Lake that are not currently in compliance
with the act and desiring addition to their home must comply with the sanitary
provisions of the act. Many people interviewed felt reticent in making
improvements in their homes for this reason and the uncertainty of the recom-
mendations of the EIS.
IV. RESULTS
A. DWELLING UNITS
Based on information gathered from the sanitary survey and data contained
in the 1979 Lakeshore Director there are 847 private dwelling units on lake-
shore properties around Otter Tail Lake. In addition, 40 businesses including
campgrounds, convenience stores, gas stations, etc. are located around Otter
Tail Lake.
Of the 40 businesses, 14 were classified as resorts and campgrounds.
WAPORA attempted to survey all of these operations and found the following:
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Composition of Resorts
Primary Dwelling Units 7
Recreational Cabins 99
Trailer Hookups 33
In addition, numerous campsites without plumbing facilities were located
in many of the resorts.
WAPORA personnel interviewed 149 or 18% of the total number of private
dwelling units around Otter Tail Lake. Information was collected on an addi-
tional 129 homes around the lake by review of building permit records. This
gave a total of 268 homes or 32% that were included in this sanitary survey.
Of the households interviewed, the preponderance (81%) were seasonal
residents*. Two types of seasonal residents were noted in the study are: 1)
the summer weekend resident who travels from nearby major urban centers such
as Minneapolis-St. Paul, Minn., and Fargo N.D. and 2) the retired resident who
spends the warm weather months at Otter Tail.
Of the residents interviewed, 14% indicated that they would eventually
become permanent residents. Most of these people wanted to retire in this
recreational community.
Many people interviewed stated that they were withholding major modifica-
tion or additions to their dwelling unit. Also, a large number expressed that
they would buy additional water-using devices if a "sewer" became available
(the devices generally included dishwashers and clothes washing machines). A
majority of people interviewed stated that they were not utilizing water con-
serving plumbing fixtures in their homes. They generally felt this was unwar-
ranted due to the high availability of water in the area.
* Permanent residents were those who occupied the dwelling unit greater than
10 months of the year. Hence seasonal occupants were those in the dwelling
units less than 10 months.
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B. SEWAGE DISPOSAL SYSTEMS
1. Types of Systems
The prominent types of on-site systems utilized by homes located around
Otter Tail Lake include septic tanks with leach pits, septic tanks with drain-
fields, cesspools, and holding tanks. A very small number of homes were found
to be still utilizing outhouses. The percentage of homes utilizing the afore-
mentioned systems include:
From Land & Resource
Records - (Reflects
only Units Constructed WAPORA Interview
Since 1972)
From Information
Gathered During
Septic tank-soil absorption
systems (drainfield)
Septic tank -leach pit
75%
18%
51%
Septic tank-unknown ultimate
disposal system
9%
9%
6%
18%
1%
6%
Holding tank
Cess pool
Outhouses
Unknown type of system
The high percentage of septic tank soil absorption systems in the first
column reflects the fact that information is kept only on dwelling units
constructed or upgraded after the passage of the Shoreline Management Act.
The other column, however, based on data collected from the interviews, indi-
cates that a majority of homes around the lake have septic tanks with soil
absorption systems. The homes with holding tanks are areas with environmental
conditions (generally high groundwater tables and/or inadequate lot area) that
are unsuitable for on-site wastewater disposal.
In some cases the exact type of on-site system was not known by the home-
owner. In these cases, WAPORA made the following assumptions based on infor-
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H
mation gathered from local plumbers, the Department of Land and Water
Resources, and the age of the dwelling unit:
Age of Dwelling Unit Estimated Type of System
0-7 years old septic tank drainfield
8-20 years old septic tank - leach pi-t or drainfield
greater than 20 years old cesspool
2. Age of On-Site Systems
A majority of the on-site systems for which information was available
fell into the 0-7 year old category. However, the Department of Land Water
Resources records were completely biased towards this age category because
their building permit records only extended back to 1972. Therefore, no
meaningful correlation can be stated between age of systems and segment loca-
tions around Otter Tail Lake based on this data alone. Based on the results
of resident interview, however, the following results were tabulated about age
of systems:
Percent of Systems in
Mean Age of System for Homes Various Age Ranges (years)
Type of System Surveyed by WAPORA 0-7 8-20 20+
Septic tank -
drainfield 11.8 years 44% 36% 20%
Septic tank -
leach pit 22.6 years 13% 33% 53%
Holding tank 4.2 years 75% 25% 0%
Cesspool 29.1 years 0% 42% 58%
Outhouse 39.5 years 0% 0% 100%
+ Based on building records and interviews.
3. On-Site System Malfunctions Noted by Homeowners
Malfunctions of septic tanks generally fall into three categories
including:
1) Surface ponding of septic tank effluent
2) Backup of septic tank effluent into dwelling unit
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H
3) Contamination of surface water or groundwater by septic tank effluent
Sixteen residents, or 11% of the 149 interviewed, reported problems with
their on-site systems. All of the problems reported were periodic backups of
sewage. No surface malfunctions were reported or were noted during site
inspections. The backups were primarily due to overloading of the systems on
holiday weekends (3%) and limited hydraulic capacity as a result of high
groundwater (8%). Malfunctions relative to groundwater contamination will be
discussed separately in Section C - "Groundwater Study". The holiday backup
problem displayed no geographical boundaries while high groundwater induced
failures seemed to be located generally in the northeastern section of the
lake in the area between Long Lake, the Otter Tail River North and Otter Tail
Lake. Another area that displayed a relatively high number of malfunctions
was the area between Blanche Lake and Otter Tail Lake. In addition to the
geographic aspects of the malfunctions, these additional facts were noted for
the 16 homes with failures:
Only 5% of the homes had additional water intensive appliances (dish-
washer and clothes washing machine) above and beyond normal appliances
(toilets, sinks, showers)
10% of the homes were 20 years old or older
At least 12% of the homes had cesspools.
It is notable that no ponding of sewage on the surface of the ground was
reported or seen at dwellings that were surveyed. This follows the results of
the EPA-EPIC aerial photography which revealed only one surface malfunction
around that lake.
Most of the problems reported were related to high groundwater levels.
High groundwater levels (less than 6') exist in over 56% of the shoreline
areas around Otter Tail Lake. It is surprising that more homes were not
experiencing difficulty. The Otter Tail Department of Land and Water
Resources standard states that the minimum vertical distance from the bottom
9
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H
of the absorption system to the groundwater table shall be 4 feet. It appears
that a majority of on-site systems are violating this standard. Problems
caused by high groundwater levels appear to be minimized by the following
factors:
Most homeowners were seasonal residents. As such, they generally did
not have water intensive devices such as dishwashers, clothes washing
machines and bathtubs.
Not only were many people seasonal residents, but many of these were
weekend visitors only. The dwelling units generally received very
little use and hence, little wastewater was generated.
Soils in most shoreline areas fall into two soil groups: 1) Salida-
Sioux-Hubbard -- a sandy soil located over well drained soils and 2)
Esterville-Arvilla -- a loamy soil located over sandy, well drained
soils. These soils have been rated by the Soil Conservation Service
as having extremely rapid permeability.
4. Maintenance of On-Site Wastewater Systems
One of the objectives of the sanitary survey was to determine how well
on-site systems were being maintained and whether this factor had a bearing on
the functioning of the systems. In addition to the 11% of homes with malfunc-
tions, 2% were found that had problems related to plumbing. These problems
included roots in the drainage lines and lines obstructed by various mate-
rials. Of the residences interviewed around Otter Tail Lake, the following
results were noted in regard to the regularity of pumping of on-site waste
systems:
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Reasons Stated By Resident For Pumpout
Tank created Homeowners felt
Frequency problem which it should be done
of necessitated periodically for
pumping Percentage pumping good maintenance Other
Resident didn't
know 21% - -
Within last year 22% 70% 16% 14%*
1-3 years 8% 61% 48% 4%+
3-10 years 8% 47% 40% 7%o 7%xx
Greater than 10
years or more 39% - - 100%x
* Holding tanks.
+ Utility work took place in yard.
o Maintenance work on on-site system.
xx Unknown.
x Never had system pumped out.
The 23 residents indicating that they had to pump their on-site systems
frequently (several stated that they pumped several times a seasons) indicates
the possibility that high groundwater may be causing more malfunctions than
homeowners were willing to admit. In most cases where hydraulic overloading
of the on-site system occurred, homeowners reported not using or having water
intensive devices such as dishwashers or clothes washing machine. However, no
other water conservation measures such as low flush toilets or flow constric-
tors were utilized.
Given the high number of systems which were not pumped in 10 years, and
the low number of malfunctions cited by homeowners, pumping of septic systems
doesn't appear to have a bearing on system operation except in cases where
groundwater levels are causing problems. Most systems are only used 3 to 4
months out of the year. The seasonally used systems can recover (decompose
wastes) for the rest of the year. Most maintenance standards for septic
systems state that they should be pumped out once every one to five years.
However, these standards apply to systems that are utilized fully for the
entire year.
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In the case of the systems which were noted as malfunctioning, 80% were
pumped out within the past 4 years. The need for pumping was probably due
primarily to the high groundwater levels rather than drainfields clogging from
lack of pumping and the resulting organic overload.
5. Number of On-Site Wastewater Systems in Noncomplicance with Sanitary
Provisions of Shoreline Management Act
A majority of homes surveyed (56%) were found to be in non-compliance
with the sanitary provisions of the Shoreline Management Act because of either
inadequate lot sizes, inadequate septic tank to well separation, or inadequate
drainfield or leach pit to well separation distances. In another 25% of the
residences no determination could be made as to compliance due to insufficient
information given during the interview. In previous studies it has been
determined that 56% of the shoreline area around Otter Tail Lake had ground-
water depths of less than 6 feet (Ulteig Engineers, 1977). It is possible
that more than 80% of privately owned systems do not comply with the Shoreline
Management Act.
6. Resorts
A majority of resort owners interviewed stated they had met the sanitary
separation distances of the Shoreline Management Act or, if not capable of
meeting the standards, had holding tanks installed. Also, the owners stated
that their potable water supplies were sampled regularly by the State Health
Department and hence, were reticent in allowing WAPORA to take well samples
for this study. However, in order for the resorts to remain open, the wells
must pass the State Health Department water quality tests.
C. GROUNDWATER STUDY
The majority of wells examined in this survey were shallow, driven wells
usually referred to as "sand points". A sand point consists of small diameter
(1-3") galvanized steel pipe which is driven into the ground to a shallow
depth (generally less than 50 feet). Their distance from septic tanks and
disposal fields varied greatly. Some wells were found to be as close as 10
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feet to a drainfield. Many people interviewed only knew the type of wells
they had and had little or no knowledge about either the depth or the age of
the well.
WAPORA collected 75 well water samples for analysis by the Otter Tail
County Health Department. The water samples were analyzed for coliform bac-
teria to determine if there was any direct evidence of sewage contamination of
water supplies. Fecal coliform bacteria are found in the intestines of warm
blooded animals and are universally found in untreated sewage. Presence of
fecal coliform bacteria in wells is presumptive, but not conclusive, evidence
of contamination by sewage. Due to the high number of very old and improperly
protected wells, other parameters had to be evaluated to determine if sewage
was causing the problem or if contamination was due to improper well construc-
tion and protection. Nitrate-nitrogen was chosen as the accompanying para-
meter due to its close link with sewage, its persistence as it travels through
groundwater aquifers, and its public health effects. High levels of nitrate-
nitrogen in a potable water supply can lead to methemoglobinemia ("blue-baby")
in infants.
Of the 75 samples taken, 13 (17%) of them showed some signs of contami-
nation. Of the 13, four (5%) violated drinking water standards. More de-
tailed information on these 13 samples is shown in Table 1. Wells that had
bacterial colony counts of one or more or that had detectable nitrate-nitrogen
levels (1 ppm or greater) were considered to have some evidence of contami-
nation.
Only one well had nitrate-nitrogen levels above 10 ppm, the national
standard set for drinking water. The owner estimated the depth of the well to
be very shallow (between 15 to 20').
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None of the wells sampled were found to have contamination due to both
coliform bacteria and elevated nitrate-nitrogen levels. Two wells showed
signs of fecal contamination but surprisingly had no evidence of nitrate
contamination. Based on this data, no positive link can be made between
on-site sewage disposal and well contamination around Otter Tail Lake. Poor
design and condition of wells is as likely a cause of the documented contami-
nation as inadequate sewage disposal. Of the 13 wells which showed evidence
of contamination, 10 were known to be shallow driven wells. Depth information
was available in only 7 of these wells and ranged from 18 to 42 feet. Design
and depth of the other 3 wells could not be determined. The two wells with
fecal coliform contamination were both over 25 years old.
Segments were analyzed to see if any geographic pattern could be noted
regarding contaminated wells. However, no pronounced pattern was discernible.
D. AQUATIC VEGETATION STUDY
An aquatic vegetation survey was made at six representative sites at
Otter Tail Lake after the sanitary survey. A summary of the biomass data for
Otter Tail Lake stations is provided in Appendix 4. At every station, the
most abundant plant was Chara. Several other plants inhabited the littoral
zone including Cladophora, Potamogeton, Sagittaria, Najas, and Ceratophyllum.
Of these other plants the most abundant were Najas and Potamogeton observed at
Station C (OT 351). Cladophora was present at four of the six stations which
were sampled (Station C-OT351, Station D-OT600, Station E-OT1010, Station
F-OT790). At all stations there was a clear pattern of zonation in which
plant biomass appeared to increase with depth and distance offshore.
Cladophora was also noted during the sanitary survey investigation and was
found in segments 1, 2, 15, 16, 17, 20, 21, 26, and 29. However, it appeared
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that algae was floating in the water column as opposed to growing attached on
suitable substrates such as rocks or boulders. It is also felt that wave
action was severe enough to have dislodged the plant material to the windward
side of the lake. Because of these facts, it is felt that no meaningful
correlation can be made between Cladophora location and septic leachate plumes
V. SUMMARY/CONCLUSIONS
GENERAL
Of the homes surveyed, 81% were occupied by seasonal residents.
Fourteen percent of the seasonal residents interviewed plan on retir-
ing in the Otter Tail Area (14%).
ON-SITE WASTEWATER SYSTEMS
Fifty six (56) percent of the residences that were interviewed did not
meet the Otter Tail County Shoreline Management Act sanitary design
provisions.
Only 11% of the residents surveyed claimed to have malfunctioning
septic systems. However, based on careful review of maintenance
practices, a 20% malfunction rate seems to be more realistic.
Most of the malfunctions noted via the survey process were
related to high groundwater levels. In addition, analysis of main-
tenance records shows that high groundwater levels are causing resi-
dents to pump their systems quite often - in many cases several tines
a season.
Approximately 4% of the dwelling units around Otter Tail Lake depend
on holding tanks for on-site waste disposal. These are lots that have
severe limitations for use of conventional septic tank-soil absorptioa
systems (ST-SAS) due to snail lot size or high groundwater conditions.
It is felt that many more dwelling units would have holding tanks if
they were in complete compliance with the Shoreline Management Ordi-
nance as it exists today.
A large number of residents reported never having pumped their septic
tanks. The minimal maintenance of these on-site systems is due in
part to the seasonal occupancy of most dwellings units. These systems
are allowed to recover from the organic load which is received during
only one season of the year. This helps to explain why no malfunc-
tions of on-site systems were reported due to clogging of drainfields.
On-site waste systems malfunctions and/or incidences of well contami-
nation around Otter Tail Lake appear to be scattered with no one seg-
ment exhibiting a high incidence of either problem.
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Most segments were dominated by the use of either septic tanks and
drainfields or septic tanks and leach pits. However, three segments
8, 9, and 28 were noted as having a majority of holding tanks. This
would indicate areas with severe limitations for septic systems due
to either small lot sizes and/or limiting environmental conditions
such as high groundwater levels.
One major conclusion can be reached regarding the percentage of mal-
functions noted by homeowners (11%) versus the percentage of resi-
dences in non-compliance with the sanitary provisions of the Shoreline
Management Act (56% or more). Noncompliance does not necessarily mean
that a system will malfunction. On the contrary, most systems seem to
be performing remarkably well despite the high groundwater levels and
minimum amount of maintenance.
WELLS/GROUNBWATER
Most on-lot wells for dwelling units are driven sand points that are
less than 50 feet deep.
Few (17%) of the wells sampled in the groundwater study showed evi-
dence of any contamination by coliform bacteria or nitrates. Of the
13 wells with detectable contamination, four are judged to be unsafe
for human consumption at the time of sampling.
Data for the wells with detectable contamination does not indicate
that on-site sewage disposal systems are sources of the contamination.
Several of the wells which had evidence of contamination met the well
to septic tank and drainfield separation distances established in the
Shoreline Management Act. These wells were in almost all cases shal-
low and driven. This points out that the wells themselves may not be
constructed properly or that they should be drilled to a greater depth.
AQUATIC VEGETATION STUDY
Cladophora was identified at 4 of the 6 sampling stations in the inten-
sive aquatic vegetation survey. Cladophora was also identified at 29%
of the segments in the sanitary survey. However, it is felt that no
meaningful correlation can be made between Cladophora location and
septic leachate plumes and that the growth of the algae may be related
to the overall productivity of the lake as opposed to specific stimula-
tion by septic tank effluent.
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APPENDIX 1
Sanitary Survey Form
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SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
(Page One)
Resident: Study Area:
Owner: Surveyor/Date:
Address of Weather:
Property:
Lot Location: Approximate Lot Dimensions:
Tax Map Designation: feet by feet
Preliminary Resident Interview
Age of Dwelling: years Age of sewage disposal system: years
Type of Sewage Disposal System:
Maintenance: years since septic tank pumped. Reason for pumping:
years since sewage system repairs (Describe below)
Accessibility of septic tank manholes (Describe below)
Dwelling Use: Number of Bedrooms: actual, potential, Planned
Permanent Residents: adults, children
Seasonal Residents: , length of stay
Typical Number of Guests: , length of stay
If seasonal only, plan to become permanent residents: In how many years?
Water Using Fixtures (Note "w.c." if designed to conserve water):
Shower Heads Kitchen Lavoratories Clothes Washing Machine
Bathtubs Garbage Grinder Water Softener
Bathroom Lavoratories Dishwasher Utility Sink
Toilets Other Kitchen Other Utilities
Plans for Changes:
Problems Recognized by Resident:
Resident Will Allow Follow-Up Engineering Studies: Soil Borings Groundwater
Well Water Sample
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SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
(Page Two)
Water Supply
Water Supply Source (check one)
Public Water Supply
Community or Shared Well
On-Lot Well
Other (Describe)
If public water supply or
community well:
If shared or on-lot well:
Fixed Billing Rate $
Metered Rate $
Average usage for prior year:
Drilled Well
Bored Well
Dug Well
Driven Well
Well Depth (if known):
Well Distance:
feet total
feet to house
feet to soil disposal area
Visual Inspection: Type of Casing
Integrity of Casing
Grouting Apparent?
Vent Type and Condition
Seal Type and Condition
Water Sample Collected:
No
Yes
(Attach Analysis Report)
feet to water table
feet to septic tank
feet to surface water
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SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
(Page Three)
Surveyor's Visual Observations of Effluent Disposal Site:
Drainage Facilities and Discharge Location:
Basement Sump
Footing Drains
Roof Draings
Driveway Runoff
Other
Property and Facility Sketch
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INDEX
Alternatives, iii, v, vi, 15, 21-22, 28,
29
composite, iii, vi
Facility Plan, iii, vi, 1
value of, vi
Limited Action, iii, iv, v, vi, 17-18,
35
costs, iii, v
Impact on population growth, iv
value of, vi
No Action, iii, v, 27, 32, 35
costs, v, 27-28
environmental effects, 31
Archaeology. See Environmentally sensi-
tive areas
Bacterial contamination, 1, 3, 8, 20
sampling sites, 6-
Commercial establishments, 18
Construction Grants Program. See
Funding, Federal
Cost effectiveness, 1, 25
Draft Environmental Impact Statement,
iii, v-vi, 3-4, 11, 15, 17-18, 23-26, 28
recommendations, iii, iv
studies reported in, 3
studies completed after. See Field
studies
Drinking water contamination, 9
Economic impacts, iii, 1, 35-36, 39
Environmental consequences, 3
Facility Plan, 37-39
Modified Limited Action Alternative,
37-40
Environmentally sensitive areas, 35
Eutrophication, 1, 3, 11
Facility Plan, iii, 1, 15, 18, 28, 29
costs, iii, 15
map of proposed action, 16
Field studies, iii, iv, 3, 17, 31
aerial photographic survey, iii, 3
aquatic productivity study, iii, iv,
11, 32
groundwater survey, iii, iv, 4, 11
partial sanitary survey, iii
septic leachate surveys, iii, iv, 4,
8, 11
site-specific analyses, iii, iv
well water sampling, 8
contamination, 9
Final Environmental Impact Statement,
v, vi
alternatives, 29
issues examined, 1
recommendations, v, vi
Funding:
Federal, 1, 18, 21-23, 25, 27
State, 1
Groundwater, 17, 31, 38
effluent plumes, 3-4, 8, 11, 20, 22,
38
map,5,10
flow patterns, map, 7, 12, 32
survey, iii, iv, 4, 11
chemical analysis, 13
well water sampling, 8, 11, 17, 23,
32, 38
See also Bacterial contamination
Lakes, iii
Deer Lake, 31-32, 37
Lake Blanche, iii, 3-4, 8y/ 31-32, 37
Long Lake, iii, 3-4, 8, 31-32, 37
Nylander Lake, 8, 11
Round Lake, iii, 3, 31-32, 37
Walker Lake, iii, 3-4, 8, 31-32, 37
See also Otter Tail Lake
Land use, iv, 33
Management alternatives. See Madified
Limited Action Alternative
Modified Limited Action Alternative, v, 17,
18, 22-23, 25, 27
community management, 22
alternatives, 23-25
existing systems, 19
implementation, vi, 25
technology selection, 18, 21, 26, 38
value of, vi
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Otter Tail County Shoreland Management Water quality, iii-iv, 37
Ordinance, iii, 4, 8, 26-28, 32, 35 impacts, iii, 1, 13J 27
modeling, iii
Otter Tail Lake, iii, 1, 3-4, 8, 11, 19,
22-25, 28-39, 31-32, 35, 37-39
Phosphorus, 31, 37
Population, iii, 38
displacement pressure, 39-40
growth constraints, iv
induced growth, iii, 3
projections, iv, 15, 32, 34-35, 38
Proposed Service Area. See Study Area
Public health, iv, 3
hazards, 1, 17, 22
Public Hearing:
issues raised, iv
Resorts, 18, 29
Rural Lake Projects, iii
Sanitary Review Board, 26
Secondary impacts, iii, 3
Septic systems, 1, 11, 25
and water quality, 1
Sewage systems, iii, 1, 15, 29
Small Waste Flows District:
feature of, iv, v
Study Area, iii, iv, 2, 17-18, 22, 25,
27, 31-32, 35
Trophic status, iii, 37
See also Eutrophication
Wastewater management, 3, 32
Wastewater treatment, iii, 23, 27
centralized systems, iii-iv
off-site systems, 21-22, 28-29, 32
35, 37-38
on-site systems, iii-iv, 4, 17-18, 21-22,
24-27, 29, 32, 35, 38-39
problems associated with, 3
replacement and rehabilitation of, iv, 19
requirements, vi
spray irrigation, iii
US GOVERNMENT PRINTING OFFICE 1980750-266
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